RCRA Peridit Policy Compendium Update Package Revised 1992


United States	SoGd Waste and	EPA530-H-skj-u i o
Environmental Protection Emergency Response	April 1992
Agency	(OS-340)
a ppA RCRA Permit Policy
Compendium Update
Package
Revision I - April 1992
Printed on Recycled Paper

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Revised
Volume 1
Replace the entire
August 1991 Volume 1
(including user's guide
and index) with the
Attached Revised
Volume 1
(New diskettes for the
Revised Index are also
included and should
replace the old dBase file)

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RCRA PERMIT POLICY
COMPENDIUM	
User's Guide
ATKlfl 104/78 kp

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RCRA PERMIT POLICY COMPENDIUM: USER'S GUIDE
OVERVIEW
The RCRA Permit Policy Compendium is a reference for Regional and
State permit writers which consists of Headquarters' permitting
policies and procedures. The Compendium volumes include this
Users' Guide, a key word index, and reference memoranda, letters,
Office of Solid Waste and Emergency Response (OSWER) Directives,
and other documents organized chronologically within subject
categories.
The Compendium was originally compiled in late 1985. This
updated Compendium includes documents issued through
December 31, 1991.
For these compilations, the files of EPA Headquarters Office of
Solid Waste Divisions and Branches were reviewed to identify
memoranda, letters, directives, and other documents that set
forth policies and interpretations relevant to the RCRA permit
program. The documents identified as relevant were then
organized, according to a system based on the structure of the
OSWER Directives System. Each document is assigned an unique
number which both categorizes the document by general topic area
and identifies the year in which the document was written. The
numbering system uses the same basic categories as the OSWER
Directives System.
KEYWORD TNPE3
A key word index is included in Vol. I to assist the user in
identifying and locating relevant documents. The index,
organized in alphabetical order, lists the topic and the
documents which are relevant to the topic, identified by title,
document number and date. The key word index groups related
topics and cross references topics which may be relevant. Subkey
words have been identified as a means to specify groups of titles
which may fall within a broader key word category.
Summaries of documents which had been included in the original
Compendium have been deleted. Users of the original Compendium
did not find them useful.
After a key word listing, there may be a "See 	 " or "See
also 	." In the "See 	" case, the documents relating
to the key word have been grouped into another listing. For
example, the listing for "Absorbents" refers the user to "Liquid
Waste." Similarly, the listing for "Appeal" refers the reader to
"Permit Process," but also reminds the user to "See also
Closure1", since appeals of closure plans also may be relevant.

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As an alternative method to search for a specific memo, diskettes
with the key word index on dBase III Plus has been included in
this package. Additional information on loading, indexing, and
searching in this database can be found in Appendix I.
DOCUMENTS INCLUDED
The Compendium incorporates a wide variety of documents that
might be useful to staff working in the field of RCRA permitting.
The Compendium includes relevant RCRA permitting memoranda,
letters, OSWER Directives, Regulatory Interpretive Letters
(RILs), Program Interpretation Guidelines (PIGs), RCRA
Reauthorization Statutory Interpretations (RSIs), RCRA/Superfund
Hotline Monthly Status Reports and Summaries of Permit Assistance
Team (PAT) Comments. Although the Compendium includes RILs,
PIGs, RSIs, and PATs from the previous years, the Office of Solid
Waste no longer issues these documents.
Documents that are internal Headquarters correspondence or
express preliminary thoughts or comments were not included in the
Compendium. Only those documents providing a clear
interpretation of Agency policy or procedures have been compiled.
ORGANIZATION
The RCRA Permit Policy Compendium volumes include this Users'
Guide, a key word index, and memoranda, letters, and other
documents organized chronologically with subject categories. The
source documents include all documents issued through
December 31, 1991. OSWER Directives are the first documents in
any section. They are ordered chronologically as well.
There are eleven volumes in this reference document:
Volume
Number Document Reference Numbers
.0*
I -
I
-

II
-
9420.1980-9434.1991
III
—
9441.198 0-9441.1986
IV
-
9441.1987-9441.1991
V
-
9442.1980-9444.1986
VI
-
9444.1987-9457.1991
VII
—
9460.1980-9482.1991
VIII
-
9483.1980-9489.1991
IX
—
9490.1980-9521.1991
Broad Subject
	Categories	
User's Guide, Key Word Index
Hazardous Waste Management
Identification of Hazardous
Waste
Identification of Hazardous
Waste (cont'd)
Characteristics and Lists of
Hazardous Waste
Lists of Hazardous Waste,
Generators
Transporters, TSDFs
TSDFs (cont'd)
Recyclable Materials,
Permitting

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X - 9522.1980-9528.1991	Permitting Procedures,
Interim Status
XI - 9530.1980-9581.1991	Air Emissions, State
Authorization, Land
Disposal/Restrictions,
Subtitle D
NUMBERING SYSTEM
All source documents are identified by a reference number in the
upper right hand corner of the page. The document reference
number is also in the key word index. This reference numbering
system is designed to be consistent with the Office of Solid
Waste and Emergency Response (OSWER) Directives System which
generally follows the organizational structure of the Code of
Federal Regulations.
Each document reference number consists of a prefix of four
digits preceding a decimal point and additional numbers in
various forms following the decimal point. The basic form used
for numbering the Compendium documents is illustrated below;
XXXX*1986(09)
XXXX « Subject category number
1986 = The year of issue of the document
(09) = Chronological number within the year of issue and
the subject category.
This document would be the ninth document of 1986 in the
category XXXX.
Subject Category Prefix
The first four digits indicates the document reference
number to the subject category into which the document has
been classified, based on the structure of the RCRA
regulations including Subtitles C, D and J. Each subject
category refers to a subsection of the RCRA regulations or
relevant statutory issue (such as Waste Minimization).
Thus, a document is assigned a four digit category number
based on the sub-section of the regulations or the issue
which is addressed in the document. Appendix II of this
Users' Guide lists the subject category numbers and
identifies, if appropriate, the 40 CFR Part or subpart
associated with each number. As demonstrated in Appendix
II, there are a number of sections within the OSWER
Directives that are "Reserved." These sections correspond
to regulations which do not exist at this time.

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All documents assigned to any one category number are
located together in the reference volumes under the
appropriate category number. Within each category,
documents are ordered chronologically.
Document Specific Suffix
The numbers found after the decimal point of the reference
number indicate the year and, within the year, the
chronological order in which the document was issued.
DELETED REFERENCE DOCUMENTS AND SUMMARIES
Since the original compilation of the Compendium a number of
documents have been deleted because they are now out-of-date or
replaced by a more recent document. As a result, there will be a
missing number in the chronological numbering of the documents
and summaries where a document has been deleted.
LOCATING INFORMATTON
The Compendium is a reference tool that can be used in two ways,
depending on the needs of the user. Information may be found
referring to individual subject category sections or by using the
key word index.	_
In reviewing individual subject categories, the user will be able
to find all documents concerning a specific subject.
Alternatively, by referring to the key word index, the user may
locate the exact document of interest without reviewing all
documents in the category. As noted earlier, the key word index
also serves to remind the user of other topics which may be
relevant to the particular issue in question. Appendix III
contains a list of available keyword and subkey words that sure in
the index.
Asterisks
The document titles preceded by an asterisk in the key word
index are excerpts from RCRA Hotline summaries. These are
so marked so as to clearly differentiate them from the
letters and memoranda.
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U

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DISCLAIMER
The compilation of documents in this Compendium, as well as the
policies, procedures and interpretations outlined in the
documents themselves, is intended solely for the guidance of
employees of the U.S. Environmental Protection Agency. This
compilation may not include all documents discussing Agency views
on particular subjects. In addition, these documents are not
intended and cannot be relied upon to create any rights,
substantive or procedural, enforceable by any party in litigation
with the United States. The views expressed in these documents
do not necessarily reflect the current position of the Agency,
and EPA reserves the right to act at variance with these views or
to change them at any time without public notice.
- 5 -
n

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Loading, Indexing and Searching
in dBase XXI Plus

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Loading and using the keyword index on dBase III Plus
The keyword index has been divided into 2 files due to size.
These files should be merged and saved on the computer hard drive
to allow the entire document to be indexed and searched. The
following instructions will allow the user to merge the files
together and save the files as one file on the computer hard
drive.
Insert disk labelled C0MP2.DBF into disk drive.
Type: [source drive] > copy C0MP2.DBF to [target drive]
Enter dBase III Plus. Typically, this is done by typing either
"dBase" or "db" at the prompt.
The system will display a copyright screen and will prompt the
user to press [INTER]
Press [ENTER] key
— Use the menu to retrieve "C0MP2.DBF" —
1.	The cursor arrows should be used to highlight "SET UP" on
the menu
2.	Press [ENTER] key to access the database file.
3.	Use cursor key to identify the drive where the file is
located and Press [ENTER].
4.	Highlight "C0MP2.DBF" and Press [ENTER]
The computer will ask if the file is indexed? Press [N]
The file is now retrieved.
C0MP1. DBF must now be merged with C0MP2. DBF. (The C0MP2. DBF file
should already be open)
*
Press [ESC] to receive dBase dot prompt
Type: APPEND FROM [source drive]: C0MP1.DBF
This will add the records in COMP1.DBF to C0MP2.DBF
"COMP2 .DBF" will now be the file name for entire keyword index on
the hard drive.
The index can now be indexed or searched in its entirety.
- 1 -
°i

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Indexing
dBase III Plus is a management system which allows the user to
organized and manipulate data. When "compend.dbf •• is retrieved
without indexing, it is in the order that the data elements were
entered. To manipulate the data fields for each record entry,
the file must be indexed.
To index the file as it appears in the key word index of
Vol. I
1.	Press [ESC] at the menu headings until the dot prompt
appears.
2.	Type
[INDEX ON SUBSTR[KEYWORD,1,25]+
SUBSTR[SUBKEYWORD,1,25]+
SUBSTR[TITLE,1,30] to KEY.NDX]
The file will index to 100%
3.	Press [F2] to return to dBase menu
The file is now indexed and the user can browse through the
file in the manner it is presented in Volume I.
Searching
dBase III Plus allows the user to search for particular data
elements within the file. Therefore, if the user knows the date
of a memo, the file can be searched for all the memos written on
a specific date. This can be done for all the data fields
(KEYWORD, SUBKEYWORD, IDNUMBER, TITLE AND DOCDATE).
To SEARCH for specific memos:
Press [F2]
Select Retrieve Menu
^ Select Display
Select Build A Search Condition
Select Field name [options include — KEYWORD, SUBKEYWORD,
IDNUMBER, TITLE, DOCDATE]
Select = Equal to
Type [Search Condition, e.g., 10/02/91], press [ENTER]
Select No More Conditions
Select Execute Command
The system displays the record numbers for all the memos dated
10/02/91
For more information on data manipulation, indexing, and
searching consult a dBase III Plus Reference Book.
- 2 -
»CS

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APPENDIX II
SUBJECT CATEGORY NUMBERING SYSTEM

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9400.00
GENERAL OSW POLICY AND PROCEDURES
9410.00
9420.00
9430.00
9431.00
9432.00
9433.00
9434.00
9435.00-
9439.00
9440.00
9441.00
9442.00
9443.00
9444.00
9445.00
9446.00-
9449.00
9450.00
9451.00
9452.00
9453.00
9454.00
9455.00
9456.00
9457.00-
9459.00
9460.00
9461.00
9462.00
9463.00
9464.00-
9469.00
RESERVED
RESERVED
HAZARDOUS WASTE MANAGEMENT SYSTEM (Part 260}
GENERAL (Subpart A)
DEFINITIONS (Subpart B)
RULEMAKING PETITIONS (Subpart C)
OTHER FEDERAL AGENCIES
RESERVED
IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
(Part 261)
GENERAL
CRITERIA FOR IDENTIFYING THE CHARACTERISTICS
OF HAZARDOUS WASTE AND LISTING HAZARDOUS
WASTES
CHARACTERISTICS OF HAZARDOUS WASTE
(Subpart C)
LISTS OF HAZARDOUS WASTE (Subpart D)
APPENDICES
RESERVED
GENERATOR STANDARDS (Part 262)
GENERAL (Subpart A)
MANIFEST (Subpart B)
PRE-TRANSPORT REQUIREMENTS (Subpart C)
RECORDKEEPING AND REPORTING (Subpart D)
SPECIAL CONDITIONS (Subpart E)
IMPORTS OF HAZARDOUS WASTE (Subpart F)
RESERVED
TRANSPORTER STANDARDS (Part 263)
GENERAL STANDARDS (Subpart A)
COMPLIANCE WITH THE MANIFEST,
RECORDKEEPING, AND REPORTING (Subpart B)
HAZARDOUS WASTE DISCHARGES (Subpart C)
RESERVED
- 1 -
• <7^

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9470.00
9471.00
9472.00
9473.00
9474.00
9475.00
9476.00
9477.00
9478.00
9479.00
9480.00
9481.00
9482.00
9483.00
9484.00
9485.00
9486.00
9487.00
9488.00
9489.00
9490.00
9491.00
9492.00
9493.00
9494.00
9495.00
9496.00
9497.00
9498.00
9499.00
9500.00
9501.00
9502.00
9503.00
TSDF ADMINISTRATIVE REQUIREMENTS (Parts 264 and
265)
GENERAL (Subpart A)
GENERAL FACILITY STANDARDS (Subpart B)
PREPAREDNESS AND PREVENTION (Subpart C)
CONTINGENCY PLAN AND EMERGENCY
PROCEDURES (Subpart D)
MANIFEST SYSTEM, RECORDKEEPING AND
REPORTING (Subpart E)
CLOSURE AND POST-CLOSURE (Subpart G)
FINANCIAL RESPONSIBILITY REQUIREMENTS
(Subpart H)
RESERVED
TSDF TECHNICAL REQUIREMENTS (Parts 264 and 265)
GROUND WATER PROTECTION STANDARDS
(Subpart F)
CONTAINERS (Subpart I)
TANKS (Subpart J)
SURFACE IMPOUNDMENTS (Subpart K)
WASTE PILES (Subpart L)
LAND TREATMENT (Subpart M)
LANDFILLS (Subpart N)
INCINERATORS (Subpart 0)
MISCELLANEOUS UNITS (Part 264, Subpart X, Part
265, Subparts P, Q and R)
STANDARDS FOR MANAGING SPECIFIC HAZARDOUS WASTES
AND SPECIFIC TYPES OF FACILITIES (Part 266)
SUBPART A (RESERVED)
SUBPART B (RESERVED)
RECYCLABLE MATERIALS USED IN A MANNER
CONSTITUTING DISPOSAL (Subpart C)
HAZARDOUS WASTE BURNED FOR ENERGY RECOVERY
(Subpart D)
SUBPART E (RESERVED)
RECYCLABLE MATERIALS USED FOR PRECIOUS METAL
RECOVERY (Subpart F)
SPENT LEAD-ACID BATTERIES BEING RECLAIMED
(Subpart G)
RESERVED
PERMITTING POLICIES
PERMITTING PRIORITIES
CORRECTIVE ACTION
SPECIAL PERMITTING UNIVERSE
- 2 -

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9504.00
9505.00
9506.00
9509.00
9510.00
9520.00
9521.00
9522.00
9523.00
9524.00
9525.00
9526.00
9527.00
9528.00
9529.00
9530.00
9531.00
9532.00
9533.00
9534.00
9535.00
9359.00
9540.00
9541.00
9542.00
9543.00
9544.00
' 9550.00
9551.00
9552.00
9553.00
9554.00
9555.00
9556.00
9959.00
COMPLIANCE AND ENFORCEMENT
PUBLIC PARTICIPATION IN PERMITTING ACTIVITIES
RESERVED
RESERVED
PERMITTING PROCEDURES (Parts 124 and 270)
GENERAL PROGRAM REQUIREMENTS (Part 124,
Subpart A)
GENERAL INFORMATION (Part 270, Subpart A)
PERMIT APPLICATION (Part 270, Subpart B)
PERMIT CONDITIONS (Part 270, Subpart C)
CHANGES TO PERMITS (Part 270, Subpart D)
EXPIRATION AND CONTINUATION OF PERMITS (Part
270, Subpart E)
SPECIAL FORMS OF PERMITS (Part 270, Subpart F)
INTERIM STATUS (Part 270, Subpart G)
RESERVED
AIR EMISSION STANDARDS FOR OWNERS AND
OPERATORS OF HAZARDOUS WASTE TSDFs
GENERAL (Subpart A)
RESERVED
RESERVED
EQUIPMENT LEAKS AND PROCESS VENTS (Subpart C)
RESERVED
STATE AUTHORIZATION (Part 271)
FINAL AUTHORIZATION (Subpart A)
INTERIM AUTHORIZATION (Subpart B)
ASSESSMENT OF STATE CAPABILITIES
RESERVED
LAND DISPOSAL RESTRICTIONS (Part 268)
GENERAL (Subpart A)
RESERVED
PROHIBITION ON LAND DISPOSAL WASTE SPECIFIC
PROHIBITIONS GROUP (Subpart C)
TREATMENT STANDARDS (Subpart D)
PROHIBITIONS ON STORAGE (Subpart E)
RESERVED
3

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9560.00
WASTE MINIMIZATION
9560.00
9561.00
9562.00
9569.00
9570.00
9571.00
9572.00
9573.00
9574.00
9575.00
9579.00
9580.00
9581.00
9582.00
9583.00
9589.00
RESERVED
POLICY STATEMENTS
RESERVED
SUBTITLE D
MINING HASTES
STATE PROGRAMS
MUNICIPAL WASTE COMBUSTION
HOUSEHOLD HAZARDOUS WASTE
RESERVED
ADMINISTRATIVE DIRECTIVES
RCRA GRANT FUNDS
CORRESPONDENCE
RESERVED
- 4 -
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f-s

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APPENDIX III
LIST OF EEY WORDS AND SUBKEY WORDS

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KEY WORD LIST
ABSORBENTS (see Liquid Waste)
ACCUMULATION (see Generators? see also Tank Systems)
ACL (see Alternate Concentration Limit, Groundwater
Monitoring)
ACTIVE/INACTIVE FACILITY (see Treatment, Storage, Disposal
Facilities)
ACTIVE INGREDIENT (see Listed Hazardous Waste under "Sole
Active Ingredient")
ADMINISTRATIVE ORDER (see Enforcement, Corrective Action)
AEROSOL CANS (see Hazardous Waste Identification)
AGRICULTURAL WASTE (see also Exclusions)
•	FIFRA
•	Pesticides
AIR EMISSIONS
ALTERNATE CONCENTRATION LIMIT (ACL) (see Groundwater
Monitoring? see also Appendix VIII)
ANALYTIC METHODS (see also Appendix VIII, Appendix IX,
SW-846)
•	Detection Limits
•	Laboratory Analysis
•	Sample Analysis
•	Sampling
•	Sampling Plan
ANCILLARY EQUIPMENT (see Tank Systems)
API SEPARATOR SLUDGE (see also Petroleum Refinery Waste,
Sludge, Wastewater)
APPEALS (see Permit Process? see also Closure)
APPENDIX IX (see also Appendix VIII, Groundwater Monitoring)
•	Skinner List
APPENDIX VIII (see also ACLs, Analytic Methods, Appendix IX,
Groundwater Monitoring, Hazardous Constituents, Sampling)
AQUEOUS WASTE (see Characteristic Hazardous Waste)
AQUIFER (see Groundwater Monitoring)
ASBESTOS (see Hazardous Waste Identification)
ASSESSMENT MONITORING (see Groundwater Monitoring)
ATOMIC ENERGY ACT (AEA) (see Mixed Waste)
' AUTHORIZED STATES (see State Authorization)
BAGHOUSE DUST (see Incineration, Sludge)
BALLAST FLUID (see Hazardous Waste Identification)
BATTERIES (see Solid Waste, Hazardous Waste Identification)
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT) (see Land Disposal
Restrictions)
BEVILL EXCLUSION (Amendment) (see Mining Waste)
BIENNIAL REPORTS (see Generators)
BIF RULE (see Incineration)
BIOLOGICAL TREATMENT (see Treatment)
BLASTING CAPS (see Characteristic Hazardous Waste)
BLENDING AND BURNING (see Burning and Blending)
BOILER ( Incineration)
• SUBKEY WORD

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BOILER SLAG (see Mining Waste)
BOND RATINGS (see Financial Responsibility)
BULK LIQUIDS (see Land Disposal Restrictions, Liquid Wastes)
BURNING AND BLENDING (see also Incineration, Used Oil)
•	Burning Hazardous Waste Fuel
BURNING HAZARDOUS WASTE FUEL (see Burning and Blending)
BY-PRODUCT (see Solid Waste; see also Mixed Waste)
CALIFORNIA LIST (see Land Disposal Restrictions)
CAPABILITY ASSESSMENTS (see State Authorization)
CAPACITY (see Siting)
CARBON FILTERS (see Hazardous Waste Identification)
CASE-BY-CASE EXTENSION (see Land Disposal Restrictions)
CEMENT KILN (see Incineration; see also Hazardous Waste Fuel)
CERCLA (SUPERFUND) (see RCRA/CERCLA Interface)
CERCLA/RCRA INTERFACE (see RCRA/CERCLA Interface)
CERTIFICATION (see also Closure, Generators, Post-Closure, Waste
Minimization)
CHANGE DURING INTERIM STATUS (see Interim Status Process)
CHANGING FEDERAL REGULATIONS (see State Authorization)
CHARACTERISTIC HAZARDOUS WASTE (see also SW-846, Listed
Hazardous Waste, Hazardous Waste Identification)
•	Aqueous Waste
•	Blasting Caps
•	Corrosive Wastes
•	Dilution
•	EP Toxicity
•	Explosive Wastes
•	Ignitability
•	Lead
•	Reactive Wastes
•	TCLP
CHEMICAL DEODORANTS (see Hazardous Waste Identification)
CHEMICAL STABILIZATION (see Treatment)
CHLORINATION TANK (see Listed Hazardous Waste)
CHROMIUM (see Exclusions)
CIVIL ACTION (see Enforcement)
CIVIL ENFORCEMENT (see Enforcement; see also Compliance)
CLEAN AIR ACT (see also Incineration, Used Oil, TSDFs)
' CLEAN CLOSURE (see Closure Process)
CLEAN WATER ACT (see also Exclusion)
•	NPDES Facilities
•	Wastewater
CLEANUP STANDARDS (see Corrective Action)
CLOSURE (see Interim Status Process)
CLOSURE PLAN (see Closure Process)
CLOSURE PROCESS (see also Interim Status Process, Post-Closure,
TSDF)
•	Clean Closure
•	Closure Plan
•	Closure Requirements
•	Closure Standards
• SUBKEY WORD

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•	Partial Closure
•	Permitting
•	Public Participation
CLOSURE REQUIREMENTS (see Closure Process)
CLOSURE STANDARDS (see Closure Process)
COAL (See Mining Waste)
COAL TAR/COKE (see also Hazardous Waste Fuels)
COLLECTION PROGRAMS (see Household Hazardous Waste)
COMMERCIAL CHEMICAL PRODUCTS (see Listed Hazardous Waste)
COMPATIBILITY (see also Containers, Liners, Minimum Technology
Requirements, TanJc System)
COMPLIANCE (see also Enforcement, Interim Status Process)
•	Inspections
COMPLIANCE MONITORING (see Groundwater Monitoring)
COMPLIANCE SCHEDULES (see also Corrective Action Enforcement,
State Authorization)
COMPRESSED GAS CYLINDERS (see Hazardous Waste Identification)
CONSTRUCTION (see also Interim Status Process)
•	New Unit
CONTAINERS
•	Empty
CONTAINMENT (see Secondary Containment)
CONTAMINATED GROUNDWATER (see Hazardous Waste Identification)
CONTAMINATED SOIL (see Hazardous Waste Identification; see also
Corrective Action)
CONTINGENCY PLAN
•	Spills	__
CONTINUING RELEASES (see Corrective Action)
CORPORATE GUARANTEE (see Financial Responsibility)
CORRECTIVE ACTION (see also Groundwater Monitoring,
Enforcement, Interim Status Process, Permit Conditions)
•	Administrative Order
•	Cleanup Standards
•	continuing Releases
•	RCRA Facility Assessment (RFA)
•	Regulated Unit
•	Release
•	Remediation
•	Solid Waste Management Units (SWMUs)
•	Voluntary Cleanups
CORROSIVE WASTES (see Characteristic Hazardous Waste)
COST (see Financial Responsibility)
COST ESTIMATES (see Financial Responsibility)
COVER DESIGN (see Final Cover)
CREOSOTE (see Wood Treatment, Hazardous Waste Identification)
CYANIDE (see Hazardous Waste Identification; see also SW-846)
DATA
•	Noncompliance
DE MINIMIS (see also Listed Hazardous Waste)
DEADLINES (see Permit Process; see also State Authorization)
• SUBKEY WORD

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DEFINITION (see Solid Waste, Hazardous Waste Identification,
Regulated Unit)
DELEGATION OF AUTHORITY (see Permit Process)
DELISTING (see also Appendix VIII, Appendix IX, Hazardous
Waste Identification, Characteristic Hazardous Waste)
•	Temporary Exclusion
•	VHS Model
DENIAL (see Permit Process under "Permit Denial")
DENTAL AMALGAM (see Scrap Metal)
DEPARTMENT OF DEFENSE (DOD) (see Federal Facilities)
DEPARTMENT OF ENERGY (DOE) (see Federal Facilities; see also
Mixed Waste)
DEPARTMENT OF TRANSPORTATION (DOT) (see Generators; see also
Transporters)
DERIVED-FROM RULE (see also Mixture Rule)
•	Residue
DESTRUCTION REMOVAL EFFICIENCY (DRE) (see Incineration)
DETECTION LIMIT (see Analytical Methods)
DETECTION MONITORING (see Groundwater Monitoring)
DIBUTYLIN DIFLUORIDE (see Hazardous Waste Identification)
DILUTION (see Characteristic Hazardous Waste; see also Land
Disposal Restrictions)
DIOXIN (see also Listed Hazardous Waste, Land Disposal
Restrictions, RCRA/CERCLA Interface)
DISCARDED MATERIALS (see Solid Waste; see also Land Disposal
Restrictions, RCRA/CERCLA Interface)
DISCHARGE (see Wastewater; see also Spills)
DISPOSAL (see also Land Disposal Facilities, Land Disposal
Restrictions, Recycle, TSDF)
DO-IT-YOURSELFERS (DIYERS) (see Used Oil)
DOUBLE LINER (see Minimum Technology Requirements)
DRE (see Incineration, under "Destruction Removal Efficiency")
DREDGED SEDIMENT (see Hazardous Waste Identification)
DRILLING FLUIDS (see Energy Exploration Wastes)
DRINKING WATER
DRIP PADS
DRUM SHREDDING UNIT (see Treatment)
DUST
' DUST SUPPRESSION (see also HSWA, Disposal, Used Oil)
ELECTRIC ARC FURNACE (see Hazardous Waste Identification,
Incineration)
ELECTROPLATING (see also Listed Hazardous Waste, Solvents)
•	Pickle Liquor
•	Zinc Plating
ELEMENTARY NEUTRALIZATION UNITS (see Exclusions)
EMERGENCY PERMIT
EMISSION CONTROL WASTES (see Sludge)
EMPTY (see Containers, Tank System)
ENERGY EXPLORATION WASTES (see also Mining Waste)
•	Drilling Fluids
• SUBKEY WORD
3.0

-------
ENFORCEMENT (see also Compliance)
•	Administrative Order
•	Enforcement Action
EP TOXICITY (see Characteristic Hazardous Waste)
EPA I.D. NUMBER (see also Generators, Transporters, TSDF,
Notification)
•	Identification
•	Identification Numbers
EQUIVALENCY (see Test Methods)
EXCLUSIONS (see also Agricultural Waste, Hazardous Waste
Identification, Recycle, Solid Waste, Wastewater)
•	Chromium
•	Elementary Neutralization Units
•	Exemption
•	Filter Press
•	Fossil Fuels
•	Gaseous Emissions
•	Mining Waste
•	Totally Enclosed Treatment Units
EXEMPTION (see Exclusions)
EXPANSION (see Permit Conditions, see also Interim Status
Process)
EXPLORATION WASTE (see Mining Waste)
EXPLOSIVE WASTES (see Characteristic Hazardous Waste)
EXPORT OF HAZARDOUS WASTE (see also Transporters, Manifest)
EXPOSURE INFORMATION (see Risk Assessment)
EXTENSION (see also Land Disposal Restrictions)
F-WASTES (see Listed Hazardous Waste, Hazardous Waste
Identification)
FACILITY (see TSDFs)
FACILITY MANAGEMENT PLAN
FEDERAL FACILITIES
•	DOD
•	DOE
•	Inventory
•	Open Burning/Open Detonation (OB/OD)
FERROUS METALS (see Hazardous Waste Identification)
FIFRA (see Agricultural Wastes)
FINAL COVER (see also Closure)
FINANCIAL RESPONSIBILITY (see also Closure Process,
Post-Closure)
•	Bond Ratings
•	Corporate Guarantee
•	Cost Estimates
•	Insurance
•	Liability
•	Liability Coverage
FLAMMABLE (see Characteristic Hazardous Waste)
FLOOD PLAIN MANAGEMENT
FOOD PROCESSING WASTE (see Hazardous Waste Identification)
FORMALDEHYDE (see Hazardous Waste Identification)
• SUBKEY WORD

-------
FOSSIL FUELS (see Mining Waste, Exclusions)
FREE LIQUIDS (see Land Disposal Restrictions, Paint Filter
Test; see also SW-846)
FREON (see Hazardous Waste Identification)
FUEL (see Hazardous Waste Fuel, Used Oil)
FURNACE (see Incineration)
GAS CONDENSATE (see Land Disposal Facilities)
GAS PROCESSING WASTES
GENERATORS (see also Hazardous Waste Identification; see also
Import, Export)
•	Accumulation
•	Biennial Reports
•	DOT
•	Manifest
•	Small Quantity Generator
•	Universities
GEOLOGICAL REPOSITORIES (see Subpart X, Land Disposal Facilities)
GROUNDWATER MONITORING (see also Post-Closure)
•	Alternate Concentration Limit (ACL)
•	Aquifer
•	Assessment Monitoring
•	Compliance Monitoring
•	Groundwater Standards
•	Hydrogeological Data
•	Monitoring
•	Student's T Test
•	Unsaturated Zone Monitoring
•	VHS Model
•	Well Construction
GUIDANCE
HAZARDOUS CONSTITUENTS (see also Appendix VIII, Appendix IX,
Corrective Action, Delisting)
HAZARDOUS WASTE FUELS (see also Burning and Blending, Used Oil)
•	Fuel
•	Waste-as-fuel
•	Waste-derived Fuel
HAZARDOUS WASTE IDENTIFICATION (see also Characteristic
Hazardous Waste, Listed Hazardous Waste)
•	Aerosol Cans
•	Asbestos
•	Ballast Fluid
•	Batteries
•	Carbon Filters
•	Chemical Deodorants
•	Compressed Gas Cylinders
•	Contaminated Groundwater
•	Contaminated Soil
•	Creosote
•	Definition
•	Dibutyltin Difluoride
• SUBKEY WORD

-------
•	Dredged Sediments
•	F-Wastes
•	Electric Arc Furnace
•	Ferrous Metals
•	Food Processing Waste
•	Formaldehyde
•	Freon
•	High Tech Wastes
•	Iron Sponge
•	Manufacturing Process Units
•	Mercury
•	Metals
•	Munitions
•	Oily Waste
•	Paint Waste
•	Phosphate Wastes
•	Process Wastes
•	Regulated Wastes
•	Smelting Waste
•	Soil
•	TCLP
•	TNT
•	Toxicity
HAZARDOUS WASTE IMPORTATIONS (see Import)
HEALTH AND SAFETY
HEALTH ASSESSMENTS (see Risk Assessment)
HIGH TECH WASTES (see Hazardous Waste Identification)
HOUSEHOLD HAZARDOUS WASTE (see also Subtitle D)
•	Collection Programs
HOUSEHOLD WASTES (see Solid Waste)
HSWA (HAZARDOUS AND SOLID WASTE AMENDMENTS) (see also
Corrective Action, Delisting, Joint Permits, Land Disposal
Restrictions, Leachate Collection)
•	HSWA Provisions
HYDROGEOLOGICAL DATA (see Groundwater Monitoring)
IDENTIFICATION (see EPA I.D. Number)
IDENTIFICATION NUMBERS (see EPA I.D. Number)
IGNITABILITY (see Characteristic Hazardous Waste)
' IMPORT (see also Generator, Transporter)
INCINERATION (see also Subpart X under "Thermal Treatment")
•	Baghouse Dust
•	BIF Rule
•	Boiler
•	Cement Kiln
•	Destruction Removal Efficiency (DRE)
•	Electric Arc Furnace
•	Furnace
•	Hazardous Waste Fuels
•	Incinerator Residue
•	Incinerators
•	Industrial Furnace
• SUBKEY WORD

-------
•	POHCs
•	Scrubber Water
•	Trial Bum
•	Waste Burning
INCOMPLETE PART B'S (see Permit Application)
INDUSTRIAL FURNACE (see Incineration)
INSPECTIONS (see Compliance)
INSURANCE (see Financial Responsibility)
INTERIM AUTHORIZATION (see State Authorization)
INTERIM STATUS PROCESS (see also Construction)
•	Change during Interim Status
•	Closure
•	Corrective Action
•	Loss of Interim Status
•	Obtaining Interim Status
•	Protective Filers
INVENTORY (see Federal Facilities)
IRON FOUNDRY WASTE (see Listed Hazardous Waste)
IRON SPONGE (see Hazardous Waste Identification)
JOINT PERMITTING (see State Authorization)
LABORATORY ANALYSIS (see Analytic Methods)
LABORATORY WASTES
LAND BAN (see Land Disposal Restrictions)
LAND DISPOSAL (see Land Disposal Facilities)
LAND DISPOSAL BAN (see Land Disposal Restrictions)
LAND DISPOSAL FACILITIES (see also Closure, Post-Closure,
Minimum Technology Requirements, Land Disposal Restrictions,
Surface Impoundments)
•	Gas Condensate
•	Geologic Repositories
•	Land Disposal
•	Land Treatment
•	Landfill
•	Landfill Gas
•	Waste Piles
LAND DISPOSAL RESTRICTIONS
•	BOAT
•	Bulk Liquids
•	California List
•	Case-by-Case Extension
•	Free Liquids
•	Land Disposal Bern
•	National Variance
•	No-Migration Variance
•	Notifications
•	Treatment Standards
LAND TREATMENT (see Land Disposal Facilities)
LANDFILL (see Land Disposal Facilities)
LANDFILL GAS (see Land Disposal Facilities)
LARGE VOLUME WASTE (see Mining Wastes)
LEACHATE (see also Appendix VIII)
• SUBKEY WORD

-------
LEACHATE COLLECTION/DETECTION SYSTEM (see Minimum Technology
Requirements)
LEAD (see Characteristic Hazardous Waste)
LEAK DETECTION (see Secondary Containment)
LEAKAGE (see Secondary containment)
LIABILITY (see Financial Responsibility)
LIABILITY COVERAGE (see Financial Responsibility)
LINERS (see Minimum Technology Requirements; see also Land
Disposal Facility)
LIQUID HASTE (see also Land Disposal Restrictions,
Characteristic Hazardous Haste)
•	Absorbents
•	Bulk Liquids
•	Non-hazardous Liquids
LISTED HAZARDOUS WASTE (see also Solid Waste, Delisting,
Characteristic Hazardous Waste, Hazardous Waste
Identification, Dioxin)
•	Chlorination Tank
•	Commercial Chemical Products
•	Definition
•	F-Wastes
•	Iron Foundry Waste
•	K-Wastes
•	Off-specification
•	P-Wastes
•	Sole Active Ingredient
•	Steel Foundries
•	Toluene
•	U-Wastes
•	Wastewater Treatment Sludge
LOCATION (see Siting)
LOSS OF INTERIM STATUS (see Interim Status Process; see also
Permit Process)
LOW LEVEL WASTE (see Mixed Wastes)
MAJOR HANDLERS
MANIFEST (see Generator; see also Transporter, DOT, Waste
Minimization)
MANUFACTURING PROCESS UNITS (see Hazardous Waste
Identification)
MARKETER (see Used Oil)
MERCURY (see Hazardous Waste Identification)
METALS (see Hazardous Waste Identification)
MINERAL PROCESSING (see also Mining Wastes)
MINIMUM SHELL THICKNESS (see Tank System)
MINIMUM TECHNOLOGICAL REQUIREMENTS (MTR) (see also
Compatibility, HSWA, Release, Surface Impoundment, Land
Disposal, TSDF)
•	Double Liner
•	Leachate Collection/Detection System
•	Liners
•	Retrofit
* SUBKEY WORD

-------
MINING WASTE (see also Exclusions)
•	Bevill Amendment
•	Boiler Slag
•	Coal
•	Energy Exploration Waste
•	Fossil Fuels
•	Large Volume Waste
MISCELLANEOUS UNITS (see Subpart X)
MIXED RADIOACTIVE WASTES (see Mixed Waste)
MIXED WASTE
•	Atomic Energy Act (AEA)
•	By-Product
•	Mixed Radioactive Wastes
•	Mixed Radioactive/Radioactive Wastes
•	NRC
MIXTURE RULE (see also Derived-from-Rule)
MOBILE TREATMENT UNITS (see also Permit Process, Permit
Conditions)
MODELS
MODIFICATIONS (see Permit Process, under "Permit
Modification")
MONITORING (see Groundwater Monitoring)
MORE STRINGENT/BROADER IN SCOPE (see State Authorization)
MUNICIPAL LANDFILL (see also Solid Waste)
•	Sanitary Landfill
MUNICIPAL WASTE COMBUSTION (see also Incineration)
MUNITIONS (see Hazardous Waste Identification
NATIONAL VARIANCE (see Land Disposal Restrictions)
NATURAL GAS
NEW UNIT (see Construction)
NO—MIGRATION VARIANCE (see Land Disposal Restrictions)
NONCOMPLIANCE (see Data)
NONHAZARDOUS LIQUIDS (see Liquid Waste)
NOTIFICATION (see also Burning and Blending, EPA I.D. Number)
NPDES FACILITIES (see Clean Water Act, Wastewater)
NRC (see Mixed Wastes)
OB/OD (see Subpart X under "Open Burning/Open Detonation")
OBTAINING INTERIM STATUS (see Interim Status Process)
' OFF-SITE FACILITIES
OFF SPECIFICATION (see Listed Hazardous Waste)
OILY WASTE (see also Hazardous Waste Identification)
OMNIBUS PROVISION
ON—SITE WASTE MANAGEMENT (see also Permit Process, Generator)
OPEN BURNING/OPEN DETONATION (OB/OD) (see Subpart X, Federal
Facilities)
OPERATING LIFE (see Permit Conditions)
OSHA (see also Health and Safety)
OWNER/OPERATOR (see also Permit Application)
P-WASTES (see Listed Hazardous Waste)
PAINT FILTER TEST (see also SW-846)
•	Free Liquids
• SUBKEY WORD

-------
PAINT WASTE (see Hazardous Waste Identification; see also
Listed Hazardous Waste, Characteristic Hazardous Waste)
PART A PERMIT APPLICATION (see Permit Application; see also
Interim Status Process)
PART B PERMIT APPLICATION (see Permit Application? see also
Interim Status Process)
PARTIAL CLOSURE (see Closure Process)
PCBs
PERMIT APPLICATION
•	Incomplete Part B*s
•	Owner/Operator
•	Part A Permit Application
•	Part B Permit Application
•	Pre-construction Ban
•	Signatures
•	Withdrawals
PERMIT CONDITIONS (see also Corrective Action, Storage, TSDF)
•	Expansions
•	Operating Life
•	Permit Requirements
•	Permit Standards
PERMIT PROCESS
•	Appeals
•	Deadlines
•	Delegation of Authority
•	Joint"Permitting
•	On-site Waste Management
•	Permit Denial
•	Permit Modification
PERMIT REQUIREMENTS (see Permit Conditions)
PERMIT STANDARDS (see Permit Conditions)
PERMITTING (see Closure Process, Permit Process)
PERSONNEL TRAINING
PESTICIDES (see Agricultural Waste; see also Hazardous Waste
Identification)
PETITIONS (see also Exclusions, Delisting, Land Disposal
Restrictions)
PETROLEUM REFINERY WASTES (see also Exclusions, Delisting)
•	Used Oil
PHOSPHATE WASTES (see Hazardous Waste Identification)
PICKLE LIQUOR (see Electroplating)
POHCS (see Incineration)
POST-CLOSURE (see also Closure, Cost Estimates, Financial
Responsibility, Groundwater Monitoring, Post-Closure
Permits)
POTW (See Wastewater)
PRE-CONSTRUCTION BAN (see Permit Application)
PRECIOUS METALS (see Recycle)
PROCEDURE (see Test Methods)
PROCESS WASTES (see Hazardous Waste Identification)
PROTECTIVE FILERS (see Interim Status Process)
• SUBKEY WORD

-------
PUBLIC PARTICIPATION (see also Closure Process, Post-Closure)
QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) (see also SW-846)
RADIOACTIVE/RADIOACTIVE WASTE (see Mixed Waste)
RAGS AND WIPERS (see Solvents)
RCRA FACILITY ASSESSMENT (RFA) (see Corrective Action)
RCRA/CERCLA INTERFACE
•	CERCLA (Superfund)
•	RCRA
•	TAX
•	Treatability Study
RD&D PERMIT
REACTIVE WASTES (see Characteristic Hazardous Waste)
RECLAMATION (see also Solid Waste, Recycle, Solvents, Used Oil)
•	Recovery
•	Unused Materials
RECOVERY (see Reclamation)
RECYCLE (see also Reclamation, Solid Waste)
•	Precious Metals
•	Regeneration
•	Reuse
•	Use Constituting Disposal
REFINERY WASTE (see Petroleum Refinery Waste)
REGENERATION (see Recycle)
REGULATED UNIT (see also Corrective Action, Groundwater
Monitoring)
•	Definition
•	F-Wastes
REGULATED WASTES (see Hazardous Waste Identification, Solid
Waste)
REGULATION
RELEASE (see Corrective Action, Secondary Containment)
REMEDIATION (see Corrective Action)
REPORTING INFORMATION (see also Generator, Notification)
RESIDUE (see Derived-from-Rule)
RETROFIT (see Minimum Technology Requirements, Surface
Impoundments)
REUSE (see Recycle)
RFA (see RCRA Facility Assessment)
' RISK (see Risk Assessment)
RISK ANALYSIS (see Risk Assessment)
RISK ASSESSMENT
•	Exposure Information
•	Health Assessments
•	Risk
•	Risk Analysis
SAMPLE ANALYSIS (see Analytic Method)
SAMPLING (see Analytic Method)
SAMPLING PLAN (see Analytic Method)
SANITARY LANDFILL (see Municipal Landfill)
SCRAP METAL (see also Solid Waste)
•	Dental Amalgam
• SUBKEY WORD

-------
SCRUBBER (see also Sludge)
•	Baghouse Dust
SECONDARY CONTAINMENT (see also Tank Systems, Minimum
Technology Requirement s)
•	Leak Detection
•	Leakage
•	Release
•	Sumps
SECONDARY MATERIALS (see Solid Waste)
SECONDARY TREATMENT (see Treatment)
SECURITY
SEWAGE SLUDGE (see Wastewater)
SXC CODES
SIGNATURES (see Permit Application)
SITING (see also Public Participation)
•	Capacity
•	Location
SKINNER LIST (see Appendix IX; see also Groundwater Monitoring,
Delisting)
SLUDGE (see also Wastewater)
•	Baghouse Dust
•	Emission Control Wastes
•	Scrubber
•	Sludge Dryers
SLUDGE DRYERS (see Sludge)
SMALL QUANTITY GENERATOR (see Generators)
SMELTING WASTE (see Hazardous Waste Identification)
SOIL (see Hazardous Waste Identification)
SOLE ACTIVE INGREDIENT (see Listed Hazardous Waste)
SOLID WASTE (see also Recycle, Hazardous Waste Identification)
•	Batteries
•	By -Product
•	Definition
•	Discarded Materials
•	Household Wastes
•	Regulated Wastes
•	Scrap Metal
•	Secondary Materials
•	Spent Materials
•	Subtitle D
SOLID WASTE MANAGEMENT UNITS (SWMUs) (see Corrective Action)
SOLIDIFICATION (see Treatment)
SOLVENTS (see also Listed Hazardous Waste, Wastewater,
Electroplating, Reclamation, Recovery, Recycle)
•	Rags and Wipers
•	Spent Solvents
SPENT MATERIALS (see Solid Waste)
SPENT SOLVENTS (see Solvents)
SPILLS (see Contingency Plans; see also Corrective Action)
• SUBKEY WORD

-------
STATE AUTHORIZATION
•	Authorized States
•	Capability Assessments
•	Changing Federal Regulations
•	Interim Authorization
•	Joint Permitting
•	More Stringent/Broader in Scope
•	Pre-HSWA Provisions
•	c^at*o T.AUG
•	State Permits
•	State Programs
•	State Regulations
STATE LAWS (see State Authorization)
STATE PERMITS (see State Authorization)
STATE PROGRAMS (see State Authorization)
STATE REGULATIONS (see State Authorization)
STATUTORY AUTHORITY
STEEL FOUNDRIES (see Listed Hazardous Waste)
STORAGE (see also Containers, Hazardous Waste Fuel, Tank
System, Permit Conditions)
STUDENT'S T TEST (see Groundwater Monitoring)
SUBPART X (see also Permit Application, Federal Facilities,
Characteristic Hazardous Waste)
•	Geologic Repositories
•	Miscellaneous Units
•	Open Burning/Open Detonation (OB/OD)
•	Thermal Treatment
SUBPARTS AA AND BB
SUBTITLE D (see Solid Waste)
SUMPS (see Secondary Containment)
SUPERFUND (see RCRA/CERCLA Interface)
SURFACE IMPOUNDMENT (see also Land Disposal Facility)
•	Retrofit
SURFACE WATER (see also Wastewater, Clean Water Act)
SW-846
SWMUs (see Corrective Action under "Solid Waste Management
^ Unit"
' TANK SYSTEM (see also Generators, Secondary Containment)
•	Ancillary Equipment
•	Empty
•	Minimum Shell Thickness
•	Tanks
TANKS (see Tank System)
TAX (see RCRA/CERCLA Interface)
TCLP (TOXICITY CHARACTERISTIC LEACHING PROCEDURE) (see
Characteristic Hazardous Waste, Hazardous Waste
Identification)
TEMPORARY EXCLUSION (see Delisting)
TEST METHODS (see also Analytic Methods, SW-846)
•	Procedure
• SUBKEY WORD

-------
sslst
No.
?06/92
\	KEYWORD INDEX
ABSORBENTS
(See liquid Waste)
ACCUMULATION
XREF
/ i
(See Generators) (See also Tank System)
ACL
(Sea Alternate Concentration Limit)
(See Groundwater Monitoring)
ACTIVE INGREDIENT
XREF
XREF
/ /
/ /
(See Listed Hazardous Waste under Sole Active Ingredient)
ACTIVE/INACTIVE FACILITY
XREF
/ /
(See Treatment, Storage, and Disposal Facilities)
ADMINISTRATIVE OROEft
XREF
/ /
(See Enforcement, Corrective Action)
AEROSOL CANS
XREF
/ /
(See Hazardous Waste Identification)
AGRICULTURAL WASTE
XREF
/ /
(See also Exclusion)
COMMERCIAL FERTILIZER VS SOIL AMENDMENTS
FARMER EXEMPTION INTERPRETATION
FOOD PROCESSING WASTE NOT UNDER AGRICULTURAL WASTE EXCLUSION
FIFftA
CREOSOTE TREATED CROSS TIES. DISPOSAL OF, FIFRA INTERFACE
END-USERS OF CHLORDIHEFORM EXEMPTION
MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS
WOOD TREATED WITH CREOSOTE. DISPOSAL OF
Pesticides
CHLORDANE AND HEPTACHLOR PESTICIDE WASTE
COMBIHEO STORAGE OF PESTICIDE WASTES
DElIsTING^ITITION INFORMATION REQUIREMENTS FOR RESIDUES FROM INCINERATION OF 2.4,5-T AND SILVEX PESTICIDES
MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS
PESTICIDE APPLICATOR WASHING RINSEWATER
PESTICIDE APPLICATOR WASHING RINSE WATER
XREF
9493.1986(04
9455.1982(01
9441.1980(02
9441.1985(28)
9441.1990(04
9444.198? 40
9441.1986(10
9444.1988
9483.1984
9441.1984
9433.1987
9444.198?
9443.1985
9441.1981
/ /
09/03/8?
0?/0?/82
08/19/80
07/16/85
02/14/90
09/09/8?
02/11/86
05/03/88
06/30/84
08/01/84
10/28/87
09/09/87
07/16/85
12/13/85

-------
THERMAL TREATMENT (see Subpart X; see also Incineration)
TNT (see Hazardous Waste Identification)
TOLUENE (see Listed Hazardous Waste)
TOTALLY INCLOSED TREATMENT UNITS (see Exclusion, Treatment)
TOXICITY (see Hazardous Waste Identification)
TRANSFER FACILITIES (see Transporters)
TRANSPORTERS (see also Generators)
•	Transfer Facilities
•	Transportation
TREATABILITY STUDY (see RCRA/CERCLA Interface)
TREATED WASTE (see Treatment)
TREATMENT
•	Biological Treatment
•	Chemical Stabilization
•	Definition
•	Drum Shredding Unit
•	Primary Treatment
•	Secondary Treatment
•	Solidification
•	Totally Enclosed Treatment Unit
•	Treated Waste
TREATMENT STANDARD (see Land Disposal Restrictions)
TREATMENT STORAGE AND DISPOSAL FACILITIES (TSDFs) (see also
Interim Status Process, Permit Process, Storage, Treatment,
Land Disposal Facilities)
•	Active/Inactive Facilities
TRIAL BURN (see Incineration)
U-WASTES (see Listed Hazardous Waste)
UNDERGROUND INJECTION (see also Land Disposal Restrictions,
Corrective Action, Disposal)
UNIVERSITIES (see Generators,* see also EPA I.D. Number)
UNSATURATED ZONE (see Groundwater Monitoring)
USE CONSTITUTING DISPOSAL (see Recycle)
USED OIL (see also Burning and Blending, Hazardous Waste Fuel,
Petroleum Refining Wastes)
•	Do-It-Yourselfers (DIYERs)
•	Fuel
•	Marketer
' VARIANCE (see also Land Disposal Restrictions)
VHS MODEL (see Groundwater Monitoring, Delisting)
VOLUNTARY CLEANUPS (see Corrective Action)
WASTE ANALYSIS (see also Analytic Method, SW-846)
WASTE-AS-FUEL (see Hazardous Waste Fuels)
WASTE DERIVED FUELS (see Hazardous Waste Fuels)
WASTE EXCHANGE PROGRAM (see Waste Minimization)
WASTE MINIMIZATION (see also Generators, HSWA, Manifest)
WASTE OIL (see Used Oil; see also Hazardous Waste
Identification)
WASTE PILES (see Land Disposal Facilities)
WASTE STREAM
• SUBKEY WORD
A. ^

-------
WASTEWATER (see also Clean Water Act, Listed Hazardous
Waste, Land Disposal Restrictions, Mixture Rule)
•	NFDES Facilities
•	POTW
•	Sewage Sludge
•	Sludge
•	Wastewater Treatment
WASTEWATER TREATMENT (see Wastewater)
WASTEWATER TREATMENT SLUDGE (see Listed Hazardous Waste)
WELL CONSTRUCTION (see Groundwater Monitoring)
WITHDRAWALS (see Permit Application)
WOOD TREATMENT (see also Listed Hazardous Waste)
•	Creosote
•	Wood Preserving
ZINC PLATING (see Electroplating)
• SUBKEY WORD

-------
RCRA PERMIT POLICY
COMPENDIUM	
Key Word Index
*Hotline Summaries

-------
Page No.
04/06/92
KEYWORD INDEX
PESTICIDE DISPOSAL BY FARMERS MID CONTAINER MANAGEMENT
PESTICIDE RINSEATE TREATMENT/RECYCLING SYSTEM
PESTICIDE STANOARDS FOR FORMALOEHYOE AND PARAFORMALDEHYDE
PESTICIDES CONTAININQ A 261.33(e) COMPOUND AS A SOLE ACTIVE INGREDIENT
SOIL CONTAMINATED VITH CHLOROANE AS A RESULT OF PESTICIDE APPLICATION
SOIL CONTAMINATED VITH PESTICIDE
SOIL CONTAMINATED VITH USEO ANO UNUSED PESTICIDES
SOILS CONTAMINATED VITH CHLOROANE AND HEPTACHLOR DURING TREATMENT OF BUILDINGS FOR TERMITES
VEHICLE FILTERS CONTAMINATED VITH PESTICIOES
VASKVATERS GENERATED FROM VASHING PESTICIDE APPLICATOR TRUCKS
9457.19871
9471.19081
9444.1989!
9444.19811
9444.19861
95S1.19871
9444.19871
9441.19871
9443.1987!
9441.1986!
01)
04)
02
05
20)
06
m
15
16
44)
03/25/87
10/27/88
03/14/89
09/18/81
09/29/86
04/08/87
04/18/87
03/11/87
08/13/87
05/30/86
AIR EMISSIONS
NO-MIGRATION PETITION FOR ARCO PROOUCTS, VA
NO-MIGRATION PETITION FOR SUN REFINING, OK
STANDARDS FOR AIR PATHVAY FOR METALS AND ORGANIC CHEMICALS
ALTERNATE CONCENTRATION LIMIT (ACL)
9SS1.1990(08
9551.1991(02
9551.1991(04
10/24/90
01/17/91
01/30/91
(Sm Groundwater Monitoring) (See also Appendix VIII)
ANALYTIC METHODS
XREF
/ /
<>\
ISee also Appendix vill, Append
NALYTICAL HETHODS/EP TOXICITY TEST/REFEREHCt STDS.
COMPRESSIVE STRENGTH OF TREATEO WASTES-USE OF SV-846 METHODS-VASTE IDENTIFICATION
CRUSHING VASTE PRIOR TO EP TEST
* DIOX IH STANDARD USEO TO TEST GAS CHROMATOGRAPHY COLUMNS, HANDLING OF
ELECTROPLATING SLUOGE, EXCLUSION PETITION
HYOROGEN SULFIOE VASTE IN SURFACE IMPOUNDMENT - REACTIVITY CHARACTERISTIC
LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISTIC LEACHING PROCEOURE (TCLP)
RCRA METHODS AND OA ACTIVITIES (NOTES)
RCRA METHODS AND DUALITY ASSURANCE ACTIVITIES (NOTES)
SV-846 METHODS MANUAL
TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS VASTE IDENTIFICATION PROGRAM
USE OF THE METHOD OF STANDARO EDITIONS
VASTE-OERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR VASTE FUELS, INFORMATION REQUIRED
Detection Limits
DELISTING PETITION INFORMATION REQUIREMENTS FOR RESIOUES FROM INCINERATION OF 2,4,5-T AND SILVEX PESTICIDES
OETECTION LIMIT FOR EP-LEACHATE CONCENTRATION OF SELENIUM
DETECTION LIMITS ANO INFORMATION CONCERNING POSSIBLE APPENOIX VIII COMPOUNDS NECESSARY FOR A DELISTING PETITION
HEALTH BASEO VALUES FOR CHEMICAL LIST
HEALTH BASED VALUES FOR PAH'S IN COKE BY-PRODUCT VASTES
METAL, K061 VASTES IN SURFACE IMPOUNDMENT-OELISTING PETITION
VASTE-DERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR VASTE FUELS, INFORMATION REQUIRED
Laboratory Analysts
•LABORATORY TESTING FOR OIOXIN
*PH TESTING OF SOLID/VATER MIXTURE
ANALYSIS OF APPENDIX IX CHEMICALS, PROPOSED
ANALYSIS OF FLUFF MATERIALS
APPENOIX VIII CONSTITUENTS IN GROUNDVATER, REQUIREMENTS FOR ANALYSIS OF
ASTM STANDARDS IN THE RCRA PROGRAM
XREF
9445.1984(02)
9445.1907103a)
9443.1987(26)
9441.1985 07
9433.19841 OS)
9443.1987(31)
9443.1986(10)
9445.1985 04
9445.1984 05)
9445.1987(02)
9443.1987(29
9443.1987(12
9441.1986(08
9433.1987(26)
9443.1986(06)
9433.1986(19)
9445.1989(02)
9551.1989(04)
9433.1987(18)
9441.1986(08)
9441.1985(11)
9443.1983 03
9481.1986102
9442.199H02
9481.1985(01
9445.1987105
/ /
04/23/84
11/17/87
11/12/87
02/13/85
12/11/84
12/07/87
05/05/86
06/30/85
12/20/84
09/16/87
11/18/87
06/23/87
01/24/86
10/28/87
03/12/86
12/09/86
07/18/89
07/06/89
08/07/87
01/24/86
03/30/85
02/28/83
07/25/86
02/22/91
10/15/85
12/21/87

-------
Page
04/0
No.
06/92
KEYWORD INDEX

EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCIP
GLASS FIBER FILTERS FOR USE IN CONDUCT IN6 THE TOXICITY CHARACTERISTIC LEACHING PROCEOURE (TCIP)
LABORATORY EQUIPMENT USEO IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEOURE (TCLP)
LABORATORY EVALUATION PROGRAM
LABORATORY SAMPLE EXCLUSION APPLICABILITY TO SAMPLES AND VASTES FROM LABORATORY ANALYSIS - OIOXIN
LEACHING TESTING FOR EVALUATING SOILS CONTAMINATED WITH LEAO
LEAD PAINT REMOVAL OEBRIS AND THE TCLP PROCEOURE
MATRIX SPIKE IN TCLP PROCEDURE
METHODS 1310 ANO 1330: EXTRACTION PROCEOURE ANO EXTRACTION PROCEOURE FOR OIL WASTE
METHODS 6240 AND 6260 DIFFERENTIATION AND EQUIVALENCY
RCRA TESTING TECHNIQUES
SEOIMENT SAMPLE DISPOSAL FROM BIOASSAY TESTING
SW-646. THIRD EDITION HOLDING TIMES FOR SEM1V0LATILES
TCLP EXTRACTIONS AS THEY APPLY TO OILY WASTE
TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF WASTE SAMPLE
Sample Analysis
•LABORATORY TESTING FOR OIOXIN
ALLOWABLE HOLDING TIMES WHEN TESTING RCRA SAMPLES
ANALYTICAL METHODS FOR CONDUCTING TESTIN6 UNOER THE TC RULE
DELISTING ACTION • STATUS OF HOLLOMAN AIR FORCE BASE
DELISTING ISSUES RELATING TO EPA'S MOBILE INCINERATOR
OILUTION OF TEST SAMPLING
EVALUATION OF DELISTING PETITIONS-INFORMATION REQUIRED
FLUFF ANALYSIS/SAMPLES
HANDLING AND ANALYSIS OF SAMPLES CONTAINING VOC'S
LABORATORY EVALUATION PROGRAM
LABORATORY SAMPLE EXCLUSION APPLICABILITY TO SAMPLES AND WASTES FROM LABORATORY ANALYSIS - OIOXIN
MULTIPLE EXTRACTION PROCEDURE. METHOD 1320
PARTICLE SIZE REOUCTION PROCEDURE FOR TCLP SAMPLES OF DRY CELL BATTERIES
QC REVIEW OF PERMIT DATA
RCRA FACILITY ASSESSMENTS, IMPLEMENTATION
RCRA TEST METHODS & QA ACTIVITIES
SELECTION OF NON-USEPA APPROVEO METHODS FOR SUBPART X PERMITS
SURROGATE RECOVERY
SW-846 TEST METHODS
SW-846, THIRD EOITION, HOLOING TIMES FOR SEMIVOLATILES
TOTAL CHROMIUM ANALYSIS
TOTAL CONCENTRATION USED TO DEMONSTRATE A WASTE DOES NOT EXHIBIT THE CHARACTERISTIC OF EP TOXICITY
Samp11AGITATE SAMPLES EVALUATEO USING METHOD 1110
DELISTING ACTION - STATUS OF HOLLOMAN AIR FORCE BASE
DELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIES
EVALUATION OF DELISTING PETITIONS-INFORMATION REQUIREO
FLUFF ANALYSIS/SAMPLES
INTERNATIONAL TRANSPORT OF LAB SAMPLES
LABORATORY WASTE EXCLUSION
METAL, K061 WASTES IN SURFACE IMPOUNDMENT-DELISTING PETITION
METH0&0L0G1ES EMPLOYED IN USED OIL SAMPLING
MODIFICATIONS TO WASTEWATER TREATMENT SYSTEM UNDER EXCLUSION
RCRA FACILITY ASSESSMENTS. IMPLEMENTATION		 	
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE
SAMPLING PLAN FOR DELISTING PETITION FOR WASTES IN LANDFILL TRENCHES
SAMPLING REQUIREMENTS FOR ESTIMATING VARIABILITY OF WASTES FOR DELISTING PETITIONS
SEDIMENT SAMPLE DISPOSAL
SPENT PICKLE LIQUOR DELISTING PETITION
9442.1991
9443.1986
9443.1966
9472.1986
9441.1987
9443.1987
9442.1991
9442.1991
9443.1987
9442.1991
9445.1987
9441.1989
9472.1987
9442.1991
9443.1987
13;
19|
17
02:
29!
24
12
03
14
06
os;
12!
10;
08
33
9441.1985(11!
9445.1987(04
9442.1991(17
9433.1987 16!
9433.1986(20
9442.1991(04
9433.1986(04!
9442.1989(02!
9442.1991(15!
9472.1986(02!
9441.1987(29
9442.1989(08!
9442.1991(07'
9442.1990(04!
9502.00-4
9441.1988(31!
9442.1990(03
9442.1991(09
9554.1991(04!
9445.1987(06!
9443.1987(11
9443.1989(01!
9441.1990(17!
9433.1987(16!
9433.1987(22'
9433.1986	04
9442.1989(02
9441.1989 20
9441.1985(03!
9433.1987	18;
9442.1991 11
9441.1991(01!
9502.00-4
9433.1988(11;
9433.1986(21
9433.1986(22
9441.1909(12
9433.1991(02
10/09/91
09/30/86
09/03/86
01/29/86
04/30/87
11/05/87
08/30/91
03/19/91
08/11/87
05/09/91
10/20/87
03/31/89
06/30/87
06/13/91
12/31/87
03/30/85
12/04/87
10/01/91
07/31/87
12/11/86
03/25/91
02/14/86
01/25/89
12/17/91
01/29/86
04/30/87
10/19/88
05/29/91
11/01/90
08/21/86
07/30/88
11/19/90
06/19/91
12/01/91
06/30/87
06/08/87
01/27/89
06/29/90
07/31/87
10/02/87
02/14/86
01/25/89
04/27/89
07/31/85
08/07/87
07/09/91
01/03/91
08/21/86
04/24/86
12/13/86
12/18/86
03/31/89
04/26/91

-------
Page No.
04/06/92
\
KEYWORD INDtX
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS	9523.00-14
TEST SAMPLES, EXCLUSION FROM HAZARDOUS WASTE	9431.1989(03)
ina Plan
ANALYSIS OF RETESTING PROCEDURES PAPER	9481.1991
CYANIDE FURNACE CRUCIBLES TREATMENT	9433.1990
DELISTING PETITIONS FOR K-WASTES MANAGEO IN ON-SITE LANO-BASEO UNITS-MONITORING REQUIREMENTS	9433.1987
DRAFT SAMPLING AND ANALYSIS PLAN FOR NH PLATING COMPANY	9433.1990
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE	9433.1906
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS	9433.1986
SAMPLING PLAN FOR DELISTING PETITION FOR WASTES IN LANDFILL TRENCHES	9433.1986i
SURFACE IMPOUNDMENT SAMPLING PLAN FOR HOLLOMAN AIR FORCE BASE	9484.1988i
03/14/86
06/05/89
10/16/91
09/26/90
09/28/87
11/27/90
04/24/86
12/30/86
12/13/86
06/20/88
ANCILLARY EQUIPMENT
(See Tank System)
API SEPARATOR SLUOGE
XREF
/ /
iSee also Petroleum Refinery Waste. Sludge, Wastewater)
API SEPARATOR WASTEWATER AND SLUDGE
PETROLEUM FACILITIES INCLUDED IN THE K051 LISTING FOR API SEPARATOR SLUDGE
APPEALS
XREF
9444.1984(06)
9444.1987(20)
/ /
04/30/84
05/26/87
(See Permit Process) (See also Closure Process)
APPENDIX IX
XREF
/ /
VP
iSee alto Appendix VIII, Groundwater Monitoring)
APPENDIX VIII AND APPENDIX IX
ANALYSIS OF APPENDIX IX CHEMICALS. PROPOSED
STANDARDS FOR AIR PATHWAY FOR METALS AND ORGANIC CHEMICALS
Skinner List
SKINNER LIST
APPENDIX VIII
XREF
9445.1989(01
9481.1986 02
9551.1991(04
/ /
06/30/89
07/25/86
01/30/91
9445.1985(06) 08/30/85
ISee also ACLs, Analytic Methods, Appendix IX, Groundwater Monitoring, Hazardous Constituents, Sampling)	XREF
APPENDIX VIII AND APPENDIX IX	9445.1989(01
*APPEN0IX VIII GROUNDWATER MONITORING	9445.1987 01
APPENDIX VIII CONSTITUENTS IN GROUNDWATER. REQUIREMENTS FOR ANALYSIS	9481.1985 01
CLOSURE AND POST CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS	9476.1987(08)
CONTAMINATED GROUNDWATER. RCRA REGULATORY STATUS	9442.1984
DELISTING ISSUES RELATING TO EPA'S MOBILE INCINERATOR	9433.1986(20
DELISTING PETITION INFORMATION REQUIREMENTS FOR RESIDUES FROM INCINERATION OF 2.4.5-T AND SILVEX PESTICIDES	9433.1987 26
DETECTION LIMITS AND INFORMATION CONCERNING POSSIBLE APPENDIX VIII COMPOUNDS NECESSARY FOR A DELISTING PETITION 9433.1986 19
ENFORCING GROUND-WATER MONITORING REQUIREMENTS IN RCRA PART B PERMIT APPLICATIONS	9504.1984(01
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT	9493.1991(05
MODIFICATIONS TO WASTEWATER TREATMENT SYSTEM UNDER EXCLUSION	9441.1991 01
POHC SELECTION FOR RCRA HAZARDOUS WASTE TRIAL BURN - USE OF 1,2,3-TRICHLOROBENZENE	9488.1991(01
/ /
06/30/89
03/30/87
10/15/85
12/17/87
12/26/84
12/11/86
10/28/87
12/09/86
08/16/84
10/11/91
01/03/91
02/05/91

-------
# No.
06/92
KEYWORD INDEX
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS
SAMPLING REQUIREMENTS FOR ESTIMATING VARIABILITY OF WASTES FOR DELISTING PETITIONS
SOIL CONTAMINATED WITH TOLUENE
STANDARDS FOR AIR PATHWAY FOR METALS AND ORGANIC CHEMICALS
AQUEOUS WASTE
(Sea Characteristic Hazardous Waste)
9433.1986(23)	12/30/66
9433.1986(221	12/10/66
9445.1965(011	04/05/85
9551.1991(04)	01/30/91
AQUIFER
ASBESTOS
(Sea Groundwater Monitoring)
XREF
XREF
/ /
/ /
(See Hazardous Waste Identification)
ASSESSMENT MONITORING
XREF
/ /
»->
¦ r-
(See Groundwater Monitoring)
ATOMIC ENERGY ACT (AEA)
(See Mixed Waste)
AUTHORIZED STATES
(See State Authorization)
6AGH0USE DUST
XREF
XREF
XREF
/ /
/ /
/ /
(See Incineration, Sludge)
BALLAST FLUID
XREF
/ /
(See Hazardous Waste Identification)
BATTERIES
(See Solid Waste, Hazardous Waste Identification)
BIST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
XREF
XREF
/ /
/ /
(Sea Land Disposal Restrictions)
XREF
/ /

-------
Page Mo.
04/06/92
\
KIVWRD INDEX
BEVIll EXCLUSION (AMENDMENTJ
(See Mining Waste)
BIENNIAL REPORTS
(See Generators)
¦IF RULE
(See Incineration)
BIOLOGICAL TREATMENT
(See Treatment)
BLASTING CAPS
(See Characteristic Hazardous Waste)
' BLENDING AND BURNING
(See Burning and Blending)
BOILER
(See Incineration)
BOILER SLAG
(See Mining Waste)
BOND RATINGS
(See Financial Responsibility)
BULK LIQUIDS
(See Land Otsposal Restrictions, Liquid Wastes)
BURNING AND BLENDING
(See also Incineration. Used 011)
^BURNING/BLENDING OF UNUSEO COMMERCIAL CHEMICAL PRODUCT (XYLENE) WITH USED OIL
•HAZARDOUS WASTE FUEL MARKETERS
•NATURAL GAS PIPELINE CONDENSATE AND ENERGf RECOVER*
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
9442.1985(01» 12/30/85
9453.1985 04} 11/30/85
9443.1987(23) 10/30/8/

-------
Page No.
04/06/92
KEYWORO INOU
•OFF-SPECIFICATION USED OIL FUEL
ATOMIZER MULTI-OIL FUELED HEATERS. INSPECTION & CERTIFICATION CRITERIA
BULKING OR CONTAINERIZING COMPATIBLE HAZARDOUS WASTES FOR TRANSPORTATION
BURNING OF USED OIL
BURNING OF USED OIL IN THE MARINE INDUSTRY ANO USED OIL GENERATOR NOTIFICATION REQUIREMENTS
COAL/FOSSIL FUEL COMBUSTION WASTES EXCLUOEO FROM SUBTITLE C PENDING FURTHER STUDY
MINERAL PROCESSING RESIDUALS FROM COMBUSTION UNITS BURNING HAZARDOUS WASTE FUEL
MIXING LOW AND HIGH BTU WASTES-SHAM BURNING. BLENDING, MANIFESTING
NOTIFICATION BY BURNERS OF USED OIL WHO FIRST CLAIM THAT USEO OIL MEETS SPECIFICATIONS
REGULATION OF HAZARDOUS WASTE TRANSFER OPERATIONS
USED OIL FOR INDUSTRIAL BURNERS
Burning
.n.
a
Hazardous Waste Fuel
BURNING AND BLENDING AND INTERIM STATUS
ADMINISTRATIVE CONTROLS ANO STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
BOILERS AND INCINERATORS. DISTINCTION BETWEEN/INTEGRAL DESI6N STANDARD
BURNING AND BLENDING OF HAZARDOUS WASTE AND USED OIL FUELS
BURNING COMPRESSOR OIL WITH AMMONIA IN SPACE HEATERS
BURNING OF OFF-SPEC USED OIL
CEMENT KILN BURNING HAZARDOUS WASTE FUELS DURING INTERIM STATUS
COAL TAR DECANTER SLUOGE WASTE PILE (TOLEDO COKE)
ENFORCEMENT POLICY ON WASTE BURNING FOR ENERGY RECOVERY
FIRE TRAINING PITS. REGULATORY REQUIREMENTS FOR
HAZAROOUS WASTE FUEL CADENCE PRODUCT 312. REGULATION OF
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES AND THE RESIOUALS GENERATED (LOUISIANA REG)
MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OF
MIXTURES OF WASTES ANO LEGITIMATE BURNING FOR ENERGY RECOVERY
REGION V FUEL-BLENDING FACILITIES CONCERNS
SHAH INCINERATION AND TREATMENT OF K048-K052 WASTES IN CEMENT KILNS AND INDUSTRIAL FURNACES
SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMED XYLENE
» SULFUR RECOVERY FURNACES ARE INDUSTRIAL FURNACES SUBJECT TO THE WASTE-AS-FUEL RULES
TWO WASTE OIL MANAGEMENT PRACTICES REGULATORY STATUS
USE/REUSE EXCLUSION TO RED WATER (K047) FROM WHICH SODIUM SULFITE IS RECOVERED ANO WHICH IS USED AS A FUEL
USED OIL INTRODUCED INTO REFINERY PROCESS UNDER HAZARDOUS WASTE OERIVEO REFINERY FUEL PRODUCTS EXEMPTION
WASTE-AS-FUEL RULES AT DOD FACILITIES, IMPLEMENTATION
WASTE-DERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIREO
WASTE-DERIVEO FUELS BURNED IN CEMENT KILN, REGULATION OF
BURNING HAZARDOUS WASTE FUEL
9454.1906
9495.1988
9432.1990
9495.19B5
9495.1966
9441.1984
9441.1984
9442.1986
9495.1987
9461.1989
9495.1986
9528.1985(11)
9494.1986(05)
9432.1986(02)
9495.1985(03)
9494.1991 03)
9494.1986(0Sa)
9528.1987(10)
9441.1987(98
9494.1986(06
9489.1987(02
9494.1986(04
9494.1967(02
9494.1986(01
9494.1987(03
9441.1991(17
9494.1991(02
9441.1987(24
9432.1986(04
9495.1991(01
9441.1987(42
9441.1986(11
9494.1986(02
9441.1966(08
9494.1985(03
(See Burning and Blending)
BY-PRODUCT
XREF
/ /
(See Solid Waste, Mixed Waste)
CALIFORNIA LIST
XREF
/ /
(See Land Disposal Restrictions)
XREF

-------
Pan No.
04/06/92
KEYWORD INDEX
CAPABILITY ASSESSMENTS
(Sea Stat* Authorization)
XREF
CAPACITY
/ /
(Sea Siting)
CARBON FILTERS
XREF
/ /
(Sea Hazardous Wast* Identification)
CASE-BY-CASE EXTENSION
XREF
/ /
(Sea Land Olsposal Restrictions)
CEMENT KILN
XREF
/ /
(Sea Incineration) (See also Hazardous Waste Fuel)
CERCLA (SUPERFUND)
XREF
/ /
(See RCRA/CERCLA Interface)
j— cerCla/rcra interface
i	(See RCRA/CERCLA Interface)
CERTIFICATION
XREF
XREF
/ /
/ /
(See also Closure, Generators. Post-Closure, Waste Minimization)
•CERTIFICATION FOR CONTAINER STORAGE
~CERTIFICATION OF CLOSURE
•HAZAROOUS WASTE TANKS - INSTALLATION/CERTIFICATION OF SECONDARY CONTAINHENT
•LOSS OF INTERIM STATUS - LAND DISPOSAL FACILITIES
•SOFT HAMMER CERTIFICATIONS/DEMONSTRATIONS
•TREATMENT SURFACE IMPOUNDMENTS LOSING INTERIM STATUS BECAUSE OF NON-COMPLIANCE WITH GROUND-WATER
213 OF HSWA. REQUIREMENTS - PERMIT ISSUANCE ANO CERTIFICATION OF COMPLIANCE
APPENDIX VIII CONSTITUENTS IN GROUNDWATER, REQUIREMENTS FOR ANALYSIS
BURNING HAZARDOUS WASTE IN BOILERS ANO INDUSTRIAL FURNACES (BIFsl
CERTIFICATION PROCESS ON BIOTECHNOLOGICAL METHODS FOR REMEDIATION Of INDUSTRIAL FACILITIES
CERTIFICATION/NOTIFICATION FOR MULTIPLE-CONSTITUENT WASTES SUBJECT TO LORs
DtOXIN TRIAL BURNS FOR PURPOSES OF CERTIFICATION OR A RCRA PERMIT
DISPOSAL FACILITY REQUIREMENTS FOR LAND DISPOSAL RESTRICTIONS CERTIFICATIONS
INTERPRETATION OF 40 CFR 260.7 REQUIREMENTS
MANIFEST CERTIFICATION SIGNATURE BLOCK FOR EMPLOYEES SIGNING FOR GENERATING COMPANY
MODIFIED MANIFEST WASTE MINIMIZATION CERTIFICATION FOR SMALL QUANTITY GENERATORS
NEUTRALIZATION SURFACE IMPOUNDMENTS. RETROFITTING VARIANCES
NOTIFICATION REQUIREMENT WHEN SHIPPING RESTRICTED WASTES TO A STORAGE FACILITY
XREF
9523.1963(02
9476.1987(05
9483.1908(13
9528.1985(03
9551.1988(13
9470.1985(01
9522,1985(03
9481.1985(01
9494.1991(01
9486.1989(01
9551.1991(10
9488.00-1A
9551.1987(07
9554.1988(03
9452.1985(02
9452.1986(02
9484.1986 04
9551.1987(20
/ /
02/28/83
09/30/87
06/30/88
09/30/85
11/30/88
02/28/85
07/05/85
10/15/85
02/04/91
03/30/89
06/05/91
05/07/86
03/10/87
05/13/88
10/17/85
10/20/86
04/21/86
10/28/87

-------
Pago No.
04/06/92
KEYW0R0 INDEX
POST CLOSURE PERMIT REQUIREMENTS (ARMCO STEEL)	9522.1966(03)	11/20/86
QUALIFICATION OF AN ENGINEER FROM THE CORPS OF ENGINEERS AS INDEPENDENT WITH RESPECT TO AN ARHY FACILITY	9483.1987 20)	12/15/67
RELEASES OF HAZARDOUS WASTE. RCRA APPLICABILITY TO	9502.1987 05	04/02/87
SECONDARY CONTAINMENT SYSTEMS CERTIFICATION	9483.1988(18)	12/12/88
TANK SYSTEMS APPLICABLE TO PRODUCTION TANKS DURING CLEANOUT, PROCESS TRANSFER EQUIPMENT, AND HOSE LINES	9483.1966(11)	12/19/86
THIRD THIRD LAND DISPOSAL RESTRICTIONS	9551.1990(15)	12/20/90
THIRO THIRD LAND DISPOSAL RESTRICTIONS FINAL RULE	9551.1991(13)	12/20/91
WASTE MINIMIZATION CERTIFICATION REQUIREMENTS	9452.1986(01)	04/28/86
CHANGE IN INTERIM STATUS
(See Interim Status Process)
CHANGING FEDERAL REGULATIONS
XREF
/ /
(Set State Authorization)
CHARACTERISTIC HAZARDOUS WASTE
XREF
/ /
(See also SW-846, Listed Hazard
*01SCAR0E0 MERCURY THERMOMETERS
Hazardous Waste, Hazardous Waste Identification)
JC
V
*HAZARDOUS WASTE LISTED SOLELY FOR SUBPART C CHARACTERISTICS
ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED OURING PAINT APPLICATION
ANTARCTICA WASTE OISPOSAL PRACTICES
AUTOMOTIVE FLUIDS, REGULATION OF
BY-PRODUCT CRUDE OIL TANK BOTTOMS
CALIFORNIA LIST PROHIBITIONS APPLICABILITY AFTER THIRD THIRO RULE
CARBON REGENERATION FACILITIES
CAUSTIC RINSING METAL PARTS
CHARACTERISTIC HAZARDOUS WASTE OR SOLID WASTE TREATMENT KAY CREATE A LISTED HAZARDOUS WASTE
CHARACTERISTIC HAZARDOUS WASTES GENERATED AT PRIMARY METAL SMELTING AND REFINING SITES
CHARACTERISTIC SLUDGES RECLAIMED OR PROCESSED PRIOR TO USE AS AN INGREDIENT IN FERTILIZER
CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTES
CHLORIOE-ILHENITE PROCESS WASTES
COMMERCIAL CHEMICAL PRODUCT P LISTING APPLIES ONLY TO UNUSED PRODUCT, NOT USED RESIDUES
DELISTING CRITERIA/LEACHATE LEVELS
ETCHANTS USED TO MANUFACTURE COPPER SALTS
EXCAVATED CONSTRUCTION SOIL CONTAINING QUANTITIES OF VOLATILE ORGANIC COMPOUNDS
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTEO WASTES - LEACHATE LEVELS
GENERATOR RECYCLING HAZARDOUS WASTE ON-SITE
HAZARDOUS CHARACTERISTIC - BASIS FOR LISTING
HAZARDOUS WASTE LISTING FOR F006 WASTE - F019 WASTE
HYDRAULIC OEVICES CONTAMINATED WITH OIL DURING QUALITY CONTROL TESTING
K035 LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS
LEAKS, SPILLS, AND ILLEGAL DISCHARGES OF LISTEO WASTES TO SURFACE WATERS. MIXTURE RULE APPLIEO TO
LIQUIO SCINTILLATION COCKTAIL SOLUTION PROOUCT, READY SAFE
LIQUIO, FREE LIQUIO, RELEASABLE LIQUIO DEFINITIONS
LITHIUM BATTERIES
LUBRICATING OIL AND JET FUELS USED TO PRODUCE PETROLEUM PRODUCTS
LUBRICATING OIL CONTAMINATED WITH TCOD THROUGH USE AS AN ANALYTICAL STANDARD
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER
MECHANICAL PLATING WASTES IN THE F006 LISTING. NON-INCLUSION OF
MIXING HAZARDOUS VAST! WITH USED OIL (REBUTTABLE PRESUMPTION)
MIXTURES OF SOLID AND HAZARDOUS WASTES
XREF
9444.1989(091
9441.1986(741
9444.1986 08)
9442.1909(04)
9441.1987(14)
9441.1986(37)
9551.1991(11)
9441.1986(26)
9444.1987(33)
9442.1989(05)
9443.1986(16)
9493.1985(03)
9443.1985(09)
9441.1991(05)
9444.1986(29
9433.1986(011
9441.1986(82)
9443.1985	01)
9441.1986	03)
9453.1987(04)
9441.1984 32
9441.1986	78
9495.1986(20)
9444.1987	52
9441.1906(07)
9443.1988(02)
9432.1989(04)
9443.1987(02
9494.1985(01
9444.1987(48
9441.1986 73)
9444.1986(13)
9495.1966(04)
9441.1987(06)
/ /
00/30/89
09/30/86
05/02/86
04/26/89
03/06/87
05/01/86
09/27/91
04/02/86
08/07/87
07/05/89
07/09/86
11/25/85
10/03/85
04/22/91
12/08/86
01/07/86
11/08/86
02/21/05
01/07/06
07/14/87
11/07/04
10/12/86
08/22/06
12/11/87
01/23/06
01/13/00
07/20/09
01/14/87
10/01/85
10/23/87
09/25/86
06/24/86
02/28/86
01/27/87

-------
Page No.
04/06/92
\
KEYWORD INDEX
. r.
MIXTURES OF SOLID WASTE AND A WASTE LISTED SOLELY BECAUSE IT EXHIBITS A CHARACTERISTIC
MUNICIPAL WASTE COMBUSTION. DISPOSAL OF RESIDUAL ASH
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
PACKAGES CONTAINING RESIDUAL URETHANE COATING CHEMICALS
PROCESS WASTES CONTAINING INKS, PAINTS, AND ADHESIVE*
REACTOR VESSEL WASHWATER CONTAMINATED WITH SOLVENTS
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
REJECT SUBSTRATES CONTAINING VENADIUM PENTOXIDE
RELISTING HAZARDOUS WASTE
RES10UES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE, I.D. NUMBERS
SCINTILLATION COCKTAIL. REGULATION OF LIQUID
SCRAP DEHP AND SHALL CAPACITORS CONTAINING DEHP, DISPOSAL REQUIREMENTS
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY
SOLAR CELL MID HIGH TECH INDUSTRIES HAZARDOUS WASTE
SPENT ANT I-FREEZE COOLANT REGULATORY STATUS
TOTAL CHROMIUM ANALYSIS
TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HAZARDOUS WASTE
USED X-RAY FILM AS A SPENT MATERIAL - SILVER RECLAMATION
WASTE SOLVENT-BASED GLUE
WASTES GENERATED FROM EXTRACTION PROCESS
WOOD TREATED WITH CREOSOTE, DISPOSAL OF
Aqueous Waste
•AQUEOUS WASTE AS IGN1TABLE
~POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSION
AqUEOUS AS USED IN THE C0RR0SIV1TY CHARACTERISTIC
AqUEOUS SOLUTION, 1GNITABILI TV 0EF1NED
CORROSIVE CHARAcfERlSTIC APPLIED TO LIQUID AND AQUEOUS WASTES
HANDLING AND ANALYSIS OF SAMPLES CONTAINING VOC'S
, IGNITABILITY OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITION
* LIQUID AS IT APPLIES TO. IGNITABLE OR CORROSIVE WASTES
PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER
WASTES GENERATED BY COKE AND COAL TAR PLANTS
WATER/KETHANOl MIXTURE WASTESTREAM
9441.1985(38
9443.1987(0$
9441.1906 21
9443.1987 09
9441.1987(09
9444.1987(49
9441.1985(39
9444.1986 17
9442.1986 08
9441.1986	05
9443.1987(18
9441.1985(23
9441.1987(02
9444.1983 03
9441.1990 25
9443.1987	11
9441.1988(44
9441.1986(42
9443.1989(02
9442.1986 07
9441.1986(10
9443.1984(06
9441.1985(09
9443.1987(19
9443,1985(02
9443.1987(17
9442.1991(15
9432.1990 01
9441.1989(51
9441.1986(31
9441.1988(49
9442.1987(02
9443.1985(07
11/20/85
04/08/87
03/13/86
05/13/87
02/19/87
10/26/87
11/25/85
09/04/86
08/21/86
01/16/86
08/19/87
06/27/85
01/06/87
07/20/83
08/24/90
06/08/87
10/27/88
05/20/86
04/12/89
07/02/86
02/11/86
08/30/84
02/28/85
09/14/87
02/26/85
08/18/87
12/17/91
02/16/90
10/05/89
04/21/86
12/06/88
07/24/87
09/10/85
Blastfni
ng Caps
BLASTING
CAPS AS REACTIVE WASTES
9443.1984(05) 09/11/84
Corrosive Wastes
•LANO DISPOSAL RESTRICTIONS - CORROSIVE WASTE
•POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSION
AQUEOUS AS USED IN THE CORROSIVITY CHARACTERISTIC
BATTERIES, SCRAP METAL, AND PRECIOUS METALS
COPPER PLATING SOLUTION
COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZER
CORROSIVE CHARACTERISTIC APPLIED TO LIQUID AND AQUEOUS WASTES
CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PROOUCTS, REACTIVE WASTES DEFINED
DEIONIZATION ACID
DELISTING PETITION OF NITROGEN TETROXIDE RINSATE
FOOD PROCESSORS, IMPACT OF HAZARDOUS WASTE REGULATIONS ON
NITRIC ACID WASTE CHARACTERIZATION
PAINTING CONTRACTOR WASTES-SHALL QUANTITY GENERATOR
PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)
RECLAMATION OF SPENT ALKALINE ETCHANT-REQUEST FOR VARIANCE UNDER MOO. CLOSEO-LOOP PROVISION
REGENERATION OF USED BATTERIES EXEMPTED FROM REGULATION
RESIOUAL WATER 0ER1VE0 FROM AN EXEMPT WASTE (COAL ASH) IS EXEMPT
9551.1987(19}
9441.1985	09
9443.1987(19)
9441.1985(44)
9443.1986(04
9493.1986	01
9443.1987(17)
9443.1984(09)
9443.1966(11)
9433.1990 07
9443.1980(02
9443.1989(09
9441.1986(47)
9441.1986(31)
9433.1985(06)
9441.1986(51)
9441.1986(49)
09/30/87
02/28/85
09/14/87
12/18/85
01/22/86
01/22/86
08/18/87
11/29/84
05/12/86
12/21/90
09/16/80
11/17/89
06/02/86
04/21/86
10/29/85
07/02/86
06/16/86

-------
Page No.
04/06/92
KEYWORD INDEX
REUSE/RECYCLE REGULATIONS IMPACT ON SPENT LEAO-ACIO BATTERY RECYCLING
SPENT PICKLE LIQUOR CORROSIVITY
SPENT PICKLE LIQUOR, REUSE OF
SPENT SULFURIC ACIO PICKLE LIQUOR USEO TO PRODUCE FERTILIZER
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEAOING TO A WASTEWATER TREATMENT PLANT
Dilution
'DILUTION OF F003 WASTES
•DILUTION OF LAND OISPOSAL RESTRICTED WASTE
~DILUTION TO MEET TREATMENT STANOAROS
DECANN1NG AND CRUSHING OPERATIONS
LDR DETERMINATION OF WASTE STREAM DILUTION
PESTICIDES CONTAINING A 261.33(e) COMPOUND AS A SOLE ACTIVE INGREDIENT
SOLIDIFICATION OF CALIFORNIA LIST LIQUID WASTES AND THE DILUTION PROHIBITION
SOLVENT AND COMMERCIAL CHEMICAL PRODUCT WASTE STREAMS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANT
EP Toxicity
*EP TOXICITY FOR OILY WASTES
*EP TOXICITY TEST ON OILY WASTES
•LANDFILLS WITH EP TOXIC LEACHATE, REGULATION OF
~LDR REQUIREMENTS DURING NATIONAL CAPACITY VARIANCE
ALLOWABLE HOLDING TIMES WHEN TESTING RCRA SAMPLES
ANALYSIS OF FLUFF MATERIALS
ANALYTES TO LOOK FOR WHEN PERFORMING RCRA ANALYSIS
ANALYTICAL METHODS/EP TOXICITY TEST/REFERENCE STDS.
CALIFORNIA AUTHORIZATION - EVALUATION OF THE WASTE EVALUATION TEST
CARBON REGENERATION UNITS - REGULATORY STATUS
CHROMIUM WASTES: TRIVALENT AND HEXAVALENT - CHROMIUM IN TANNERY WASTES
• CRUSHING WASTE PRIOR TO EP TEST
DELISTING TESTING REQUIREMENTS, CYANIOE AND OTHER WASTES, STEEL INDUSTRY
OETECTION LIMIT FOR fP-LEACHATE CONCENTRATION OF SELENIUM
EP TOXICITY LEVEL FOR BARIUM IN DRINKING WATER
EP TOXICITY TEST EXTRACTION MEDIUM, REQUESTED CHANGE
EXTRACTION PROCEDURE TOXICITY TEST
F006 WASTES, VHS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION
FLUE DUST AND METAL HYDROXIDE SLUDGE RECYCLING/RECLAMATION
FLUFF ANALYSIS/SAMPLES
FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)
FLUORESCENT ANO MERCURY VAPOR LAMPS AND CLASSIFICATION USING THE EP TOXICITY TEST
GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS
LEACH TESTING PROCEDURE TO REMOVE LEAD-CONTAMINATED SOILS FROM RESIDENTIAL AREAS
LEAD AND ARSENIC WASTES TREATMENT STANDARDS
LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS
MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONS
METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEDURE FOR OILY WASTE
MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGE
MUNICIPAL WASTE COMBUSTION, DISPOSAL OF RESIDUAL ASH
PAINT FILTER LIQUIDS TEST USED TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONS
PAINT ril TFD WASTF
PAINT WASTES AND OF THE SPENT SOLVENT LISTINGS
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
RECYCLING OF MOLDING ANO CASTING SANDS
REGENERATION OF USED BATTERIES EXEMPTED FROM REGULATION
RESIDUES FROM U.S. NAVY SALVAGE FUEL BOILER
SILVER IN WASTES AND IN SEWER DISCHARGES FROH THE PHOTO-FINISHING INDUSTRY
9497.1986
9443.1986
9441.1987
9493.1985
9441.1986
05
17
02
62
9441.1986(97
9551.1988(02
9554.1986(05
9432.1984 03
9551.1990 06
9444.1981 OS
9551.1987(23
9444.1989(03
9523.00-14
9441.1986(62)
9443.1985(08
9443.1984(04
9487.1984(04
9551.1990(16
9445.1987(04
9442.1991(02
9442.1989(03
9445.1984(02
9442.1988(03
9489.1991(04
9441.1986(24
9443.1987(26
9433.1984(06
9443.1986(06
9443.1989(03
9443.1985(10
9443.1981(01
9433.1987(09
9441.1969(10
9442.1989(02
9441.1988(48
9443.1986(09
9451.1986(03
9431.1989(01
9554.1990(11
9443.1987 20
9443.1986	18
9443.1987	14
9443.1986	13
9443.1987(06
9553.1967 15
9444.1982 01
9444.1987	17
9441.1985(39
9441.1986(01
9441.1986(51
9441.1987(16
9443.1986(15
02/06/86
05/02/88
03/31/87
11/14/85
08/19/86
12/30/86
05/30/88
12/30/86
04/26/84
10/14/90
09/18/81
11/13/87
06/28/89
03/14/86
08/19/86
09/30/85
07/30/84
08/30/84
12/01/90
12/04/87
02/22/91
04/20/89
04/23/84
05/02/88
08/02/91
03/21/86
11/12/87
12/18/84
03/12/86
04/20/89
10/21/85
06/17/81
06/08/87
03/27/89
01/25/89
11/21/88
04/30/86
04/28/86
06/26/89
06/24/90
11/20/87
09/04/86
08/11/87
05/27/86
04/08/87
12/03/87
08/19/82
05/20/87
11/25/85
01/06/86
07/02/86
03/17/87
06/26/86

-------
Paga No.
04/06/92
KEYWORD INOEX
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY. CHEMICAL RECOVERY CARTRIDGES FOR
SPENT SULFURIC ACIO PICKLE LIQUOR USED TO PRODUCE FERTILIZER
TC RULE DELAY OF IMPOSITION ON OIL FILTERS
TOTAL CHROMIUM ANALYSIS
TOTAL CONCENTRATION USED TO DEMONSTRATE A WASTE DOES NOT EXHIBIT THE CHARACTERISTIC OF EP TOXICITY
TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF WASTE SAMPLE
USE OF THE METHOD OF STANDARD EDITIONS
WASTE BATTERIES AND CELLS
Explosive Wastes
ASH RESIDUE GENERATED FROM INCINERATION OF K045
CORRECTIVE ACTION/PERMIT 1SSUES-U.S. ARMY-ABERDEEN PROVING GROUNDS
DEMILITARIZATION OF MUNITIONS
DETONATING EXPLOSIVE WASTES
01SCAR0ED CLASS C EXPLOSIVES
DOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO DISPOSE OR DESTROY THEM
EMERGENCY PERMITS FOR DETONATION OF EXPLOSIVE WASTE
LEAKING OR DAMAGED EXPLOSIVES
REACTIVE WASTE - EXPLOSIVITY
IgnltabUlty
•AQUEOUS WASTE AS IGNITABLE
•NATURAL GAS PIPELINE CONDENSATE AND ENERGY RECOVERY
AQUEOUS SOLUTION, IGNITABILITY DEFINED
CHARACTERISTIC OF IGNITABILITY
D001 CHARACTERISTIC WASTES - LAND DISPOSAL RESTRICTIONS
DEFINING IGNITABLE LIQUIDS METHOD
DETERMINATION OF THE IGNITABILITY CHARACTERISTIC
F003 10% RULE AND ASSOCIATED REGULATIONS
Lead
IGNITABILITY CHARACTERISTIC UNDER STANDARD TEMPERATURE AND PRESSURE
IGNITABILITY CHARACTERISTIC. MEANING OF STANDARD TEMPERATURE AND PRESSURE
-JC	IGNITABLE SOLID DEFINITION APPLIED TO TITANIUM SWARF
<7.	MIXED SOLVENT WASTES
MIXTURE OF METHANOL AND SOLID WASTE WHICH DOES NOT EXHIBIT ANY CHARACTERISTICS
SOLVENT-CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTURE
THIRD THIRD LAND DISPOSAL RESTRICTIONS
THIRD THIRD LAND DISPOSAL RESTRICTIONS FINAL RULE
TOLUENE-LADEN FILTER RESIDUE GENERATED FROM AN INK PRODUCTION PROCESS
WATER/METHANOL MIXTURE WASTESTREAM
BLAST SLAG TESTING PROCEDURES
CLEANUP LEVELS FOR LEAD AND CADMIUM IN SOILS FOR CLEAN CLOSURE
FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)
INTERIM SOIL CLEAN-UP LEVELS FOR LEAO AT SUPERFUNO SITES
LEACHATE TESTING FOR EVALUATING SOILS CONTAMINATED WITH LEAD
LEAD PAINT REMOVAL DEBRIS AND THE TCLP PROCEDURE
LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS
LEAD-BEARING WASTES TREATMENT STANDARDS
NO-MIGRATION PETITION FOR SINCLAIR OIL, OK
RECOVERED LEAO AND LEAO ALLOYS FROM BATTERIES
RECYCLING OF MOLDING AND CASTING SANDS
SECONDARY LEAD SMELTER VARIANCES
SOIL CLEANUPS FOR LEAO - CLEANUP STANDARDS FOR CLEAN CLOSURE
TCLP AND LEAD PAINT REMOVAL D.EBRIS
9443.1987(01)
9493.1985(02$
9441.1991 15
9443.1987(111
9443.1989 01
9443.1987133
9443.198?)12)
9443.1983(05
9441.1987(12)
9502.1986(091
9441.1987(03)
9443.1987	30)
9443.1988(07)
9441.1985(311
9527.1986(01)
9471.1988	05)
9443.1988(10)
9443.1984(06
9443.1987 23
9443.1985	02
9443.1987(07
9554.1990(02
9442.1991(05
9443.1991 01
9444.1987(30
9489.1987(02
9443.1990(01
9443.1988(08
9443.1988(08
9443.1983(01
9444.1988(02
9441.1986	23
9442.1987(06
9551.1990	15
9551.1991	13
9444.1985(09
9443.1985(07
9442.1989(09)
9476.1988 02a)
9441.1988(48)
9502.1990(01)
9443.1987	24$
9442.1991(12)
9443.1987(28$
9554.1990(06)
9551.1990 12
9455.1991(03$
9441.1986(01$
9444.1988	14)
9502.1969 02
9442.1991(10$
01/06/87
11/14/85
09/25/91
06/08/87
01/27/89
12/31/87
06/23/07
07/27/83
03/03/87
05/08/86
01/07/87
11/30/87
06/02/88
10/31/85
01/05/86
11/30/88
09/13/88
08/30/84
10/30/87
02/26/85
04/16/87
02/22/90
03/27/91
09/06/91
07/21/87
07/22/87
01/30/90
09/09/88
09/09/88
01/10/83
01/20/88
03/21/86
10/26/87
12/20/90
12/20/91
06/03/85
09/10/85
11/03/89
03/02/88
11/21/88
05/07/90
11/05/87
08/30/91
11/20/87
06/25/90
11/08/90
12/10/91
01/06/86
08/26/88
05/25/89
07/03/91

-------
Pag# No.
04/i
06/92
KiVHORO INDEX
TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMIMATEO Oft RADIOACTIVE LEAD
USED OIL, BURNING OF OFF-SPECIFICATION FUEL - DUMPING
Reactive Wastts
~SURFACE IMPOUNDMENTS CONTAINING WASTEWATER WHICH BECOMES REACTIVE WHEN DRV
AEROSOL PAINT AND SOLVENT CANS DEMONSTRATION OF REACTIVITY
ASH RESIDUE GENERATED FROM INCINERATION OF K04S
BATTERIES, SCRAP METAL. AND PRECIOUS METALS
BLASTING CAPS AS REACTIVE WASTES
CHEMICAL AGENTS 68, VX, AND HX AT MUNITIONS DISPOSAL FACILITY
CORROSIVE SOLIDS. COMMERCIAL CHEMICAL PRODUCTS. REACTIVE WASTES DEFINED
CTAN1DE-SALT CONTAINING WASTES IN METAL HEAT TREATING OPERATIONS
DETONATING EXPLOSIVE WASTES
DISCARDED CLASS C EXPLOSIVES
OOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO DISPOSE OR OESTROY THEN
HYDROGEN SULFIDE WASTE IN SURFACE IMPOUNDMENT - REACTIVITY CHARACTERISTIC
POPPING FURNACES-OOD DISPOSAL OF OUTDATEO ORDNANCE BY INCINERATION - METALS RECOVERY
REACTIVE CHARACTERISTICS OF DISCHARGED L1/S02 BATTERIES
REACTIVE WASTE - EXPLOSIVITY
SMALL ARMS AMMUNITION REACTIVITY. OFF SPECIFICATION
SPENT IRON SPONGE REGULATION ANO TREATMENT
SULFIDE REACTIVITY CHARACTERISTIC
TCLP
.r_
G"'
•PETROLEUM CONTAMINATED MEDIA ANO 0EBR1S UNDER THE TC UST TEMPORARY OEFERAL
•REMOVAL OF TC WASTE FROM A SURFACE IMPOUNDMENT
ACTIVATEO CARBON CANISTERS SATURATED WITH SPENT SOLVENTS
ANALYTICAL METHODS FOR CONDUCTING TESTING UNDER THE TC RULE
BIAS CORRECTION APPLIED TO THE TCLP
CCA TREATED WOOD WHEN OISPOSEO
CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS Of MINING WASTES
DIGESTION OF IP AND TCLP EXTRACTS PRIOR TO METAL ANALYSIS
DILUTION OF TEST SAMPLING
ELECTRIC UTILITY POLES
EP TOXICITY TEST EXTRACTION MEDIUM, REQUESTEO CHANGE IN
EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCLP
GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS
GLASS FIBER FILTERS FOR USE IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
LABORATORY EQUIPMENT USED IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEOURE (TCLP)
LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
LEACH TESTING PROCEOURE TO REMOVE LEAD-CONTAMINATEO SOILS FROM RESIDENTIAL AREAS
LEACHATE TESTING FOR EVALUATING SOILS CONTAMINATED WITH LEAD
LEAD AND ARSENIC WASTES TREATMENT STANDARDS
LEADED PAINT SANOBLASTING WASTE TESTING USING TCLP
LOSS OF INTERIM STATUS FROM NEWLY IDENTIFIED TC WASTES
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
MATRIX SPIKE IN TCLP PROCEDURE
METHODOLOGIES EMPLOYED IN USEO OIL SAMPLING
MOBILE TREATMENT UNITS QUALIFIED FOR INTERIM STATUS
MODIFICATIONS TO WASTEWATER TREATMENT SYSTEM UNOER EXCLUSION
PETROLEUM REFINING WASTES ANO EXEPTIONS FOR WWTUs
POTENTIALLY CONFLICTING REGULATION OF INFILTRATION GALLERIES BY THE OGWOW ANO OSW
QC REVIEW OF PERMIT DATA
SHELL OIL FACILITY - TC COMPLIANCE
SLU08ES WITHIN SURFACE IMPOUNDMENTS, NEWLY REGULATED OUE TO TC RULE
TC APPLICABILITY TO MIXEO WASTE
9441.1987(52
9441.19B6
9443.1963(02
9441.198?!??
9441.1987(12
9441.1985(44
9443.1984(05
9443.1904(03
9443.1904	09
9444.1984(01
9443.190730
9443.1988(07
9441.1905	31
9443.1987(31
9441.1983(04
9443,1987(05
9443.1988(10
9443.1984(10;
9443.1986(02
9443.1985(04
9441.1990(31)
9443.1991(02)
9441.1986(54
9442.1991(17)
9442.1990	02
9441.1991(11)
9443.1985(09)
9443.1989(10)
9442.1991(04)
9441.1990(21)
9443.1985(10)
9442.1991(13)
9451.1986(03)
9443.1986(19)
9443.1986(17)
9443.1986(10)
9431.1909(01)
9443.1987(24)
9554.1990(11)
9442.1991(01
9528.1990(02
9493.1991(04
9493.1991(05
9442.1991	03
9442.1991(11
9528.1991(02
9441.1991(01
9483.1990	03
9521.1991	01
9442.1990(04
9431.1991(02
9484.1991(01
9441.1991 02
06/26/87
07/31/86
01/30/83
09/30/87
03/03/87
12/18/85
09/11/84
06/04/84
11/29/84
03/05/84
11/30/87
06/02/88
10/31/85
12/07/8?
06/08/83
03/18/87
09/13/88
11/30/84
01/17/86
07/16/85
10/01/90
11/01/91
07/15/86
10/01/91
11/08/90
06/28/91
10/03/85
12/13/89
03/25/91
07/19/90
10/21/85
10/09/91
04/28/86
09/30/86
09/03/86
05/05/86
06/26/89
11/05/B?
08/24/90
01/08/91
07/11/90
10/11/91
10/11/91
03/19/91
07/09/91
02/27/91
01/03/91
09/20/90
08/27/91
11/01/90
05/09/91
03/00/91
02/12/91

-------
Pag* No.
04/06/92
KEYWORD 1N0l_
TC RULE - IMPLEMENTATION
TC RULE HAZARDOUS WASTE DETERMINATION
TC RULE RELATIONSHIP TO USED OIL FILTER DISPOSAL
TCLP EXTRACTIONS APPLIED TO LIQUID WASTES. OILS AND SOLVENT-BASED PRODUCTS
TCLP EXTRACTIONS AS THE* APPLY TO OIL* WASTE
TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS VASTE IDENTIFICATION PROGRAM
TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONS
UNDERGROUND INJECTION WELLS USEO IN HVOROCARBON RECOVERY
USE OF PETROLEUM-CONTAMINATED SOILS AS AN INGREOIENT IN ASPHALT BATCHING
USED AUTOMOBILE ANTIFREEZE DISPOSAL
USED OIL FILTERS - REGULATION
USED OIL FILTERS, REGULATORY DETERMINATION
9441.1990(29)
9441.1991
9451.199H
9442.1991
9442.1991
9443.1967
9442.1991
9521.1991
9493.1991
9442.1991(
9441.1990
9442.19901
12
03
14
(00
29
16
02)
02
16
30
05
10/01/90
07/31/91
04/16/91
10/29/91
06/13/91
11/18/87
05/01/91
08/30/91
06/20/91
12/19/91
10/30/90
10/30/90
CHEMICAL DEODORANTS
(Sea Hazardous Waste Identification)
CHEMICAL STABILIZATION
XREF
/ /
(See Treatment)
CHLORINATION TANK
XREF
/ /
(See Listed Hazardous Waste)
XREF
CHROMIUM
/ /
(See Exclusions)
XREF

CIVIL ENFORCEMENT
/ !
(See Enforcement) (See also Compliance)
CLEAN AIR ACT
XREF
/ /
(See also Incineration, Used Oil. TSOFal
BIF REGULATIONS EFFECTS ON INOUStRIAL BOILER
GASEOUS EMISSIONS FROM LANDFILLS
INCINERATORS THAT RECEIVE GASEOUS EMISSIONS, RCRA EXCLUSION, CAA APPLIES
RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES
XREF
9488.1991(03)
9487.1986 03
9441.1984(15)
9487.1906(08)
CLEAN CLOSURE
/ /
09/23/91
03/06/B6
OF/31/84
05/27/66
(See Closure Process)
CLEAN WATER ACT
XREF
/ /
See also Exclusion)
NVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTS
XREF
9444.1986(07)
/ /
04/07/86

-------
I
Page No.	.
04/06/92	S
KEYWORD INDEX
\
VOOD PRESERVING AND SURFACE PROTECTION FACILITIES. CONTROLLING ENVIRONMENTAL RELEASES FROM
NPDES Facilities
LEAKS. SPILLS. AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WATERS, MIXTURE RULE APPLIED TO
PERMIT REQUIREMENTS FOR ZERO WASTEWATER TREATMENT SYSTEM
WASTEWATER TREATMENT UNIT EXEMPTION
Wastewater
~BOAT FOR WASTEWATER
~MIXTURE RULE - DISCHARGES TO WASTEWATER
'ZERO DISCHARGE AT FACILITIES ANO SURFACE IMPOUNDMENTS, RCRA EXCLUSION, CWA APPLIES
ANTMrTtra uicn nicpiKii poiriirFt
CARBON REGENERATION FACILITY. MIXTURE OF SOLID AND HAZARDOUS WASTES (CALGON)
EXEMPTION FOR WASTEWATER DISCHARGES AND GENERATOR ACCUMULATION PROVISIONS
FILTER PRESS PROPOSED AS PART OF CORRECTIVE ACTION - NOT EXCLUOED FROM PERMITTING
LAND DISPOSAL OF SOLVENTS
REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENT
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN ANO THE MIXTURE RULE
SURFACE IMPOUNDMENTS VIS-A-VIS NPOES-PERMITTED DISCHARGE POINTS
WASTES COVERED UNDER THE DIOXIN LISTING
WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIOE TO RECOVER ALKALOIOS FROM PLANT MATTER
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE
CLEANUP STANDARDS
9441.1906(28) 04/07/86
9441.1966(07
9471.1969(01
9431.1989(02
9432.1966(16)
9522.1967(02)
9441.1964(14
9442.1989(04
9441.1986(33
9441.1987(96
9433.1987(10)
9453.1987 09
9444.1987(49)
9433.1986(11)
9464.1986(09
9444.1986(23
9441.1986(52)
9444.1987(39)
01/23/66
03/20/89
09/26/89
12/30/86
12/30/87
05/30/84
04/26/89
04/23/86
12/10/87
06/12/87
12/10/87
10/26/87
04/24/86
12/29/66
10/21/86
07/02/86
09/02/87
X.
(See Corrective Action)
CLOSURE PLAN
~
(See Closure Process)
CLOSURE PROCESS
XREF
XREF
/ /
/ /
(See also Interim Status, Post-Closure, TSDF1
'CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENTS
'CORRECTIVE ACTION BEYOND FACILITY BOUNDARY - FINANCIAL RESPONSIBILITY REQUIREMENT
'LEASING OF PROPERTY PRIOR TO CLOSURE
'PERSONNEL TRAINING DURING POST CLOSURE
'TEMPORARY CLOSURE OF USTs
3008(h) ORDERS OR POST-CLOSURE PERMITS AT CLOSING FACILITIES, USE OF
CLOSURE REQUIREMENTS
DELAY OF CLOSURE PERIOO FOR HUM FACILITIES
DELAY OF CLOSURE RULE PREAMBLE LANGUAGE, CORRECTION
FINANCIAL RESPONSIBILITY REQUIREMENTS -CERTIFYING CLOSURE
GROUND-WATER QUALITY AT CLOSURE
LAND DISPOSAL UNIT CLOSURE CLARIFICATION OF PROPOSED AND PROMULGATED RULES
MIXED RADIOACTIVE AND HAZARDOUS WASTE. DISPOSAL OF
PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
POST CLOSURE PERMIT REQUIREMENTS (ARMCO STEEL)
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS 		
RCRA PROGRAM DIRECTIONS - PRIORITY TO ENVIRONMENTALLY SIGNIFICANT FACILITIES
RDM) PERMITS - POLICY GUIDANCE
RELEASES OF HAZARDOUS WASTE. RCRA APPLICABILITY TO
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
XREF
9484.1987(04
9502.1986110
9528.1983103
9523.19851 05
9483.1989105
9502.00-7
9476.00-12
9476.1989(01
9476.1989(02
9477.1990(02
9476.1985 02
9476.1985(05
9431.1968 02
9528.1986(08
9522.1986(03
9476.1985(04
9501.1987 02
9503.50-1A
9502.1967(05)
9523.00-17
/ /
04/30/87
05/30/86
09/30/83
10/30/85
10/30/89
03/08/88
02/02/88
05/16/89
08/22/89
05/28/90
08/27/85
12/13/85
01/30/88
11/20/86
11/20/86
09/25/85
12/14/87
12/23/65
04/02/07
09/02/88

-------
a No,
mm
KEYWORD INDEX
,-C
_D
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWEO FOR CLOSURE
TRANSFER OF A HAZARDOUS WASTE STORAGE OPERATION TO A NEW SITE
VOOO PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
CItan Closure
*CLEAN CLOSURE
•CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT AND WASTE PILE
CLEAN CLOSURE AND DISPOSAL OF AN INCINERATOR
CLEANUP LEVELS FOR LEAD AND CADMIUM IN SOILS FOR CLEAN CLOSURE
CLOSURE AND POST-CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS
DEMONSTRATING EQUIVALENCE OF PART 265 CLEAN CLOSURE VITH PART 264 REQUIREMENTS
EFFECTIVE OATES FOR CHARACTERISTIC I LISTED WASTES PER 03/19/07 CLEAN CLOSURE REGULATION
GROUNDWATER MONITORING AT CLEAN CLOSING SURFACE IMPOUNDMENT I WASTE PILE UNITS
SOIL BACKGROUND LEVELS AS CLEAN CLOSURE STANDARDS, USE OF
SOIL CLEANUPS FOR LEAD - CLEANUP STANDARDS FOR CLEAN CLOSURE
Closure Plan
~CLOSURE PLAN PUBLIC COMMENT PER 100 FOR INTERIM STATUS FACILITIES
'CLOSURE PLANS - APPEALS
•CONTINGENT CLOSURE ft POST CLOSURE PLANS FOR TANKS
•POST CLOSURE PLANS FOR HAZARDOUS WASTE TANKS
CALL-IN OF STORAGE AND TREATMENT APPLICATIONS
CLOSURE PLAN COMMENTS/ISSUES (CRUCIBLE STEEL)
CLOSURE PLAN FOR THE HAZARDOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT
CLOSURE PLANS-MOBILE TREATMENT UNITS
DEADLINES APPLICABLE TO PROPOSED DELAY OF CLOSURE REGULATION. GUIDANCE
DELISTING PETITION-STEEL FACILITY, REQUIREMENTS FOR CLOSURE PLAN
*	PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
*	SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
Closure Requirements
•CERTIFICATION OF CLOSURE
•ESTIMATED CLOSURE DATES IN PART B PERMIT APPLICATIONS
9523.00-12
9523.00-14
9484.00-5a
9520.1986(03
9441.1986
Jill
FOR TANK SYSTEMS
•HAZARDOUS WASTE TANK CLOSURE AND POST CLOSURE
•RETROFITTING SURFACE IMPOUNDMENTS
CLOSURE I POST-CLOSURE REQUIREMENTS REGARDING HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES
CLOSURE AFTER CESSATION OF RECEIPT OF HAZARDOUS WASTE
CLOSURE COST ESTIMATES
CLOSURE COST ESTIMATES BASED ON THIRD PARTY COSTS
CLOSURE ISSUES RELATED TO WOOD PRESERVING PLANTS
CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUS
CLOSURE REQUIREMENTS AT FACILITIES HAVING DELISTING EXCLUSIONS REVOKED
CLOSURE REQUIREMENTS FOR THE DISPOSAL OF STORAGE TANKS
CLOSURE STANDARDS FOR HAZARDOUS WASTE LAND TREATMENT UNITS
CLOSURE/POST-CLOSURE REGULATIONS/PARTIAL CLOSURE (EMELLE.AL)
ESTIMATED CLOSURE OATES IN PERMIT APPLICATIONS
FINANCIAL RESPONSIBILITY REGULATIONS RELATED TO BANKRUPTCY (LTV)
INTERIM STATUS SURFACE IMPOUNDMENTS I CLEAN CLOSED WASTE PILES, CODIFICATION RULE 12/01/87
NUETRALIZAT10N SURFACE IMPOUNDMENTS. GROUNDWATER MONITORING FOR CLOSURE OF INTERIM-STATUS
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 3005(1) OF RCRA
TEMPORARY PERIOD AND HOLDING DEFINED
03
01
04
02a)
9476.19871
9522.19881
9488.1987
9476.19881
9476.19871 08)
9476.00-111
9476.00-16
9476.00-14
9476.1988103a)
9502.1989(02)
9476.1907(07)
9476.1906 01a)
9483.1987 08)
9476.1988(03)
9528.1988(06)
9476.1984(05)
9488.1907(01)
9476.1986(02)
9476.1988(04)
9433.1986(07)
9528.1986(11)
9523.00-18
9523.00-15
9476.1987(05
9523.1984(03
9477.1986(11
9483.1989 01
9476.1986 02
9476.1986(04
9476.1983(02
9476.1986(03
9477.1963(03
9477.1984 01
9476.1984(04
9484.1986 02
9476.1988(01;
9403.1987(03
9476.1991(01
9476.1986(01
9523.1984(01!
9477.1986(12
9522.1988(05!
9484.1986(03
9476.1987(01)
9522.1986(01
03/30/87
03/14/86
10/15/88
03/03/86
04/07/86
06/30/87
02/28/88
06/12/87
03/02/88
12/17/87
05/12/88
04/01/88
03/31/88
05/27/88
05/25/89
11/30/87
08/30/86
05/30/87
04/30/88
04/19/88
09/18/84
02/09/87
08/22/88
05/31/88
03/18/86
12/10/86
03/14/89
03/30/88
09/30/07
04/30/04
06/30/86
04/30/89
09/30/86
10/30/86
01/11/83
10/08/86
12/09/83
01/12/84
08/07/84
04/02/86
01/29/88
04/08/87
05/02/91
05/08/86
01/17/84
07/23/86
11/30/88
04/09/86
06/09/87
12/20/85

-------
Page No.
04/06/92
KEYW0R0 INDEX
Closure Standards
CLOSURE PERFORMANCE STANDARD
FACILITY TRANSFER/RECONSTRUCTION OURINB INTERIM STATUS
POST CLOSURE PERMITTING REQUIREMENTS FOR N0N-RE6ULATE0 UNITS
Partial Closure
•AMENDING CLOSURE PLANS TO AOORESS PARTIAL CLOSURE
•TANK REPLACEMENT
Permitting
•AMENDING CLOSURE PLANS TO ADDRESS PARTIAL CLOSURE
"INTERIM STATUS CLOSURE CERTIFICATION
PERMITTING UNITS CREATED FOR FACILITY CLOSURE
Public Participation
•CLOSURE PLAN PUBLIC COMMENT PERIOD FOR INTERIM STATUS FACILITIES
PUBLIC PARTICIPATION REQUIREMENTS FOR CLOSURE PLAN APPROVAL
CLOSURE REQUIREMENTS
9471.00-13
9477.1986(01
9521.1985
9476.1985(01
9477.1988(03
9476.1985(01)
9476.1964	03)
9476.1965	03
9471.1987(07
9476.1989
02/08/88
01/03/86
09/25/85
06/30/85
07/30/88
06/30/85
03/30/84
09/11/85
11/30/87
09/07/89
(See Closure Process)
CLOSURE STANDARDS
XREF
/ /
(See Closure Process)
COAL
~
(See Milting Hastes)
^ COAL TAR/COKE
XREF
XREF
/ /
/ /
(See also Hazardous Waste Fuels)
'COKE AND COAL TAR RECYCLABLE MATERIAL REQUIREMENTS
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEOO COKE)
COAL TAR DECANTER SLUDGE WASTE PILE TOLEDO COKE)
WASTE-DERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIRED
WASTES GENERATED BY COKE AND COAL TAR PLANTS
XREF
9441.1989(04
9441.1987(75
9441.1987(98
9441.1986(08
9442.1987(02
/ /
02/28/89
09/04/87
12/24/87
01/24/86
07/24/87
COLLECTION PROGRAMS
(See Household Hazardous Waste)
COMMERCIAL CHEMICAL PRODUCTS
XREF
/ /
(See Listed Hazardous Waste)
XREF

-------
Page No.
04/06/92
KEYWORD IROCX
COMPATIBILITY
(Sm alio Containers. Liner*. Minimum Technology Requirements, Tank System)
BULKING AND CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WITH DIFFERENT HAZARI
CONTAINERS STORING HAZARDOUS WASTE. REQUIREMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
TRO INDICATING THAT ETHANOL AND STAINLESS STEEL ARE COMPATIBLE
DOUS CODES
COMPLIANCE
XREF
9461.1985(01
9402.1986(01
9523.00-12
9483.1987(12)
/ /
09/19/85
01/21/86
03/30/87
07/29/87
(See also enforcement, Interim Status Process]
'GROUNDWATER MONITORING-COKPLIANCE PERlOD/POSt-CLOSURE CARE PERIOD
•RCRA COMPLIANCE ORDERS
213 OF HSWA. REQUIREMENTS - PERMIT ISSUANCE AND CERTIFICATION OF COMPLIANCE
EPA AUTHORITY TO CONSIDER PERMIT APPLICANT HISTORY Of COMPLIANCE WITH RCRA
PERMIT COMPLIANCE/ENFORCEMENT ISSUES (REG. X)
PERMIT REQUIREMENTS, THERMEX ENERGY/RADIAN
PHYSICAL COMPLIANCE IN GROUNDWATER MONITORING, DEFINITION
Inspections
~INSPECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKS
•LABORATORY AUDIT INSPECTION
COMPLIANCE MONITORING
XREF
9481.1988(03)
9523.1986(03)
9522.1985(031
9523.1991(01)
9522.00-3
9521.1987(011
9481.1985(04)
9483.1987(06)
9431.1987(03)
/ /
04/30/88
08/30/86
07/05/85
03/13/91
11/13/87
08/07/87
10/30/85
05/30/87
07/30/87
(See Groundwater Monitoring)
COMPLIANCE SCHEOULES
XREF
/ /
A
(See also Corrective Action Enforcement,	State Authorization)
COMPLIANCE SCHEOULES IN RCRA PERMITS
CORRECTIVE ACTION AT FEDERAL FACILITIES.	NATIONAL PRIORITIES
INSTALLATION RESTORATION PROGRAM (IRP) -	DOD
INSTALLATION RESTORATION PROGRAM (IRP) -	DOD
COMPRESSED GAS CYLINDERS
XREF
9524.1984(01)
9502.1986(04)
9502.1986(20
9502.1986(20
/ /
10/05/84
02/13/86
12/08/86
12/08/86
(See Haiardous Waste Identification)
CONSTRUCTION
XREF
/ /
(See also Interim Status Process)
•CONSTRUCTION CURING INTERIM STATUS WHERE ORIGINAL UNITS ARE CLOSED
•CONSTRUCTION DURING INTERIM STATUS - RECONSTRUCTION LIMIT WHERE SOME UNITS HAVE CLOSED
•GROUNDWATER MONITORING WELL CONSTRUCTION
•PERMIT MODIFICATION
•RCRA PERMITS FOR MOBILE TREATMENT UNITS
CONSTRUCTION OF A NEW INCINERATOR WITH THE CHANGES DURING INTERIM STATUS
DESTRUCTION OF 0I0XIN CONTAMINATED SOIL USING MOBILE INCINERATION
1N-EX1STENCE AND UNDER CONSTRUCTION-DEFINITIONS
SPENT FLU1DIZEO BED MEDIA AND CHANGES UNDER INTERIM STATUS
XREF
9528.1987(03)
9528.1987(04)
9481.1985 05)
9525.1985	01)
9523.1986(01)
9528.1986(07)
9488.1986(05)
9432.1989(02)
9444.1986	28)
/ /
03/30/87
03/30/87
10/30/85
10/30/85
03/30/86
09/19/86
04/24/86
05/16/89
12/05/86

-------
Page No.
04/06/92
KEYWORD INDEX
SUMMARY OF PERMIT ASSISTANCE TEAM
SUMMARY OF PERMTI ASSISTANCE TEAM
PAT
PAT
COMMENTS
COMMENTS
Nw Unit
BIF RULE APPLIED TO NEWLY REGULATED UNITS AT INTERIM STATUS FACILITIES
EXISTING UNITS UNDER HSWA-APPLICABILITY OF MTR TO EXPANSIONS
INTERIM STATUS OF PROPOSED LANOFILL CELLS
PERMITTING UNITS CREATED FOR FACILITY CLOSURE
CONTAINERS
9523.00-12
9523.00-15
9529.199H
9432.19851
9487.19811
9476.1985(
01
04}
01
03
03/30/8?
03/30/88
08/07/91
08/30/85
03/12/81
09/11/85
i K
Empty
•ADDING ABSORBENT TO WASTE CONTAINERS
'HAZARDOUS WASTE TANKS/CONTAINERS - CAPACITY OF SECONDARY CONTAINMENT
•LAB PACKS AT GENERATOR SITES
•RELEASES FROM 90-DAY ACCUMULATION TANKS
ABSORBENTS FOR CONTAINERIZED LIQUID HAZARDOUS WASTES, USE OF
ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTS
CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN fiCRA LANDFILLS
CONTAINERS CLEANING OTHER THAN TRIPLE RINSING - PAPER BASS
CONTAINERS FOR SAFE AND ECONOMICAL STORAGE. TRANSPORT, ANO DISPOSAL OF HAZARDOUS WASTE, DEVELOPMENT OF
CONTAINERS STORING HAZARDOUS WASTE, REQUIREMENTS
CORRECTIVE ACTION/PERMIT ISSUES-US ARMY ABERDEEN PROVING GROUNDS
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES
EMPTY CONTAINER RULE APPLIED TO TANKER OR VACUUM TRUCKS
HAZARDOUS WASTE TRANSFER OPERATIONS
LAB PACKS - LANO DISPOSAL RESTRICTIONS ASPECTS
ON-SITE TREATMENT BY GENERATORS UNDER 262.34
ON-SITE TREATMENT EXEMPTION, REINTERPRETATION OF
PERMITTING OF TREATMENT ACTIVITIES IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERS
PESTICIDE DISPOSAL BY FARMERS AND CONTAINER MANAGEMENT	1
RESIDUES REMAINING IN EMPTY CONTAINERS, BURNING OF
SATELLITE ACCUMULATION
SATELLITE ACCUMULATION AREA AND REGULATIONS
SPECIAL MATERIALS 01SP0SE0 OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS
TANK TREATMENT PROCESSES
THIRD THIRD LANO DISPOSAL RESTRICTIONS
THIRD THIRD LAND DISPOSAL RESTRICTIONS FINAL RULE
TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMINATED OR RADIOACTIVE LEAO
TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWEO FOR ALL GENERATOR SUBJECT TO 262.34
TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORS
USED OIL FILTERS - REGULATION
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
•CONTAINER RESIDUE, REGULATION OF
•EMPTY CONTAINERS, POURING ADDITIONAL WASTE FROM
ACETONE ANO METHANOL CONTAMINATED WASHWATERS
CONTAINERS THAT HELD COMMERCIAL CHEMICAL PRODUCTS, DEFINITION OF EMPTY
CONTAINERS, TRIPLE RINSING FOR FERTILIZER
CONTAINERS, TRIPLE RINSING OF EMPTY
CONTAINERS. TYPES OF EMPTY - RESIDUE HANDLING
EMPTY CONTAINER RULE APPLIED TO TANKER OR VACUUM TRUCKS
EMPTY CONTAINERS REGULATORY STATUS
EMPTY DRUMS CONTAINING METALLIC NICKEL OR NICKEL OXIDE
EMPTY DRUMS FOR REUSE ANO RECONDITIONING, REGULATION OF
EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCT
9453.1990(02
9483.1988(14
9453.1988 02
9453.1986(05
9487.1985	05
9453.1986	01
9487.1986(12
9441.1985(15
9482.1985(01
9482.1986(01
9502.1986(09
9451.1986(01
9441.1986(02
9461.1989(01
9551.1990(02
9453.1987(03
9453.1987(08
9453.1986(04
9457.1987(01
9441.1986(04
9453.1989(07
9453.1987(01
9487.1986(13
9483.1990(02
9551.1990(15
9551.1991(13
9441.1987(52
9453.1986 07
9453.1991(02
9441.1990(30
9441.1986(28
9441.19831
9441.1985i
9444.1989
9441.19841
9441.19841
9441.19831
9441.1984
9441.1986
9432.1990
9441.1985
9441.1980i
9441.1985!
07/30/90
06/30/88
01/30/88
08/30/86
09/20/85
04/16/86
12/30/86
05/20/84
11/26/85
01/21/86
05/08/86
03/17/86
01/07/86
01/03/89
08/08/90
07/01/87
12/15/87
07/25/86
03/25/87
01/07/86
07/13/89
02/22/87
12/31/86
08/15/90
12/20/90
12/20/91
06/26/87
12/05/86
09/20/91
10/30/90
04/07/86
09/01/83
12/30/85
07/21/89
09/11/84
08/01/84
12/13/83
09/10/84
01/07/86
09/13/90
05/31/85
05/30/80
12/12/85

-------
Pago No.
04/06/92
MEYW0R0 INDEX
INDUSTRIAL EQUIPMENT THAT FORMERLY CONTAINED HAZARDOUS WASTE
PESTICIDE DISPOSAL BY FARMERS AND CONTAINER MANAGEMENT
RESIDUES REMAINING IN EMPTY CONTAINERS, BURNING OF
STEAM-SPRAYING OF AN EMPTY TANK
TANK riUK IIM IWIBK nFFINITIflN (IF FNPTV
UNRINSED CONTAINERS'(MICH FORMERLY CONTAINED AN UNUSED FORMULATION OF PENTACHLOROPHENOL
9441.1991
945?.198?
9441.1986
9441.1990
9441.1984
9444.1986
10/22/91
03/25/8?
01/07/86
04/10/90
11/28/84
02/12/86
CONTAINMENT
(See Secondary Containment)
CONTAMINATED GROUND WATER
XREF
/ /
(Sea Hazardous Waits Identification)
CONTAMINATED SOIL
XREF
/ /
(See Hazardous Waste Identification) (see also Corrective Action)
CONTINGENCY PLAN
XREF
/ /
Wn
VP
CONTINGENCY PLANS-INFORMATION SUBMISSION
ORIPPAGE IN WOOD PRESERVING STORAGE YARDS
Spills
. ~MUITISOURCE LEACHATC (F039) WASTE CODE AS IT APPLIES TO CONTAMINATION FROM SPILLS
RESPONSES TO ACCIDENTAL. SPILLS OF LISTED OR CHARACTERISTIC HAZARDOUS WASTES
CONTINUING RELEASES
(See Corrective Action)
CORPORATE GUARANTEE
9474.1984(01
9489.1991
9444.1991(06)
94?1.1986(01}
XREF
09/10/84
05/31/91
11/01/91
09/29/86
/ /
(See Financial Responsibility)
CORRECTIVE ACTION
XREF
/ /
•CORRECTIVE ACTION AND PERMITS
'CORRECTIVE ACTION BEYOND FACILITY BOUNDARY - FINANCIAL RESPONSIBILITY REQUIREMENT
•CORRECTIVE ACTION FOR INTERIM STATUS SURFACE IMPOUNDMENT
•CORRECTIVE ACTION FOR NEW FACILITIES
•CORRECTIVE ACTION FOR UIC WELLS
•CORRECTIVE ACTION IN PERMITS
•CORRECTIVE ACTION REQUIREMENTS WHILE SEEKING A MAJOR PERMIT MODIFICATION
•PETROLEUM CONTAMINATED MEDIA ANO OEBRIS UNDER THE TC UST TEMPORARY OEFERAL
BYPRODUCT MATERIAL ANO NIXED WASTE, AEA AND 00E INTERFACE
CONTAMINATED GROUNDWATER, REGULATORY STATUS OF
XREF
9502.1967(01)
9525.1988 01)
9502.1986(10)
9484.1986(07)
9481.1986(10)
9502.1986(07)
9521.1986(06a)
9502.1986(03)
9441.1990(31
9441.1986(46
9528.1987 02
/ /
01/30/87
02/28/88
05/30/86
07/30/86
10/30/86
04/30/86
06/30/86
01/30/86
10/01/90
06/02/86
03/11/87

-------
Page No.
04/06/92
\
KEYW0R0 INOEX
r
ENVIRONMENTAL RELEASES FROM WOOO PRESERVING PLANTS
FEDERAL FACILITIES INVENTORY UNOER RCRA 3016
FIRE TRAINING PITS, REGULATORY REQUIREMENTS FOR
GROUNDWATER CLEANUP STANDARDS/ACLs IN ORAFT HSVA PERMIT (INTERNATIONAL PAPER COMPANY)
HSWA APPLIED TO FEDERAL FACILITIES (DOE-OAK RIDGE)
PIPELINE TRANSPORTATION OF HAZARDOUS WASTE
RCRA CORRECTIVE ACTION PROCEDURES ANO AUTHORITIES
RELEASES OF HAZARDOUS WASTE. RCRA APPLICABILITY TO
SOL 10 WASTE MANAGEMENT UNIT FOR THE PURPOSE OF CORRECTIVE ACTION UNDER 3004(u), DEFINITION OF
SOL 10 WASTE MANAGEMENT UNITS. INFORMATION ON
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
WASTE PILES AND POST-CLOSURE PERMITS. APPLICATION OF NOVEMBER 1986 DEADLINE TO
WOOD PRESERVING ANO SURFACE PROTECTION FACILITIES. CONTROLLING ENVIRONMENTAL RELEASES FROM
Remediation
CERTIFICATION PROCESS ON BIOTECHNOLOGICAL METHODS FOR REMEDIATION OF INDUSTRIAL FACILITIES
CLOSURE STANDAROS FOR HAZAROOUS WASTE LAND TREATMENT UNITS
CONTAMINATED SOIL ANO DEBRIS TREATED REPLACEMENT UNDER A TREATABILITY VARIANCE
DRAFT SAMPLING AND ANALYSIS PLAN FOR NH PLATING COMPANY
Solid Waste Management Units (SWMUs)
•CORRECTIVE ACTION REQUIREMENTS AT FACILITIES HANDLING SCRAP METAL RECLAMATION
CORRECTIVE ACTION REQUIREMENTS FOR FEDERAL FACILITIES AND IRP ACTIVITIES
CORRECTIVE ACTION/PERMIT ISSUES-U.S. ARMY - ABERDEEN PROVING GROUNDS
FEOERAL FACILITIES INVENTORY UNDER RCRA 3016
FINANCIAL ASSURANCE FOR CORRECTIVE ACTION
GROUNDWATER MONITORING AT REGULATEO UNITS NEAR SWMUs THAT HAVE IHPACTEO GROUND WATER
IMMEDIATE IMPLEMENTATION OF NEW CORRECTIVE ACTION REQUIREMENTS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATEO UNITS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATEO UNITS
~ SOLID WASTE MANAGEMENT UNIT (SWMU) DETERMINATION
SOLID WASTE MANAGEMENT UNIT OEFINED FOR CORRECTIVE ACTION UNDER 3004(u)
SOL 10 WASTE MANAGEMENT UNIT FOR THE PURPOSE OF COORECTIVE ACTION UNDER 3004(u). DEFINITION OF
SOLID WASTE MANAGEMENT UNITS. INFORMATION ON
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SWMU CORRECTIVE ACTION RIA FACILITY DATA BASE
WOOD TREATMENT CYLINDER CREOSOTE SUMPS
WOOD TREATMENT CYLINDER CREOSOTE SUMPS
WOOO TREATMENT PLANT DRIP AREAS AS SWHUs, REGULATION OF
Voluntary Cleanups
VOLUNTARY CLEANUP CONSTRAINTS
VOLUNTARY CORRECTIVE ACTION
9444.1986
9502.1987
9489.19871 02
9481.19871
9502.1985<
9432.19861
9502.19861
9502.1987
9502.00-6
9502.1986(01a)
9523.00-14
9501.1985(01)
9441.1986(28)
9486.1989(01
9476.1991(01
9551.1990(05
9433.1990(06
9502.1985(04
9502.1986(14
9502.1986(09
9502.1987(03
9502.1986(13
9461.1987(05
9502.1985(01
9476.1985(04
9521.1985(01
9483.1991(01
9502.1987(07
9502.00-6
9502.1986(01a)
9523.00-14
9502.1987(08)
9502.1986(15)
9441.1986(69)
9502.1985(02)
9502.1988(02)
9502.1987(11)
04/07/86
03/06/87
07/22/87
03/10/87
10/29/85
04/30/86
01/31/86
04/02/87
07/02/87
01/23/86
03/14/86
10/01/85
04/07/86
03/30/89
05/02/91
10/09/90
11/27/90
06/30/85
08/22/86
05/08/86
03/06/87
08/22/86
06/17/87
02/06/85
09/25/65
09/25/85
01/04/91
07/24/87
07/02/87
01/23/86
03/14/86
08/11/87
09/12/86
09/12/86
06/17/85
02/18/88
12/21/87
CORROSIVE WASTES
(See Characteristic Hazardous Waste)
XREF
/ /
COST
(See Financial Responsibility)
XREF
/ /

-------
Pag# No.
04/06/92
KEYWORD INDEX
\
COST ESTIMATES
(See Financial ResponabllIty)
COVER DESIGN
XREF
/ /
CREOSOTE
CYANIDE
DATA
(See Final Cover)
(See Wood Treatment, Hazardous Waste Identification)
(See Hazardous Waste Identification) (See alio SW-646)
XREF
XREF
XREF
/ /
/ /
/ /
KA
<
CORRECTIVE ACTION TECHNOLOGY. HQ SUPPORT
SWHU CORRECTIVE ACTION RIA FACILITY DATA BASE
Noncompliance
REPORTING REQUIREMENTS SECTION 270.30(1)(10)
DE I|INIM1$
~TRUCK TRANSPORT OF WASTEWATER FOR PURPOSES OF SECTION 261.3(a)(2)(lv)(A)
0RIPPA6E IN WOOD PRESERVING STORAGE YARDS
DEADLINES
9502.1986(19) 10/07/86
9502.1987(00) 08/11/87
9524.1988(01) 02/23/88
9441.1991(13
9489.1991
07/01/91
05/31/91
(See Permit Process) (See also State Authorization)
DEFINITION
XREF
/ /
(See Solid Waste, Hazardous Waste Identification, Regulated Unit)
DELEGATION OF AUTHORITY
XREF
/ /
(See Permit Process)
OELISTING
XREF
/ /
(See also Appendix VIII, Appendix IX, Hazardous Waste Identification, Characteristic Hazardous Waste)
~OELISTING BY STATES
~OELISTING OF K051 WASTE AT PETROLEUM REFINERY-EFFECT ON INTERIM STATUS
ADOPTION OF TCLP FOR DELISTING DEMONSTRATIONS
XREF
9541.1986(24)
9433.1986(12)
9433.1990(03)
/ /
10/30/86
04/30/86
06/14/90

-------
Page No
04701
06/92
KEYWORD INDEX
DRAINAGE WATER BENEATH LAND TREATMENT UNITS - NO MIGRATION PETITIONS
ELECTRIC ARC FURNACE OUST AFTER ENCAPSULATION TREATMENT PROCESS
MIXING LOW ANO HIGH BTU HASTES - SHAM BURNING, BLENDING, MANIFESTING
PAINT VASTES AND SPENT SOLVENT LISTINGS
PETROLEUM REFINERY WW, MIXTURE AND DERIVED-FROM RULES
PLASTIC PACKING MEDIA FROM AIR STRIPPING TOWER TREATING CONTAMINATED GROUNDWATER
REFRACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY
RESIDUAL WATER OERtVED FROM AN EXEMPT WASTE (COAL ASH) IS EXEMPT
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE
SPENT ION EXCHANGE RESINS ANO FILTER AS HAZARDOUS WASTE
SPENT PICKLE LIQUOR FINAL RULE REGARDING SCOPE OF THE K062 LISTING. CORRECTION NOTICE
SPENT PIPELINE FILTER CARTRIDGES
SUPERNATANT FORMED IN LINE STABILIZATION OF WASTE PICKLE LIQUOR AS HAZARDOUS WASTE
SUPERNATANT FROM TREATMENT OF SPENT PICKLE LIQUOR (K082)
WASTE GENERATED BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHLOROBENZENE AND HEXACHLOROETHANE
Res(due
PERCHLOROETHYLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAINING
RESIDUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES
SCRUBBER BRINE/SLUDGE PRODUCED IN INCINERATION OF A LISTED HAZARDOUS WASTE
DESTRUCTION REMOVAL EFFICIENCY (ORE)
9551.1988(15)
9444.1906(331
9442.1966(05}
9444.1907(171
9441.1985(29j
9441.1989(171
9444.1988 05)
9441.1986(49
9433.1986	11
9444.1987(13)
9444.198631
9444.1908(03)
9441.1987	831
9444.1987(47}
9441.1988(04)
9441.1985(10
9496.1991 01
9441.1984 05
01/21/88
12/29/86
08/31/86
05/20/87
08/23/85
04/14/89
03/11/88
06/16/86
04/24/86
05/05/87
12/11/86
02/11/88
10/23/87
10/23/87
01/14/88
04/10/81
08/05/91
02/19/84
(Sec Incineration)
OETECTION LIMIT
XREF
/ /
(Set Analytic Methods)
XREF
DETECTION MONITORING
/ /
(See Groundwater Monitoring)
DIBUTYLIN OIFLUORIOE
XREF
/ /
(See Hazardous Waste Identification)
XREF
/ /
DILUTION
(See Characteristic Hazardous Waste) (See also Land Disposal Restrictions)
XREF
/ /
D10XIN
ISee also Listed Hazardous Waste, land Disposal Restrictions, RCRA/CERLA Interface)
LABORATORY TESTING FOR DI0X1N
•LAND DISPOSAL RESTRICTION. OIOXIRS, AND 90-DAY ACCUMULATION
•LAND DISPOSAL RESTRICTION* - SOLVENT ANO 0I0X1N WASTES
•VARIANCES TO BAN - EFFECTIVE DATES FOR SOLVENTS AND DIOXINS
CHLORIHATEO DIOXIN VASTES (F023)
CLOSURE PLAN FOR THE HAZARDOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT
OELISTING ISSUES RELATING TO EPA'S MOBILE INCINERATOR
XREF
9441.1985(11
9551.1987104
9553.1906' 01
9551.19B622
9444.1985116
9468.198701
9433.19861 20
/ /
03/30/85
01/30/87
02/20/08
12/30/86
09/26/85
02/09/87
12/11/06

-------
Page No.
04/06/92
\
KEYWORD INDt*
( h
CHLORINATED OIOXIN WASTES (F023)	j
COMBINATION OF SLUDGES FROM ALL IHPOUNOHENTS TO DETERMINE WASTE VOLUME FOR VHS ANALYSIS
CONTAMINATED SOIL AND DEBRIS TREATED REPLACEMENT UNDER A TREATABILITY VARIANCE
CYANIDE FURNACE CRUCIBLES TREATMENT
DELISTING ACTION - STATUS OF HOLLOHAN AIR FORCE BASE
DELISTING CRITERIA/LEACHATE LEVELS
DELISTING OF WASTE BY AUTHORIZED STATES
DELISTING OF WASTE GENERATEO FROM ZINC PHOSPHATING ON CARBON STEEL
DELISTING PETITION - FUJI PHOTO FILM WASTEWATER TREATMENT SLUDGE
DELISTING PETITION FOR INCINERATOR ASH
0ELIST1NG PETITION INFORMATION REQUIREMENTS FOR RESIDUES FROM INCINERATION OF 2,4,5-T AND SILVEX PESTICIDES
DELISTING PETITION OF NITROGEN TETROXIDE RINSATE
DELISTING PETITION, USE Of VHS MODEL
DELISTING PETITION-STEEL FACILITY, REQUIREMENTS FOR CLOSURE PLAN
DELISTING PETITIONS, PROCEOURES FOR PROCESSING
OELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIES
DELISTING RESIDUE FROM TREATMENT OF LISTED WASTES
DELISTING TESTING REQUIREMENTS, CYANIDE ANO OTHER WASTES. STEEL INOUSTRY
OEL1 STING, INTERIM STATUS, AND SAMPLING ISSUES AT U.S. NAMEPLATE COMPANY
DESTRUCTION OF OIOXIN CONTAMINATED SOIL USING MOBILE INCINERATION
DETECTION LIMIT REQUIREMENTS AND INFORMATION ON APPENDIX VIII COMPOUNDS FOR A DELISTING PETITION
DI0X1N-C0NTAINING WASTE RINSEATES. OISPOSAL BY DEEP WELL INJECTION
ELECTROPLATING SLUDGE. EXCLUSION PETITION
ENFORCEMENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENDING DELISTING REGULATIONS
ENFORCEMENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENOING DELISTING PETITIONS
EVALUATION OF DELISTING PETITIONS-INFORMATION REQUIRED
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
EXCLUSION OF WASTE GENERATEO AT INDIVIDUAL FACILITIES (DELISTING)
F006 LISTING FOR PICKLING AND ETCHING WASTES ANO DELISTING ISSUES
GENERATOR LIABILITY FOR DELISTEO WASTE RELEASES
• GROUNDWATER CONTAMINATION AS A BASIS TO DENY A DELISTING PETITION
HAZARDOUS WASTE LISTING FOR F006 WASTE
HSWA EFFECT ON STATE DELISTING DECISIONS
K035 LISTING ANO DELISTING ISSUES:GROUNOWATER CONTAMINATION
LIME SLUDGE IMPOUNDMENT SLUDGE, DELISTING OF
MAGNESIUM SULFATE VS. ALUMINUM SULFATE DELISTING PETITION
MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS
METAL, K061 WASTES IN SURFACE IHPOUNDMENT-DELISTING PETITION
MIXTURE OF F003 AND A SOLID WASTE ANO OELISTING REQUIREMENTS
MIXTURES OF SOL 10 ANO HAZARDOUS WASTES
PETITION TO WITHORAW K090 AND K091 LISTINGS
PROCESS WASTE DELISTEO BY THE STATE DESIGNATED THE WASTE NON-HAZARDOUS WITHIN THE STATE
SOIL CONTAMINATED WITH TOLUENE 0II50CYANATE (TD1)
SPENT PICKLE LIQUOR OELISTING PETITION
SPENT PICKLE LIQUOR GENERATED FROM PORCELAIN ENAMEL INDUSTRY, DELISTING OF
STATE PESTICIDE PERSONNEL - DEREGULATING OECONTAMtNATEO WATER
SUBSURFACE FATE AND TRANSPORT MOOEL
TEMPORARY AND INFORMAL DELISTINGS AND HSWA EFFECTS ON BOTH
WASTES FROM BRIGHT DIPPING UNDER THE REINTERPRETED F006 LISTING
Temporary Exclusion
•DELISTING OF K051 WASTE AT PETROLEUM REFINERY-EFFECT ON INTERIM STATUS
RCRA 3001(f)(2)(bl AND STATES* EXCLUSION OF WASTES FROM REGULATION AS HAZARDOUS
RCRA 3001If)(2)(b) AND STATES' EXCLUSION OF WASTES FROM REGULATION AS HAZARDOUS
SLUDGE WASTE HANDLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY
STATUS OF FACILITY WHERE A TEMPORARY DELISTING EXCLUSION WAS NEVER GRANTEO
SURFACE IMPOUNDMENTS HOLDING ONLY K-WASTES GENERATED UNDER A TEMPORARY EXCLUSION
9444.1985(16
9433.1987(07
9551.1990(0S
9433.1990(05
9433.1987116
9433.1966(01
9542.1980(04
9441.1964 24
9433.199101
9433.1991(03
9433.1987(26
9433.1990(07
9433.1985(05
9433.1986(07
9433.1987(15
9433.1967(22
9441.1981105
9433.1984(06
9433.1987(03
9433.1986(10 :
9433.1986(19
9444.1985(14
9433.1984(05
9504.1987 01
9433.1987(14
9433.1986(04
9441.1986(03
9542.1982(01)
9444.1987(55
9433.1985(04
9433.1987(08
9441.1986(78
9433.1985(02
9433.1987(27
9484.1986(05
9433.1990(01
9444.1967(40
9433.1987(18
9441.1987(65
9441.1987(06
9444.1989(11
9541.1966(04
9433.1990(02
9433.1991(02
9433.1984(03
9433.1986(08
9431.1991(01
9433.1986 14
9444.1987(28
9433.1986
9541.1986
9433.1986
9433.1986
9433.1986
9433.1987
12)
05
09
17
06
23

-------
Page No.
04/06/92
KEYWORD INDEX
CORRECTIVE ACTION AT FEOERAL FACILITIES, ISSUES AND NATIONAL PRIORITIES FOR
CORRECTIVE ACTION AT FEOERAL FACILITIES. NATIONAL PRIORITIES
CORRECTIVE ACTION AUTHORITY AT FACILITIES THAT LOSE INTERIM STATUS
CORRECTIVE ACTION PLAN (CAP), CONTENTS AND USE OF
CORRECTIVE ACTION REQUIREMENTS FOR FEDERAL FACILITIES AND 1RP ACTIVITIES
CORRECTIVE ACTION TECHNOLOGY, HQ SUPPORT
CORRECTIVE ACTION/PERMIT ISSUES-U.S. ARHY-ABEROEEN PROVING GROUNDS
DOD'S IRP PROGRAM AND RCRA CORRECTIVE ACTION
FACILITIES NOT SUBJECT TO CORRECTIVE ACTION
FIBER OPTICS FOR IN-SITU MONITORING
FINANCIAL ASSURANCE FOR CORRECTIVE ACTION BEYOND FACILITY BOUNDARIES
INSTALLATION RESTORATION PROGRAM (IRP) - DOD
LAND DISPOSAL RESTRICTIONS:SOILS AND OEBRIS FROM RCRA CORRECTIVE ACTION
PARTIAL PERMITTING OF INCINERATOR UNIT (DOW)
PERMITTING AND CORRECTIVE ACTION REQUIREMENTS AFFECTING COMPLIANCE WITH LAND DISPOSAL RESTRICTIONS
RCRA CORRECTIVE ACTION PROGRAM
RCRA PERMIT REAUTHORIZATION ISSUES IN REGION III
RCRA PERMITS WITH HSWA CONDITIONS - JOINTLY ISSUED PERMITS
RCRA PROGRAM DIRECTIONS - PRIORITY TO ENVIRONMENTALLY SIGNIFICANT FACILITIES
SOIL CLEANUPS FOR LEAD - CLEANUP STANOARDS FOR CLEAN CLOSURE
SOLID WASTE MANAGEMENT UNITS. INFORMATION ON
STATE AUTHORIZATION TO REGULATE HAZARDOUS COMPONENTS OF RADIOACTIVE MIXED WASTES
SUMMARY OF ASSISTANCE BRANCH PERMITTING COHHENTS
SUHHARY OF PERMIT ASSISTANCE TEAM (PAT) COHHENTS
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 3005(1) OF RCRA TO
TREATMENT SURFACE IHPOUNDHENTS, REGULATORY OPTIONS AVA
UIC CORRECTIVE ACTION REQUIREMENTS, IMPLEMENTATION
VULNERABILITY GUIDANCE
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES
ZINC OXIDE RECLAIHEO FROM KILNS
VAILABLE TO WOOD PRESERVERS
9502.1986(01
9502.1986(04
9526.1987(01
9502.1987(04
9502.1986(14
9502.1986(19
9502.1986(09
9502.1986(17
9502.1986(05
9502.1987(09
9502.1989 01
9502.1986(20
9551.1908 14
9522.1985	04
9502.1986(11
9431.1991(03
9541.1985(01
9502.1987(06
9501.1987(02
9502.1989(02
9502.1986(01a)
9541.1986(20)
9523.00-18
9523.00-15
9476.1987(01)
9484.1987(12)
9502.00-3
9401.1987(01)
9441.1986	28)
9444.1988(02a)
01/08/86
02/13/86
01/30/87
03/13/87
08/22/86
10/07/86
05/08/86
09/29/86
03/24/86
09/03/87
03/02/89
12/08/86
12/30/88
08/30/85
06/16/86
05/01/91
03/06/85
06/30/87
12/14/87
05/25/89
01/23/86
10/20/86
03/14/89
03/30/88
06/09/87
11/25/87
08/04/86
02/25/87
04/07/86
01/26/88
< r«
Administrative Order
CORRECTIVE ACTION AT FEDERAL FACILITIES
PREVIOUSLY UNREGULATED SURFACE IMPOUNDMENT - CORRECTIVE ACTION OROERS
Cleanup Standards
CLASSIFICATION OF LEACHATE CONTAMINATED GROUNDWATER
CORRECTIVE ACTION RULE
FEOERAL POLICY REGARDING DIOXIN DISPOSAL
INTERIM SOIL CLEAN-UP LEVELS FOR LEAD AT SUPERFUND SITES
REINJECTED GROUNDWATER RESULTING FROM CORRECTIVE ACTION TREATMENT
Continuing Releases
uing Releases
CORRECTIVE ACTION PLAN (CAP), CONTENTS AND USE OF
ASSESSMENTS. IMPLEMENTATION
RCRA
RCRA Facility Assessment (RFA)
FACILITY ASSESSMENTS,
Regulated Unit
GROUNDWATER MONITORING AT REGULATED UNITS NEAR SWMUs THAT HAVE IMPACTED GROUND WATER
RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
Release
'ENFORCEMENT USING 3000(h) AUTHORITY AND 3013 ORDERS
3000(h) OF THE SOLID WASTE DISPOSAL ACT, INTERPRETATION OF
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION AT FEOERAL FACILITIES
9502.00-2
9502.1986(07a)
9554.1991
9502.1988
9444.1987
9502.1990
9554.1991
02)
01
(26)
01
03
9502.1987(04)
9502.00-4
9481.1987(05)
9502.1986(02)
9502.1986(18)
9502.1985(09)
9502.00-2
9502.1906(06)
04/18/86
04/30/86
01/01/91
08/23/88
07/02/87
05/07/90
04/01/91
03/13/87
08/21/86
06/17/87
01/31/86
09/30/86
12/16/85
04/10/06
04/15/06

-------
P«Q« No.
04706/92
KEYWORD INDEX
TEMPORARILY AND INFORMALLY DELISTED HASTES. REGULATORY STATUS
TEMPORARY AND INFORMAL DELISTINGS AND HSWA EFFECTS ON BOTH
TEMPORARY EXCLUSION APPLIED TO ONLY ONE FACILITY (MONROE AUTO)
VHS Modal
DELISTING ISSUES RELATING TO EPA'S MOBILE INCINERATOR
DELISTING PETITION. USE OF VHS MODEL
DELISTING PETITIONS FOR K-WASTES MANAGED IN ON-SITE LAND-BASED UNITS-MONITORING REQUIREMENTS
DELISTING REGULATORY STANOAROS FOR FREON
DENIAL OF DELISTING PETITION BASED ON EXISTING GROUNDWATER CONTAMINATION
DETECTION LIMIT REQUIREMENTS AND INFORMATION ON APPENDIX VIII COMPOUNDS FOR A OELISTINS PETITION
F006 WASTES. VHS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION
K103/K104 WASTE STREAMS - RELATIONSHIP OF CWA BAT. LAND DISPOSAL RESTRICTIONS. BOAT, AND DELISTING CRITERIA
RECONSIDERATION OF DELISTING OENIAL BASEO ON USE OF VHS, TOTAL CHROMIUM STANDARD, AND MCL
SURFACE IMPOUNDMENT DELISTING PETITIONS. USE OF VHS MODEL
9433.1986(05
9433.1986 14
9441.1987(30
9433.1986(20
9433.19051
9433.1987>
9433.1987(
9433.19871
9433.1986
9433.19871
9433.19871
9433.1986
9433.19871
02/24/86
05/27/86
04/30/87
12/11/86
11/27/8S
09/28/07
09/03/87
03/19/87
12/09/86
06/08/87
04/02/87
03/24/86
10/26/87
OEMINIMUS
(Sea also Listed Hatardous Wasta)
OENIAL
XREF
/ /
(See Permit Process under Permit Denial)
DENTAL AMALGAM
XREF
/ /
( (See Scrap Metal)
DEPARTMENT OF OEFENSE (00D)
XREF
/ /
-O
(See Federal Facilities)
DEPARTMENT OF ENERGY (DOE)
XREF
/ /
(See Federal Facilities) (See also Mixed Waste)
OEPARTMENT OF TRANSPORTATION (DOT)
XREF
/ /
(See Generators, Transporters)
DERIVED-FROH RULE
XREF
/ /
(See also Mixture Rule)
•DOMESTIC SEWAGE EXCLUSION
•RECLAIMED SPENT WOOD PRESERVATIVE EXCLUSION IN 261.4(a)(9)
•SPENT SOLVENTS FROM VARNISH STRIPPING
BEVILL AMENDMENT APPLIEO TO COAL GASIFICATION FACILITY
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)
CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUS
DERIVED FROM/MIXTURE RUL^ APPLICATION TO REFINERY WASTEWATER TREATMENT SYSTEMS
XREF
9461.1987
9441.1991
9441.1986
9441.1987
9441.1987
9442.1984
9441.1987
041
19
57)
[76
98
01
70
/ /
07/30/87
12/01/91
05/30/86
09/15/87
12/24/87
12/26/84
08/28/87

-------
Page No.
®4/0i
06/92
KEYWORD INDEX
DESTRUCTION OF OIOXIN CONTAMINATED SOIL USING MOBILE INCINERATION	9433.1986(10
OIOXIN IN HASTES FROM WOOD PRESERVING PROCESSES USING PENTACHIOROPHENOL	9444.1985 02
DIOXIN STANDARD USED TO TEST GAS CHROMATOGRAPHY COLUMNS. HANDLING OF	9441.1985(07
010X1N TRIAL BURNS FOR PURPOSES OF CERTIFICATION FOR A RCRA PERMIT	9488.00-1A
0I0XIN-C0NTAIN1NG LABORATORY WASTE WITH RADIOACTIVE PROPERTIES	9441.1985(26
OIOXIN-CONTAINING WASTE RINSEATES, DISPOSAL BY OEEP WELL INJECTION	9444.1985(14
EXCLUSION FROM RCRA PERMITTING REQUIREMENTS FOR LESS THAN 90-0AY ACCUMULATORS OF OIOXIN CONTAINING WASTES	9453.1985(02
F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPKENOLIC COMPOUNDS	9444.1987(42
F027 IISTINING-USEO AND UNUSEO FORMULATIONS IN WOOD PRESERVING	9444.1987(10
FEDERAL POLICY REGARDING DIOXIN DISPOSAL	9444.1987(26
INCINERATOR PERMITS TO BURN OIOXIN WASTES, MODIFICATION OF	9488.1985(04
LABORATORY CARCASSES CONTAINING TCDD	9441.1987(36
LABORATORY SAMPLE EXCLUSION APPLICABILITY TO SAMPLES AND WASTES FROM LABORATORY ANALYSIS - DIOXIN	9441.1987(29
LABORATORY WASTE GENERATED IN RESEARCH USING TCDD STOCK SOLUTIONS	9444.1986(16
LABORATORY WASTES (INCLUDING CARCASSES, BEDDING, CAGES) CONTAINING OIOXIN	9444.1986(30
LUBRICATING OIL CONTAMINATED WITH TCOO THROUGH USE AS AN ANALYTICAL STANDARD	9444.1987(481
MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGE	9443.1986(13
RCRA METHODS AND QA ACTIVITIES (NOTES)	9445.1965(04
REFRACTORY WASTES AT U.S. IPA COMBUSTION RESEARCH FACILITY	9444.1988(05
SOIL CONTAMINATED WITH PESTICIOE	9441.1987(21
SOIL CONTAMINATED WITH USEO AND UNUSEO PESTICIDES	9444.1987(12
SOILS FROM MISSOURI OIOXIN SITES, WETHER HAZARDOUS	9441.1984(01
SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATER	9444.1986(05
TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS WASTE IDENTIFICATION PROGRAM	9443.1987(29
UNRINSED CONTAINERS WHICH FORMERLY CONTAINED AN UNUSEO FORMULATION OF PENTACHIOROPHENOL	9444.1986(03
WASTES COVERED UNOER THE DIOXIN LISTING	9444.1986(23
WASTES FROM ENVIRONMENTAL CHEMISTRY LABORATORY	9444.1987 34
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE	9444.1987(39
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM	9441.1986(28
04/24/86
03/04/85
02/13/85
05/07/86
07/01/85
09/10/85
03/12/85
09/23/87
04/09/87
07/02/87
05/30/85
05/14/87
04/30/87
08/18/86
12/10/86
10/23/87
05/27/86
06/30/85
03/11/88
04/08/87
04/18/87
01/06/84
03/03/86
11/18/87
02/12/86
10/21/86
08/07/87
09/02/87
04/07/86
DISCARDED MATERIALS
a
(Set Solid Waste) (See also Land Disposal Restrictions, RCRA/CERCLA Interface)
DISCHARGE
XREF
/ /
DISPOSAL
(See Wastewater) (See also Spills)
XREF
/ /
(See also Land Disposal Facilities, Land Disposal Restrictions, Recycle, TSOF)	XREF
~MANUFACTURING PROCESS UNITS	9441.1987
•TANK CLOSURE IN 1977 - RCRA APPLICABILITY TO	9480.1987
•USE CONSTITUTING DISPOSAL, RESIDUES FROM FIRE TRAINING EXERCISES	9493.1985
ACCUMULATION OF SECONDARY MATERIAL - ABANDONED VS. DISPOSED OF	9441.1985
CLEAN CLOSURE ANO OISPOSAL OF AN INCINERATOR	9488.1987
CONTAINERS FOR SAFE AND ECONOMICAL STORAGE, TRANSPORT, AND OISPOSAL OF HAZARDOUS WASTE	9482.1985)
CREOSOTE TREATED CROSS TIES, OISPOSAL OF, FIFRA INTERFACE	9441.19851
DECHARACTERI2ATION ANO OISPOSAL OF HAZARDOUS WASTES THAT HAVE UNDERGONE CHEMICAL	SOLIDIFICATION 9493.1985
DRY TOLVENE AND CARBON TETRACHLORIDE, SAFE OISPOSAL OF	9451.1986
EXCLUSION FROM REGULATION FOR CHARACfERISTIC ANO LISTED WASTES - LEACHATE LEVELS	9441.19861
FORMALDEHYDE-BASED TOILET DEODORANTS	9441.1986
	 	 	 	 		9432,19861
LEVEL RADIOACTIVE	AND HAZARDOUS WASTE DISPOSAL 9467.00-8
71)
01
04)
25)
04)
01
28)
05
06
03)
38
m
/ /
08/30/87
05/30/87
11/30/85
07/01/85
06/12/87
11/26/85
07/16/85
12/13/85
12/15/86
01/07/86
05/01/86
07/28/06
08/03/87

-------
Page No.
04706/92
KEfUORO INDEX
K006 WASTE AND ONSITE DISPOSAL UNIT CONTAINING THESE WASTES	9444.1907
LEAKS, SPILLS, AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WATERS, MIXTURE RULE	APPLIED TO 9441.1966
MARINE DEBRIS IN WATERS. DISPOSAL OF	9432.1987(
OPEN BURNING/OPEN DETONATION AT 000 FACILITIES	9502.1986
PERFORMANCE AND PERMITTING STANDARDS IN 3004(b), PROHIBITION OF PLACEMENT OF HAZARDOUS	WASTE IN SALT OWES 9489.1985
PROPER DISPOSAL OF OLD MEDICATIONS	9574.1990
RESIDUALS GENERATED BY PROCESS FOR SEWAGE SLUDGE TREATMENT	9442.1988
RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES	9487.1986(
SEDIMENT SAMPLE DISPOSAL	9441.1989
SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS	94B7.1986
USED OIL, BURNING OF OFF-SPECIFICATION FUEL - DUMPING	9441.1986
37)
07}
12s)
16)
01
01.
01)
08 >
12
13
40
08/19/87
01/23/86
11/04/87
09/22/86
09/20/85
11/28/90
02/10/88
05/27/66
03/31/89
12/31/86
07/31/86
DO-IT-YOURSELFERS (DIVERS)
(See Used Oil)
DOUBLE LINER
XREF
/ /
(See Minimum Technology Requirements)
XREF
ORE
/ /
(See Incineration, under Destruction Removal Efficiency)
DREDGED SEDIMENT
XREF
/ /
(See Hazardous Waste Identification)
DRILLING FLU10S
XREF
/ /
(See Energy Exploration Wastes)
DRINKING WATER
XREF
/ /
~GROUNDWATER MONITORING FOR RADIONUCLIDES
EP TOXICITY LEVEL FOR BARIUM IN DRINKING WATER
HEALTH-BASED LEVEL FOR CYANIDE
PETROLEUM REFINERY SLUDGE REGULATIONS
POTENTIALLY CONFLICTING REGULATION OF INFILTRATION GALLERIES BY THE OGWDW AND OSW
REINJECTED GROUNDWATER RESULTING FROM CORRECTIVE ACTION TREATMENT
UNDERGROUND INJECTION WELLS USED IN HYDROCARBON RECOVERY
9481.1987(06
9443.1989(03
9442.1988(02
9444.1990(05
9521.1991(01
9554.1991(03
9521.1991(02
06/30/87
04/20/89
03/30/88
10/17/50
08/27/91
04/01/91
08/30/91
DRIP PAOS
'WOOD PRESERVING WASTES - ADMINISTRATIVE STAY
ORIPPAGE IN WOOD PRESERVING STORAGE YARDS
9489.1991(03)
9489.1991(02)
06/01/91
05/31/91

-------
Page No.
04/
06/92
KEYWORD INDEX
DRUM SHREDDING UNIT
(See Treatment)
BUST
BERYLLIUM WASTE DUST
CEMENT KILN DUST WASTE
RECYCLING OF ELECTRIC ARC FURNACE OUST
STAINLESS STEEL PRODUCTION RESIDUES
OUST SUPPRESSION
(Sea also HSWA, Oltposal, Used Oil)
•USED OIL AS DUST SUPPRESSANT
OUST SUPRESSION AS ROAD TREATMENT
HSWA PROHIBITION ON THE USE OF HAZARDOUS WASTE AS A OUST SUPPRESSANT
TWO WASTE OIL MANAGEMENT PRACTICES REGULATORY STATUS
ELECTRIC ARC FURNACE
(See Hazardous Waste Identification, Incineration)
ELECTROPLATING
' (See also Listed Hazardpus Waste. Solvents)
'ELECTROPLATING AND ELECTROLESS PLATING LISTINGS
•F006 SLUDGE FROM ACID WASTE MIXTURE
•WASTEWATER TREATMENT SLUDGE FROM CHEMICAL ETCHING
"WASTEWATER TREATMENT SLUDGE FROM ELECTROPLATING OPERATIONS
') y	CADMIUM WASTES FROM MILITARY COATING MATERIALS
DRAFT SAMPLING AND ANALYSIS PLAN FOR NH PLATING COMPANY
ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE F006 LISTING
ELECTROPLATING RINSEWATERS
ELECTROPLATING RINSEWATERS NOT IN F007-009 LISTINGS
ELECTROPLATING SLUDGE, EXCLUSION PETITION
ELECTROPLATING WASTES
F006 ANO F01I ELECTROPLATING LISTINGS
F006 LISTING ANO DEFINITION OF CONVERSION COATING
F006 LISTING APPLIED TO PRINTING INDUSTRY
F006 LISTING FOR PICKLING ANO ETCHING WASTES AND DELISTING ISSUES
F009 LISTING AND THE MIXTURE RULE TO ELECTROPLATING RINSEWATERS AND RESINS
F009 LISTING FOR ELECTROPLATING AFTER CYANIDE BATH	>
F019 LISTING AND THE CONVERSION COATING PROCESS
IMMERSION PLATING WASTEWATERS-ORONZE PLATING
LAND OISPOSAL RESTRICTIONS ON THE METAL FINISHING INDUSTRY
MECHANICAL PLATING WASTES IN THE F006 LISTING, NON-INCLUSION OF
NARROWING THE SCOPE OF THE F006 LISTING		
RECYCLING NICKEL. COPPER AND CHROMIUM-CONTAINING ELECTROPLATING SLUDGES
RECYCLING OF ELECTROPLATING SLUDGES (F006) FOR CEMENT/AGGREGATE MANUFACTURE
RCINTERPRITATION OF THE F006 LISTING		
SLUDGES GENERATED FROM THE FIRST CLEANING STAGES OF PHOSPHATING PROCESS
XREF
/ /
9434.1989(01)
9441.1980(36
9441,1980(27)
9441.1988 07
03/17/69
07/29/88
06/15/88
03/10/88
XREF
9493.1985(06;
9493.1985 01
9493.00-1A
9495.1991(01)
/ /
12/30/85
07/12/85
05/31/86
06/05/91
XREF
/ /
XREF
9432.1989(01)
9441.1987(11)
9444.1984(02
9453.1984(021
9441.1990 11
9433.1990(06)
9444.1987(03
9442.1987(03
9444.1988	07
9433.1984 05)
9441.1991(06)
9444.1986(09)
9444.1987(09)
9444.1987(19)
9444.1987(55)
9444.1967 31
9444.1989(06)
9444.1907 22)
9442.1988(05
9554.1987(02)
9444.1986(13)
9444.1986(21)
9441.1988(09)
9441.1989	19
9444.1986(19)
9444.1986 11)
/ /
08/30/89
02/28/87
03/30/84
05/30/84
04/12/90
11/27/90
01/27/87
07/28/87
04/07/88
12/11/84
05/29/91
05/02/86
03/26/87
05/22/87
12/28/87
07/28/87
07/30/89
06/24/87
10/03/88
02/03/87
06/24/86
10/04/86
04/06/88
04/26/89
09/25/86
05/22/86

-------
Page No.
04/06/92
KEYWORD INDEX

SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY
SPENT ION EXCHANGE RESIN
SPENT ION EXCHANGE RESINS AND FILTER AS HAZARDOUS WASTE
WASTE FROM CHEMICAL ETCHING USING CYANIDE
WASTE TREATMENT FACILITIES ACCEPTING F006 ELECTROPLATING WASTES
WASTES FROM BRIGHT DIPPING UNDER THE REINTERPRETED FOOS LISTING
WASTES FROM ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL EXCLUDED FROM F006
WASTEWATER TREATMENT SLUDGE RESULTING FROM METAL CLEANING PROCESS
WASTEWATER TREATMENT SLUDGES FROM ELECTROPLATING OPERATIONS
ZINC PLATING, WASTEWATER TREATMENT SLUDGE GENERATED FROM
Ptckl* Liquor
CORRECTED LISTING DESCRIPTION FOR K062
EXCLUSIONS FOR K-WASTES OENIEO (LACLEDE STEEL)
K062 - SPENT PICKLE LIQUOR LISTING
K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRY
LIME STABILIZED WASTE PICKLE LIQUOR SLUDGE EXCLUSION
LIME-STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION FOR LIME-AMMONIA STABILIZED IRON OXIDE SLUDGE
MIXTURES OF PICKLE LIQUOR AND OTHER WASTES AND THE LINE STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION
PICKLE LIQUOR ANO SCOPE OF K0S2 LISTING
PICKLE LIQUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE
SIC CODE FOR A STEEL MANUFACTURER/PROCESSOR. PICKLE LIQUOR SLUOGE - POINT OF WASTE GENERATION
SPENT ACIO FROM ELECTROPOLISHING OF STAINLESS STEEL
SPENT PICKLE LIQUOR CORROSIVITY
SPENT PICKLE LIQUOR DELISTING PETITION
SPENT PICKLE LIQUOR FINAL RULE REGAROING SCOPE OF THE K0S2 LISTING. CORRECTION NOTICE
SPENT PICKLE LIQUOR GENERATES FROM PORCELAIN ENAMEL INDUSTRY, DELISTING OF
SPENT PICKLE LIQUOR SLUDGE. LIHE-STABILIZEO, IN IRON ANO STEEL AND PORCELAIN ENAMELING INDUSTRIES
SPENT PICKLE LIQUOR USEO IN PRODUCTION OF FERRIC CHLORIDE
, SPENT PICKLE LIQUOR USED/REUSEO IS NOT SOLID WASTE
SPENT PICKLE LIQUOR, DEFINITION OF HAZARDOUS
SPENT PICKLE LIQUOR, REUSE OF
SPENT PICKLE LIQUOR, STATUS OF SUPERNATANT FROM LIME NEUTRALIZATION OF
SPENT PICKLE LIQUOR, USE/REUSE EXEMPTION AS APPLIED TO
SPENT SULFURIC ACIO PICKLE LIQUOR USED TO PRODUCE FERTILIZER
SUPERNATANT FORMED IN LINE STABILIZATION OF WASTE PICKLE LIQUOR AS HAZARDOUS WASTE
SUPERNATANT FROM TREATMENT OF SPENT PICKLE LIQUOR (K062)
WASTE LISTINGS F006 ANO K062, SCOPE OF
2|nc |>||||m
DELISTING OF WASTE GENERATEO FROM ZINC PH0SPHAT1NG ON CARBON STEEL
ELECTROLESS ZINC PLATING WASTE NOT IN F006 LISTING
ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL
ZINC PLATING, WASTEWATER TREATMENT SLUDGES GENERATEO FROM
9441.1989(34
9444.1965 11
9444.19B7 13
9444.1967(16.
9554.1988(05)
9444.1967(28
9444.1967(14
9444.1909 08
9444.1965(13
9441.1964(29
9444.1987(31»)
9441.1989 48)
9444.1984(11
9444.1987(06
9441.1967 74)
9441.1987 54)
9441.1987(06
9444.1985(17)
9432.1967(13)
9441.1965(18)
9444.1984(12)
9443.1966(05)
9433.1991(02)
9444.1986	31
9433.1984(03)
9441.1984(31)
9441.1985(27)
9441.1966(61
9441.1987(39)
9441.1987(17)
9441.1984	12
9441.1985	20
9493.1985 02
9441.1987	83
9444.1987(47
9444.1986(32)
9441.1984(
9444.1967
9444.1964
9441.1984(
24)
23
09
29
07/06/89
06/19/85
05/05/87
05/20/87
08/11/88
07/13/87
05/08/87
08/21/89
09/03/85
09/24/84
07/30/87
09/12/89
07/27/84
03/16/87
09/02/87
07/13/87
01/28/87
10/03/85
11/10/87
05/21/65
07/30/84
05/02/88
04/26/91
12/11/86
10/23/84
10/25/84
07/16/85
08/18/86
05/20/87
03/31/87
06/04/84
06/05/85
11/14/85
10/23/87
10/23/87
12/12/86
09/06/84
06/30/87
06/13/84
09/24/84
ELEMENTARY NEUTRALIZATION UNITS
(St* Exclusions)
EMERGENCY PERMIT
XRIF
/ /
EMERGENCY PERMITS FOR DETONATION OF EXPLOSIVE WASTE
TANKS USEO FOR EMERGENCY CONTAINMENT
TEMPORARY TANK SYSTEMS USEO IN RESPONSE TO EMERGENCIES, REQUIREMENTS FOR
9527.1986(01
9471.1984(03
9463.1987(04
01/05/86
09/06/84
04/20/87

-------
Pag* No.
04/06/92
KEYWORD INDEX
\
EMISSION CONTROL WASTES
(Sea Sludge)
EMPTY
XREF
/ /
(See Container*. Tank System)
ENERGY EXPLORATION HASTES
XREF
/ /
(St* also Ntnlno Waste)
"DRIP GAS EXCLUSION
•OIL AND GAS EXCLUSION APPLICABILITY
MINING WASTE EXCLUSION INCLUDING PRIMARY PROCESSING BUT NOT SUBSEQUENT STEPS
OIL AND GAS EXPLORATION EXCLUSION
TC RULE - IMPLEMENTATION
Drilling Fluids
DRILLING FLUIOS AND PRODUCED WATERS, SUBTITLE C EXCLUSION OF
DRILLING OPERATIONS, EXEMPTION OF CERTAIN WASTE FROM
ENFORCEMENT
XREF
9441.1909(05
9441.1980(42
9441.1966(81
9441,1987(04
9441.1990(29
9441.1903(02
9441.1980(03
/ /
02/28/89
09/30/B8
11/03/86
01/13/87
10/01/90
04/19/83
09/04/80
{See also Compliance)
NFORCEHENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENDING DELISTING REGULATIONS
, ENFORCEMENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENDING DELISTING PETITIONS
ENFORCEMENT POLICIES FOR HISSING PART A APPLICATIONS
EPA ENFORCEMENT OF RCRA-AUTHORIZED STATE HAZARDOUS WASTE LAWS AND REGS.
GWM DEFICIENCIES IN PART B'a, RESPONSES TO AND MECHANISMS TO PREVENT
INADEQUATE PART B PERMIT APPLICATION
PENALTIES FOR FAILURE TO SUBMIT A COMPLETE AND ADEQUATE PART B APPLICATION
PERMIT COMPLIANCE/ENFORCEMENT ISSUES (REG. X)
RCRA FACILITY ASSESSMENTS, IMPLEMENTATION
ROLE OF AUTHORIZED STATES IN DISPUTE RESOLUTION
Administrative Order
•ENFORCEMENT USING 3001(H) AUTHORITY AND 3013 ORDERS
•RCRA COMPLIANCE OROERS
3008(h) ORDERS OR POST-CLOSURE PERMITS AT CLOSING FACILITIES, USE OF
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES, NATIONAL PRIORITIES
Enforcement ActlonRs p0ST-CLOSURE PERMITS AT CLOSING FACILITIES, USE OF
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
EP TOXICITY
XREF
9504.1967(01
9433.1987(14
9504.1903(01
9541.1982(01
9504.1984(02}
9521.1984(01)
9523.1964(10)
9522.00-3
9502.00-4
9541.1987(01)
9502.1986(18)
9523.1986(03)
9502.00-7
9502.00-2
9502.1986(04)
9502.00-7
9523.00-12
/ /
07/20/87
07/20/87
08/10/83
05/17/82
U/29/84
05/02/84
12/18/64
11/13/87
08/21/86
01/14/87
09/30/86
08/30/86
03/08/80
04/18/86
02/13/86
03/08/68
03/30/87
(See Characteristic Hazardous Waste)
XREF
/ /

-------
KIYWORO INUtX
EPA 1.0. NUMBER
(Sat alto Generator#, Transporters, TSDF. Notification)
'MANIFESTING REQUIREMENTS AND EPA ID NUMBERS
~TRANSFER FACILITY AS CENTRAL COLLECTION POINT
GENERATOR I.D. NUMBERS TO COLLEGES AND UNIVERSITIES. ASSIGNING
PROGRAM IMPLEMENTATION GUIOANCE ON ISSUANCE OF PROVISIONAL EPA ID NUMBERS
RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE, I.D. NUMBERS FOR
Identification
DOT MANIFEST REQUIREMENTS
IDENTIFICATION NUMBERS FOR RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE
RAPID ISSUANCE OF IDENTIFICATION NUMBERS TO SITES UNOER INVESTIGATION BY DEA
Identification Numbers
•IDENTIFICATION NUMBERS FOR TWO COMPANIES ON SAME SITE
EPA 10 NUMBER AND FACILITY LOCATION
EQUIVALENCY
(Sea Test Methods)
XREF

9452.1989
[01
9461.1991
01
9451.1983
02
9463.1980
02
9441.19B6
05
9461.1987(05
9442.1986(01
9451.1907(01
9432.1988(02
9461.1989(03
XREF
/ /
12/30/89
11/01/91
09/30/83
11/26/80
01/16/86
09/30/87
01/16/86
02/05/87
02/20/88
OB/18/89
/ /
EXCLUSIONS
(X
(See also Agricultural Waste, Hazardous Waste Identification, Recycle, Solid Waste, Wastewater)
"API SEPARATOR SLUDGE, EXCLUSION OF WATER FRACTION FROM K051 LISTING
•BATTERY REGENERATION
•COKE AND COAL TAR RECYCLABLE MATERIAL REQUIREMENTS
•CONDITIONS FOR EXCLUSION OF PORTABLE TREATMENT UNITS
•LAB EXCLUSION, APPLICATION OF
•LABORATORY TESTING FOR 010XIN
•MEDICAL WASTE - HOUSEHOLD ME01CAL WASTE
•MINING WASTE EXCLUSION REINTERPRETATION
•MOBILE WASTEWATER TREATMENT UNITS
•POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSION
•RECLAIMED SPENT WOOD PRESERVATIVE EXCLUSION IN 261.4(a)(9)
•WASTES GENERATED IN PROCESS UNITS
•ZERO OISCHARGE AT FACILITIES AND SURFACE IMPOUNDMENTS, RCRA EXCLUSION, CWA APPLIES
AQUEOUS SOLUTION, 1GN1TABILITY DEFINED
CCA TREATED WOOD WHEN DISPOSED
DENIZATION ACID
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE
DOMESTIC SEWAGE SLUDGE EXCLUSION
0RILL1NQ FLUIDS AND PRODUCED WATERS. SUBTITLE C EXCLUSION OF
DRILLING OPERATIONS. EXEMPTION OF CERTAIN WASTE FROM
DRY CLEANING ANO MAINTENANCE SERVICES WASTE NOT EXCLUDEO AS HDUSEHOLO WASTE
EMISSION CONTROL DUST/SLUDGE FROM ELECTRIC ARC FURNACE AT FOUNDRY NOT A K061 WASTE
ENVIRONMENTAL HAZARDS ASSOCIATED WITH BURNING HAZAROOUS WASTE IN CEMENT KILNS
EXCLUSIONS FOR K-WASTES OENIEO (LACLEDE STEEL)
EXCLUSIONS FOR PRE-EXISTING CONDITIONS IN RCRA TSDF INSURANCE POLICIES, GUIDANCE ON
HOUSEHOLO WASTE - OISPOSAL OF CARBON-ZINC BATTERIES
HOUSEHOLD WASTE EXCLUSION SCOPE
INTERNATIONAL TRANSPORT OF LAB SAMPLES
K006 WASTE AND ONSITE DISPOSAL UNIT CONTAINING THESE WASTES
XREF
9441.1984(13)
9441.19B5(30a)
9441.1989(04)
9471.1984(02)
9441.1984(22)
9441.1985(11)
9441.1989(24)
9441.1985(35)
9432.1987(05]
9441.1905(09)
9441.1991(19}
9441.1986(96)
9441.1984 14
9443.1985(021
9441.1991(11)
9443.1986(11)
9441.1980(111
9441.1990(02)
9441.1983(02)
9441.1980(03)
9441.1986(32)
9441.1984(08)
9441.1987(78)
9441.1989 48)
9477.00-6
9441.1984(07)
9574.1991(01
9441.1989(20)
9444.1987(37)
05/30/84
09/30/85
02/28/89
03/30/84
07/31/84
03/30/85
08/16/89
10/30/85
06/30/87
02/28/85
12/01/91
12/30/66
05/30/B4
02/26/85
06/28/91
05/12/86
04/21/88
02/12/90
04/19/83
09/04/80
04/21/86
05/03/84
10/08/87
09/12/89
11/23/87
04/19/84
05/30/91
04/27/89
08/19/87

-------
Page No.
04/06/92
KEYWORD INOEX
K051 SLUDGE RE-USEO ON-SITE, EXEMPTION
LABORATORY WASTE EXCLUSION
LAND DISPOSAL OF SOLVENTS
MINING WASTE REGULATED UNOER SUBTITLE 0 RATHER THAN SUBTITLE C
MIXING OF METHANOL AS NON-HAZARDOUS WASTE
MIXTURES OF SPENT SOLVENTS - F00I-F005. REGULATORY STATUS OF
MODIFICATIONS TO WASTEWATER TREATMENT SYSTEM UNOER EXCLUSION
OIL AND GAS EXEMPTION IN 3001(b)(2)(A) OF RCRA: IRON SPONGE PROCESS
ON-SITE TREATMENT EXEMPTION
PROCESS WASTE DELISTED BY THE STATE OESIGNATEO THE WASTE NON-HAZARDOUS WITHIN THE STATE
RAW MATERIAL TRANSPORT VESSEL EXCLUSION FOR ALL WASTES GENERATEO ON SUCH VESSELS
RCRA 3001(f)(2)(b) AND STATE'S EXCLUSION OF WASTES FROM REGULATION AS HAZAROOUS
RESIDUES FROM U.S. NAVY SALVAGE FUEL BOILER
RESPONSE TO REGION III IMPLEMENTATION AND OVERSIGHT ISSUES
SCRAP OEM* AND SMALL CAPACITORS CONTAINING OEHP, DISPOSAL REQUIREMENTS FOR
SIC CODE FOR A STEEL MANUFACTURER/PROCESSOR. PICKLE LIQUOR SLUDGE - POINT OF WASTE GENERATION
SLUDGE DEHYDRATION EQUIPMENT THAT IS PART OF A WASTEWATER TREATMENT FACILITY
SPENT PICKLE LIQUOR SLUDGE. LIME-STABILIZED, IN IRON ANO STEEL AND PORCELAIN ENAMELING INDUSTRIES
SPENT PICKLE LIQUOR, STATUS OF SUPERNATANT FROM LIME NEUTRALIZATION OF
SPENT PICKLE LIQUOR, USE/REUSE EXEMPTION AS APPLIED TO
TEMPORARY EXCLUSION APPLIED TO ONLY ONE FACILITY (MONROE AUTO)
TRUCK OR RAIL SHIPMENT OF HAZARDOUS WASTE TO A POTW
WASTES GENERATED IN MANUFACTURING PROCESS UNIT NOT SUBJECT TO LAND DISPOSAL RESTRICTIONS UNTIL REMOVED
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE
ZIRCONIUM PHOSPHATING SLUDGES EXEMPTION
9494.1985(02
9441.1905(03
9453.1967(09}
9441.1986 55
9471.1983(01
9441.1964 06
9441.1991(01
9441.1983 03
9521.1987(03
9541.1986(04
9441.1986 65
9541.1986 05
9441.1987116
9541.1986(10
9441.1985(23
9441.1985(18
9522.1988(02
9441.1964(31
9441.1984(12
9441.1981(20
9441.1987(30}
9441.1986 88
9441.1987(53
9444.1987(39
9444.1990(04
07/30/85
07/31/85
12/10/87
07/16/86
07/12/03
04/10/84
01/03/91
05/25/83
12/15/87
03/03/86
09/03/86
10/31/86
03/17/87
05/01/86
06/27/85
05/21/85
03/07/88
10/25/84
06/04/84
06/05/85
04/30/87
11/30/86
06/29/87
09/02/87
05/02/90
Chromium
•SW-B46 TEST METHOD 3060
CHROMIUM WASTES, EXCLUSION FOR CERTAIN
CHROMIUM WASTES; TRIVALENT AND HEXAVALENT, CHROMIUM IN TANNERY WASTES
* SPENT SULFURIC ACID PICKLE LIQUOR USED TO PRODUCE FERTILIZER
TOTAL CHROMIUM ANALYSIS
¦C~
e*
Elementary Neutralization Un»t«
•ELEMENTARY NEUTRALIZATION UNITS
ELEMENTARY NEUTRALIZATION EXEMPTION
HAZARDOUS WASTE TANK SYSTEM STANDARDS TO ANCILLARY EQUIPMENT AND EXEMPTED ELEMENTARY NEUTRALIZATION SYSTEMS
TANK TREATMENT PROCESSES
WASTEWATER TREATMENT AND ELEMENTARY NEUTRALIZATION UNITS EXEMPTION
9443.1987
9441.1988
9441.1986
9493.1985
9443.1987
20)
03
24)
02)
11}
9471.1988(03)
9471.1988 02)
9483.1988 01)
9483.1990(02)
9471.1987(02)
09/30/8/
01/13/88
03/21/86
11/14/85
06/08/87
07/30/88
04/29/88
01/27/88
08/15/90
12/21/87
Exemption
"ELEMENTARY NEUTRALIZATION UNITS
•FUME INCINERATORS
•HAZARDOUS WASTE EXPORT RULE FOR BATTERY RECLAMATION
•OIL AND GAS EXCLUSION APPLICABILITY
•PARTS WASHING WITH MINERAL SPIRITS, SMALL QUANTITY GENERATORS
•TRUCK TRANSPORT OF WASTEWATER FOR PURPOSES OF SECTION 261.3(a)(2)((v)(A)
•WASTE DERIVED FROM TREATING EXEMPT OR EXCLUDED WASTES
•WASTEWATER TREATMENT UNIT DEFINITION
•WASTEWATER TREATMENT UNIT/GENERATOR ACCUMULATION TANK
CLOSURE REQUIREMENTS AT FACILITIES HAVING DELISTING EXCLUSIONS REVOKED i
COAL/FOSSIL FUEL COMBUSTION WASTES EXCLUDED FROM SUBTITLE C PENDING FURTHER STUDY
ELEMENTARY NEUTRALIZATION EXEMPTION
EXEMPTION FOR WASTEWATER DISCHARGES AND GENERATOR ACCUMULATION PROVISIONS
LEAKING OR DAMAGEO EXPLOSIVES
LIME STABILIZED WASTE PICKLE LiqUOR SLUDGE EXCLUSION
LIME-STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION FOR LIME-AMMONIA STABILIZED IRON OX10E SlUOGE
9471.1988(03)
9488.1986(03)
9497.1986(018)
9441.1988 42)
9441.1986 45
9441.1991 13
9441,1967(31]
9432.1988 05
9483.1988(15)
9476.1988(01)
9441.1984(20)
9471.1988(02)
9441.1987(96)
9471.1988(05)
9441.1987(74)
9441.1987(54)
07/30/88
03/30/86
05/30/86
09/30/88
05/30/86
07/01/91
04/30/87
10/30/88
07/30/88
01/29/88
08/16/84
04/29/88
12/10/87
11/30/88
09/02/87
07/13/87

-------
Page No.
04/06/92
%
\
KEYWORD INDEX
C
—X
Filter Praia
•FILTER PRESS IN WASTEWATER TREATMENT UNIT. EXCLUSION FOR
FILTER PRESS PROPOSEP AS PART OF CORRECTIVE ACTION - NOT EXCLUDED FROM PERMITTING
Fossil Fuels
•FOSSIL FUEL COMBUSTION WASTE EXCLUSION
•MINING EXCLUSION FOR SHELTER SLAG
COAL/FOSSIL FUEL COMBUSTION WASTES EXCLUDED FROM SUBTITLE C PENDING FURTHER STUDY
FOSSIL FUEL COMBUSTION WASTE EXCLUSION IN 261.4(b)(4), FUEL MIXTURES
Gaseous Emissions
INCINERATORS THAT RECEIVE GASEOUS EMISSIONS, RCRA EXCLUSION, CAA APPLIES
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER	9441.1966(73)	09/25/66
NIXED RADIOACTIVE HOSPITAL WASTES AND THE OOHESTIC SEWAGE EXCLUSION	9441.1966 94	12/19/66
MIXTURES OF PICKLE LIQUOR AND OTHER WASTES AND THE LINE STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION	9441.1987(06	01/26/67
OIL AND GAS EXPLORATION EXCLUSION	9441.1967(04 i	01/13/87
OIL FIELO OPERATIONS, EXEMPTIONS FOR CERTAIN	9441.1969(27 i	06/06/69
ON-SITE TREATMENT EXEMPTION. REINTERPRETATION OF	9453.1967(08)	12/15/87
PERMIT-EXEMPT STATUS OF SLUDGE DRYERS ADDED TO WASTEWATER TREATMENT UNITS	9503.52-1A	01/02/66
PETROLEUM REFINING WASTES AND EXEMPTIONS FOR WWTUs	9483.1990(03)	09/20/90
PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)	9441.1966(31)	04/21/66
QUANTUM TECH PLASMA ARC UNIT - REGULATORY CLASSIFICATION	9488.1991(04)	09/30/91
ROM) PERMIT FOR A SLUDGE DRYING PROCESS IN A WASTEWATER SYSTEM	9503.51-1A	12/24/85
REGULATION AND PERMITTING OF LABORATORIES	9441.1988(39)	08/30/68
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE	9493.1991(01)	01/08/91
RESPONSES TO ACCIDENTAL SPILLS OF LISTED OR CHARACTERISTIC HAZARDOUS WASTES	9471.1966(01	09/29/86
SCRAP AMALGAM FILLINGS FROM DENTISTS. DISPOSAL OF	.	9441.1969(22	05/17/69
SCRAP METAL REMOVED FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED	9441.1966(79	10/20/86
SECONDARY MATERIALS REGULATION - USED SULFURIC ACID	9441.1988(23)	06/06/88
SEDIMENT SAMPLE OISPOSAL	9441.1989(12	03/31/89
SLUDGE DEHYDRATION EQUIPMENT AS A WASTEWATER TREATMENT UNIT	9432.1987(08)	06/03/67
STABILIZED WASTE PICKLE LIQUOR FROM STEEL/IRON INDUSTRY	9441.1990 16)	06/19/90
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS	9523.00-14	03/14/86
TC RULE DELAY OF IMPOSITION ON OIL FILTERS	9441.1991(15)	09/25/91
TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONS	9442.1991(16)	05/01/91
TEST SAMPLES, EXCLUSION FROM HAZARDOUS WASTE	9431.1989(03}	06/05/89
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM	9432.1967 01	03/17/87
USEO BATTERIES RETURNED FOR REGENERATION EXEMPTION	9497.1991(01)	03/04/91
USEO CRANKCASE OIL DISPOSEO OF BY DO-IT-YOURSELFERS	9441,1987(64)	08/13/87
USED OIL. BURNING OF OFF-SPECIFICATION FUEL - DUMPING	9441.1986(40	07/31/66
WASTEWATER TREATMENT SYSTEM, SOLVENT RECOVERY STILL BOTTOMS	9441.1965(43	12/17/85
WASTEWATER TREATMENT UNIT EXEMPTION	9431.1969 02)	09/26/89
ZINC OXIDE RECLAIMED FROM KILNS	9444.1988(02#)	01/26/88
9432.1964(041
9433.1967(10)
9441.1986(16
9441.1984(23
9441.1984(20
9441.1981(01
05/30/84
06/12/67
02/28/86
07/31/84
08/16/64
01/13/81
9441.1984(15) 07/31/84
Mining Waste
•EXPLORATION OR PRODUCTION OF CRUDE OIL, NATURAL GAS, OR GEOTHERMAL ENERGY - WASTE EXCLUSION
•MINING EXCLUSION FOR SMELTER SLAG
•MINING WASTE EXCLUSION RE INTERPRETATION
•MINING WASTE. K064, MID 3004(x)
•ORE AND MINERAL EXfRACTION. BENEFICIATION AND PROCESSING EXCLUSION APPLICABILITY
•PRODUCED WATERS FROM NATURAL GAS EXPLORATION-EXCLUSION
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTES
DECISION DEADLINES FOR RETROFITTING WAIVER REQUESTS
OROSS FROM ALUMINUM SMELTING USED IN MANUFACTURE OF CEMENT
INDUSTRIAL FURNACES BURNING HAZAROOUS WASTES AND THE RESIDUALS GENERATED (LOUISIANA REG)
9441.1984(11
9441.1964(23
9441.1985(35)
9571.1986(04
9571.1989(01
9441.1984(21 i
9441.1987(76
9443.1985(09
9571.1987(01
9441.1989(01
9494.1987(02
04/30/84
07/31/84
10/30/85
07/30/86
01/30/89
07/31/84
09/15/87
10/03/85
10/08/87
02/07/89
04/15/87

-------
Page
04/0i
No.
06/92
KEYWORD INDEX
MINERAL PROCESSING RESIDUALS FROM COMBUSTION UNITS BURNING HAZARDOUS HASTE FUEL
MINING LABORATORY HASTES UNDER 40 CFR *261.4(b)(7) - EXCLUSION OF
MINING HASTE AS NON-HAZARDOUS HASTE
MINING HASTE EXCLUSION FOR A FERROALLOY FACILITY
MINING HASTE EXCLUSION INCLUDING PRIMARY PROCESSING BUT NOT SUBSEQUENT STEPS
MINING HASTE REGULATED UNDER SUBTITLE D RATHER THAN SUBTITLE C
PHOSPHATE AND OAS PROCESSING INDUSTRY HASTES
RESIDUAL HATER OERIVEO FROM AN EXEMPT HASTE (COAL ASH) IS EXEMPT
Totally Enclosed Treatment Units
AUTHORIZATION OF STATE PROGRAMS TO IMPLEMENT LAND DISPOSAL RESTRICTIONS PROGRAMS
CHEMICAL AGENT/MUNITIONS SYSTEM (CADMS) IS HOT TOTALLY ENCLOSED ANO SUGGESTED RDID PERMIT
EVAPORATOR USED TO REMOVE WATER FROM HAZARDOUS HASTE
FILTER PRESS PROPOSED AS PART OF CORRECTIVE ACTION - NOT EXCLUDED FROM PERMITTING
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
TOTALLY ENCLOSED TREATMENT EXEMPTION AND ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
TOTALLY INCLOSED TREATMENT EXEMPTION FOR VET-AIR OXIOATION IMlTfVERTECH)
TREATMENT OF HAZARDOUS HASTE IN PIPELINES LEAOING TO A HASTEHATER TREATMENT PLANT
9441.1984
9441.1984
9441.1986
9441.1986
9441.1986
9441.1986
9443.1983
9441.1986
19)
091
72)
48)
01
55)
04
49)
EXEMPTION
(See Exclusions)
9541.1986(13
9432.1985	07
9432.1987 03
9433.1987(10
9432.1986(07
9432.1987(10
9432.1986(15
9432.1986(06
9441.1986	62
XREF
08/15/84
05/09/84
09/16/86
06/10/86
11/03/86
07/16/86
07/05/83
06/16/86
06/24/86
11/19/85
05/01/87
06/12/87
02/11/06
08/28/87
12/22/86
02/06/86
08/19/86
/ /
EXPANSIONS
(See Permit Conditions) (See also Interim Status Process)
EXPLORATION WASTE
XREF
/ /

(See Mining Haste)
XREF
EXPLOSIVE HASTES
/ /
(See Characteristic Hazardous Haste)
EXPORT OF HAZARDOUS HASTE
XREF
/ /
(See also Transporters, Manifest)
1 EXPORT OF HAZARDOUS WASTE
•EXPORT OF RECYCLABLE MATERIALS
•EXPORTING HAZAROOUS WASTES
*HAZARDOUS HASTE EXPORT RULE FOR BATTERY RECLAMATION
BATTERY RECYCLING AND EXPORT
CANADIAN MANIFEST FOR SHIPMENTS ENTERING THE U.S.
EXPORT OF HAZARDOUS HASTES UTILIZED FOR PRECIOUS METALS RECLAMATION
EXPORT REQUIREMENTS FOR SPENT BATTERIES SENT TO FOREIGN COUNTRIES FOR RECYCLING
EXPORTERS OF HAZAROOUS HASTE TO MEXICO. RESPONSIBILITIES OF
EXPORTING PETROLEUM HASTE TO SOUTH AMERICA
LAND DISPOSAL RESTRICTIONS APPLIED TO EXPORTED HASTES
RECOVERED LEAD AND LEAD ALLOYS FROM BATTERIES
REPROCESSING OF BATTERIES
XREF
9455.1986(01
9456.1986
9456.1987
9497.1986
9497.1987
9462.1985
9455.1991
9455.1987
9455.1987
9455.1989
9551.1991
9455.1991
9497.1987
01
01)
Ola)
01)
01
Oil
01)
02)
01
07)
03)
02)
/ /
09/30/86
10/30/86
08/30/87
05/30/86
02/12/87
11/29/85
02/05/91
06/19/87
06/15/87
06/27/89
04/23/91
12/10/91
02/19/87

-------
Page No.
04/06/92
KEYWORD INDEX
EXPOSURE INFORMATION
(See Risk Assessment)
EXTENSION
F-WASTES
FACILITY
(See alio Land Disposal Restrictions)
XTENSION TO GENERATOR ACCUMULATION TIME LIMITS FOR UNFORESEEN. TEMPORARY CIRCUMSTANCES
EXTENSIONS TO STORAGE PROHIBITION AND LAND DISPOSAL RESTRICTIONS
POTENTIALLY CONFLICTING REGULATION OF INFILTRATION GALLERIES BY THE OGVDU ANO OSW
UNDERGROUND INJECTION WELLS USED IN HYDROCARBON RECOVERY
(Sea Listed Hazardous Uaste)
XREF
XREF
9453.1987(05)
9555.1987(01)
9521.199101
9521.1991(02)
XREF
/ /
/ /
08/12/87
10/02/87
08/27/91
08/30/91
/ /
(See TSDFs)
FACILITY MANAGEMENT PLAN
XREF
/ /
FIELD ASSESSMENT AND PUBLIC INVOLVEMENT PLAN FOR THE OCCIDENTAL INCINERATOR
PUBLIC PARTICIPATION PROGRAM REQUIREMENTS FOR FY 19B6
RCRA PROGRAM DIRECTIONS - PRIORITY TO ENVIRONMENTALLY SIGNIFICANT FACILITIES
^ FEDERAL FACILITIES
.£>
000
•RECORDING STATE-REGULATED WASTES ON THE UHWH
CORRECTIVE ACTION AT FEOERAL FACILITIES, NATIONAL PRIORITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES, ISSUES ANO NATIONAL PRIORITIES FOR
CORRECTIVE ACTION/PERMIT ISSUES-U.S. ARMY-ABERDEEN PROVING GROUNDS
DELISTING PETITION OF NITROGEN TETROXIDE RINSATE
HSWA APPLIEO TO FEOERAL FACILITIES (DOE-OAK RIDGE)
MIXED WASTE (DOE FACILITIES), DEFINITION OF
OPERATOR AT DOE OAK RIDGE FACILITY. DETERMINATION OF
OPERATOR AT GOVERNMENT-OWNED CONTRACTOR-OPERATED (GOCC) FACILITIES
ROLE OF AUTHORIZE!) STATES IN DISPUTE RESOLUTION
SIGNATORIES FOR DEPARTMENT OF OEFENSE PERMIT APPLICATIONS
STATE REGULATION OF FEDERAL AGENCIES FOR PURPOSE OF INTERIM AUTHORIZATION
VIOLATION OF EPA HAZARDOUS WASTE MANIFEST REGULATIONS BY FEOERAL FACILITIES
ARMY CHEMICAL/MUNITIONS SYSTEM, REGULATORY STATUS OF
CORRECTIVE ACTION REQUIREMENTS FOR FEDERAL FACILITIES AND IRP ACTIVITIES
DEMILITARIZATION OF MUNITIONS
DEPARTMENT OF ARMY MUNITION DEACTIVATION POPPING FURNACE
DISCARDED WASTEWATER AT A CORROSION CONTROL FACILITY	'
9505.1986(01
9505.1985(01
9501.1987(02
9452.1984(03)
9502.1986(04)
9502.00-2
9502.1986(06)
9502.1986	01)
9502.1986(09
9433.1990 07)
9502.1905(06)
9503.1985(01)
9432.1984 01
9472.1987	01
9541.1987 01)
9522.1985(01)
9542.1980(05)
9452.1984(02)
9527.1985
9502.1986
9441.1987
9488.19871
9444.19911
01)
14)
03}
03)
09/18/86
11/13/85
12/14/87
11/30/84
02/13/86
04/18/86
04/15/86
01/08/86
05/08/86
12/21/90
10/29/85
05/10/85
01/27/84
06/24/87
01/14/87
02/11/85
11/14/80
10/25/84
11/19/85
08/22/86
01/07/87
03/25/87
11/26/91

-------
Page No.
04/08/92
KEYWORD 1N0EX
DOE
OOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WIN THERE IS AN INTENT TO DISPOSE OR DESTROY THEM
ODD POLICY FOR DEMILITARIZATION OF MILITARY MUNITIONS
ODD'S IRP PROGRAM ANO RCRA CORRECTIVE ACTION
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS, HIGH PRIORITY PERMITTING
INSTALLATION RESTORATION PROGRAM (IRP) - OOD
OPEN BURNING/OPEN DETONATION AT DOD FACILITIES
PERMIT APPLICATIONS FOR DESTRUCTION OF NERVE AGENTS
QUALIFICATION OF AN ENGINEER FROM THE CORPS OF ENGINEERS AS INDEPENDENT WITH RESPECT TO AN ARMY FACILITY
REACTIVE WASTE - EXPLOSIVITY
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SURFACE IMPOUNDMENT SAMPLING PLAN FOR HOLLOMAN AIR FORCE BASE
TCLP PARTICLE SUE REDUCTION EXEMPTION FOR MUNITIONS
VOLATILIZATION OF SOLVENTS COUNTED AS SOLVENTS USED
WASTE-AS-FUEL RULES AT 000 FACILITIES, IMPLEMENTATION
BYPRODUCT MATERIAL ANO MIXED WASTE, AEA AND DOE INTERFACE
CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUS
MIXED WASTES AT DOE FACILITIES, REGULATION OF	,
9441.1985(31
9444.1905(18
9502.1966(17
9501.1986 01
9502.1986(20
9502.1986 16
9488.1906(10
9403.1987(20.
9443.1988(10)
9523.00-10
9464.1988(03
9442.199116
9441.1991(08
9494.1986(02
9441.1986(46
9484.1986(02
9503.1985(02
10/31/85
10/03/85
09/29/86
09/11/86
12/08/86
09/22/86
09/11/86
12/15/87
09/13/88
03/14/89
06/20/88
05/01/91
06/10/91
03/19/86
06/02/86
04/02/86
08/30/85
Inventory
FEDERAL FACILITIES INVENTORY UNDER RCRA 3016
Opan Burning/Open Detonation (OB/OD)
•INTERIM STATUS FOR MILITARY FACILITIES OPEN BURNING AREA
DEMILITARIZATION OF MUNITIONS
OOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WEN THERE
FIRE TRAINING PITS, REGULATORY REQUIREMENTS FOR
OPEN BURNING/OPEN DETONATION AT DOD FACILITIES
~ THERMAL TREATMENT UNITS, SCOPE OF SUBPART X
IS AN INTENT TO DISPOSE OR OESTROT THEM
9502.1987(03) 03/06/87
9441.1984(04)
9441.19871
9441.190S(
9489.1987(02)
9502.1986(16)
9489.1988(01)
02/18/84
01/07/87
10/31/85
07/22/87
09/22/86
05/18/88
FERROUS METALS
-1
o
(See Hazardous Waste Identification)
FIFRA
XREF
/ /
(See Agricultural Wastes)
FINAL COVER
XREF
/ /
See also Closure)
10SURE PLAN COMMENTS/ISSUES (CRUCIBLE STEEL)
FINANCIAL RESPONSIBILITY
XREF
9476.1984(05)
09/18/84
(Set also Closure Process, Post-Closure)
'CORRECTIVE ACTION BEYONO FACILITY BOUNDARY - FINANCIAL RESPONSIBILITY REQUIREMENT
'FINANCIAL ASSURANCE
•GENERATOR CLOSURE/FINANCIAL REQUIREMENTS FOR TANK SYSTEMS
•SUBSTITUTION OF STATE FINANCIAL MECHANISM FOR EPA
AUTHORITY TO ENFORCE 264 SUBPART H COMPLIANCE AT FACILITIES LOCATEO ON STATE-OWNED LAND
FACILITY'S OPERATING LIFE, DETERMINATION OF
XREF
9502.1986(10)
9477.1987(I2i
9483.1989(01
9477.1983	04
9477.1984	02
9477.1984(07
/ /
05/30/86
11/30/87
04/30/89
09/30/83
01/30/84
12/03/84

-------
Page No.
M/0i
06/92
KEYWORD INDEX
FINANCIAL ASSURANCE FOR CORRECTIVE ACTION BEYOND FACILITY BOUNDARIES
FINANCIAL ASSURANCE INSTRUMENTS
FINANCIAL ASSURANCE REQUIREMENTS
FINANCIAL RESPONSIBILITY REGULATIONS RELATED TO BANKRUPTCY (LTV)
FINANCIAL RESPONSIBILITY REQUIREMENTS - CERTIFYING CLOSURE
LOSS OF FINANCIAL RESPONSIBILITY COVERAGE ON INTERIM STATUS AND PERMIT ISSUANCE
PARI B FINANCIAL RESPONSIBILITY INFO. REQ. FOR OWNERS/OPERATORS IN STATES WITH ONLY PHASE 1 AUTHORIZATION
REQUIREMENTS OF A FACILITY GENERATING, STORING, AND MANIFESTING F001
RISK RETENTION GROUPS AND FINANCIAL ASSURANCE REQUIREMENTS
Bond Ratings
ACCEPTABLE BOND RATINGS FOR USE IN SUBTITLE C FINANCIAL TEST
CLOSURE COST ESTIMATES
THIRD PARTY LETTERS OF CREDIT - CONVERTIBLE BONDS
Corporate Guarantee
CORPORATE GUARANTEE AS ALTERNATIVE MEANS TO MEET FINANCIAL REQUIREMENTS
Cost Estimates
•FINANCIAL REQUIREMENTS/CLOSURE COSTS
CLOSURE COST ESTIMATES BASED ON THIRD PARTY COSTS
FINANCIAL TEST (UNION CARBIDE, 3/86)
PETROLEUM REFINERY SLUDGE REGULATIONS
Insurance
•LIABILITY INSURANCE FOR ACCIDENTAL AND SUDDEN ACCIDENTAL OCCURRENCES
~LIABILITY REQUIREMENTS
•TERMINATION OF INSURANCE
CAPTIVE INSURANCE COMPANIES TO COMPLY WITH LIABILITY COVERAGE REQUIREMENTS, CREATION OF
~ CERTIFICATIONS OF LIABILITY INSURANCE, HW FACILITY
ENVIRONMENTAL IMPAIRMENT LIABILITY INSURANCE
EXCLUSIONS FOR PRE-EXISTING CONDITIONS IN RCRA TSOF INSURANCE POLICIES, GUIDANCE ON
INSURANCE COVERAGE LIMITS
LIABILITY REGULATIONS
RISK RETENTION GROUPS AND FINANCIAL ASSURANCE REQUIREMENTS
Liability
•FINANCIAL ASSURANCE
•LIABILITY REQUIREMENTS
•LIABILITY REQUIREMENTS OF SUBSIDIARIES
CAPTIVE INSURANCE COMPANIES TO COMPLY WITH LIABILITY COVERAGE REQUIREMENTS, CREATION OF
CORPORATE GUARANTEE FOR LIABILITY COVERAGE
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES
EXCLUSIONS FOR PRE-EXISTING CONDITIONS IN TSOF INSURANCE POLICIES
FACILITIES UNABLE TO MEET LIABILITY COVERAGE REQUIREMENTS
FINANCIAL ASSURANCE FOR LIABILITY THROUGH RISC RETENTION GROUP
FINANCIAL TEST (UNION CARBIDE. 3/86}
GENERATOR LIABILITY FOR DELISTED WASTE RELEASES
HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS, CERCLA MID RCRA LIABILITY OF MUNICIPAL SPONSORS OF
LIABILITY COVERAGE REQUIREMENTS WITH RESPECT TO LOSS OF INTERIM STATUS
LIABILITY REGULATIONS
LIABILITY REQUIREMENTS FOR FACILITIES ACTIVELY SEEKING A RCRA PERMIT
OWNER/OPERATOR UNDER RCRA AND CERCLA, DEFINITION OF
PERMIT ISSUES REGARDING ON-SITE TREATMENT BY FLU1DIZED BED INCINERATION
RECYCLABLE CLOTH WIPERS AND DISPOSABLE INDUSTRIAL WIPERS USED TO CLEAN UP HAZARDOUS WASTES
SMALL QUANTITY GENERATOR (SQG) REQUIREMENTS AND LIABILITIES
SUBPART H FINANCIAL RESPONSIBILITY REQUIREMENTS
9502.19B9
9477.I9B4
9477.1985
9477.1986
9477.1990
9528.1985
9477.1982
9475.1906
9477.00-5
01)
OS)
01)
12
02)
09)
Oil
Ola)
9477.1989101
9477.1983(03
9477.1986(16
9477.1986
9477.1984
9477.1986
9444,19901
9477.1984(08)
9477.1986(03
9477.1983(02
9477.1986(04
9477.1982(03
9477.1984(06
9477.00-6
9477.1984(04)
9477.1986(09)
9477.00-5
9477.1988(04}
9477.1986(03)
9477,1987(05)
9477.1986(04)
9477.1986 13
9451.1986(01)
9477.1988(01)
9477.1987(10)
9477.1987(09)
9477.1986(10)
9433.1985(04
9441.1986(09
9477.1987(03)
9477.1986(09)
9477.1987(01)
9432.1987(12
9522.1985(05)
9441.1986(53)
9451.1991(01)
9477.1983(01)
03/02/89
06/06/84
12/30/84
07/23/86
05/28/90
10/27/85
05/24/82
10/30/86
11/23/87
05/16/89
12/09/83
09/04/86
9477.1986(02) 01/03/86
06/30/86
01/12/84
06/25/86
10/17/90
11/30/84
02/28/86
02/28/83
03/20/86
10/07/82
11/28/84
11/23/87
11/20/84
07/24/86
11/23/87
10/30/88
02/28/86
06/30/87
03/20/86
08/15/86
03/17/86
02/25/88
11/10/87
11/10/87
06/25/86
10/23/85
01/28/86
04/01/87
07/24/86
03/02/87
10/28/87
12/13/85
07/03/86
03/13/91
05/11/83

-------
Page No.
04/06/92
KEYWORD INDEX
\
THIRD-PART* LIABILITY COVERAGE REQUIREMENTS
Liability Coviran
BODILY INJURY/PROPERTY DAMAGE CLAIMS AT TSOFe
RISK RETENTION GROUPS AND FINANCIAL ASSURANCE REQUIREMENTS
FLAMMABLE
(Set Characteristic Hazardous Waste)
FLOOD PLAIN MANAGEMENT
POST-CLOSURE REQUIREMENTS FOR SURFACE IMPOUNDMENTS LOCATED IN A 100 YEAR FLOOD PLAIN
FOOD PROCESSING WASTE
(Sea Hazardous Watte Identification)
FORMALDEHYDE
(See Hazardous Waste Identification)
FOSSIL FUELS
t (See Mining Waste, Exclusions)
FREE LIQUIDS
J
(See Land Disposal Restrictions, Paint Filter Test) (See also SW-846)
FRCON
(See Hazardous Waste Identification)
FUEL
(See Hazardous Waste Fuel, Used oil)
FURNACE
(See Incineration)
OAS CONDENSATE
(See Land Disposal Facilities)
9477.1987(11) 11/10/87
9477.1990(01) 01/25
9477.00-5	11/23
XREF
9464,1984(02) 12/31
XREF
XREF
XREF
XREF
XREF
XREF
XREF
XREF
90
87
04

-------
Page No.
04/06/92
KEYWORD INDEX
GAS PROCESSING WASTES
PHOSPHATE AND 6AS PROCESSING INDUSTRY WASTES
GENERATORS
9441.1983(04) 07/05/83
..J
V)>
(See alao Hazardous Waste Identification, Import, Export}
*BURNING/BlENOING OF UNUSEO COHHERCIAl CHEMICAL PRODUCT (XYLENE) WITH USED OIL
*GENERATOR AT NAVAL VESSEL OPERATIONS
'GENERATOR CLOSURE/FINANCIAL REQUIREMENTS FOR TANK SYSTEMS
~GENERATOR RESP0NSIBIL1TIES:FACILITY OWNER/OPERATOR OR MOBILE RECYCLING UNIT OPERATOR
'HAZARDOUS WASTE EXPORT RULE FOR BATTERY RECLAMATION
•LAB PACKS AT GENERATOR SITES
'TRANSFER FACILITY AS CENTRAL COLLECTION POINT
•TREATABILITY STUDIES ON HAZARDOUS WASTE SAMPLES. PERMIT REQUIREMENTS
ATOM BATTERIES, GENERATOR DEFINITION FOR
CHARACTERISTIC HAZARDOUS WASTES GENERATED AT PRIMARY METAL SMELTING AND REFINING SITES
GENERATOR DETERMINATION-CONTRACTORS AND SUBCONTRACTORS
GENERATOR LIABILITY FOR DELISTED WASTE RELEASES
GENERATOR RESPONSIBILITIES FOR IMPORTATION OF HAZAROOUS WASTE
GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
LIABILITY OF A SERVICING COMPANY AS A GENERATOR OF HAZAROOUS WASTE
MICRO-CLEAR REGULATORY STATUS
MOBILE SOLVENT RECYCLER, GENERATOR DETERMINATION FOR
NOTIFICATION REQUIREMENT WEN SHIPPING RESTRICTED WASTES TO A STORAGE FACILITY
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
~ PERMIT ISSUES REGARDING ONSITE TREATMENT BY FLUIDIZED BED INCINERATION
PERMIT REQUIREMENTS RELATING TO ON-SITE TREATMENT I WASTEWATER TREATMENT UNIT EXEMPTIONS
PORT FACILITIES AS GENERATORS OF OILY WASTE
RAW MATERIAL TRANSPORT VESSEL EXCLUSION FOR ALL WASTES GENERATEO ON SUCH VESSELS
RECYCLING ACTIVITIES
REGULATION AND PERMITTING OF LABORATORIES
REQUIREMENTS FOR CHANGING STATUS OF A TANK FROM TSO TO GENERATOR ACCUMULATION
RESIDUES GENERATEO FROM THE TREATMENT OF HAZARDOUS WASTE, I.D. NUMBERS FOR
RESPONSIBILITY OF GENERATOR IN HAZAROOUS WASTE DETERMINATIONS
SATELLITE ACCUMULATION
SOLAR CELL AND HIGH TECH INDUSTRIES HAZARDOUS WASTE
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS
SPENT CARBON REGULATION
TOTALLY ENCLOSED TREATMENT EXEMPTION AND ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY
TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORS
TREATMENT RESIDUALS OF CHARACTERISTIC HAZAROOUS WASTE AS A LISTED HAZAROOUS WASTE
VOLUNTARY CORRECTIVE ACTION
WASTE AS FUEL RULES AT DOO FACILITIES. IMPLEMENTATION
WASTEWATER TREATMENT UNITS ARE NOT DESIGNATED FACILITIES AND HAY NOT RECEIVE OFF-SITE HAZAROOUS WASTES
Accumulation
•ACCUMULATION TIME FOR EXCESS OF 5S-GALL0N LIMIT IN SATELLITE AREAS
•AODING ABSORBENT TO WASTE CONTAINERS
•GENERATOR ACCUMULATION AND SECONDARY CONTAINMENT
•GENERATOR AT NAVAL VESSEL OPERATIONS
•GENERATOR SATELLITE ACCUMULATION/COUNTING REQUIREMENT
•GENERATOR STANDAROS APPLICABLE TO TRANSPORTERS
•HAZARDOUS WASTE TANKS
XREF
9442.1905(01)
9432.198510?
9483.1989(01
9453.1985(01
9497.1986 01a)
9453.1988(02)
9461.199101
9441.1986(58
9453.1988(03
9443.19061IS
9451.1980(02)
9433.1985(04
9455.1985(01
9451.1986(03
9432.1986(05
9451.1980(01
9444.1990(02
9432.1986(13
9551.1987(20
9441.1986(21
9522.1985(05
9522.1988(04
9451.1986(02
9441.1986	65
9451.1989(01
9441.1988(39
9453.1985(05
9441.1986(05
9451.1984(02
9453.1989(0/
9444.1983(03)
9441.1986(89
9441.198/(3/
9432.1987	10
9453.1991 02
9441.1988(44
9502.1987 11
9494.1986(02
9452.1987(01
9453.1990(03
9453.1990(02
9483.1986(10
9432.1985(02
9453.1989(03
9453.1989(01
9483.1986(07
/ /
12/30/85
05/30/85
04/30/89
12/30/84
05/30/86
01/30/88
11/01/91
06/30/86
02/25/88
07/09/86
11/18/80
10/23/85
06/25/85
04/28/86
02/05/86
12/02/80
03/22/90
08/06/86
10/28/87
03/13/86
12/13/85
11/02/88
03/17/86
09/03/86
05/03/89
08/30/88
12/03/85
01/16/86
09/04/84
07/13/89
07/20/83
12/02/86
05/18/87
08/28/87
09/20/91
10/27/88
12/21/87
03/19/86
02/24/87
10/01/90
07/30/90
11/30/86
05/30/85
08/30/89
04/30/89
10/30/86

-------
Page No.
0470i
06/92
KEYWORD INOEX
C
•INTERIM STATUS PART A APPLICATION WITHDRAW.	9453.1991(01
•RELEASES FROM 90-DAY ACCUMULATION TANKS	9453.1966 05
•SATELLITE ACCUMULATION	9453.1905106
•SQS ACCUMULATION	9453.1966! 02
•WASTEWATER TREATMENT SLUDGE FROM ELECTROPLATING OPERATIONS	9453.1964 02
•WASTEWATER TREATMENT UNIT/GENERATOR ACCUMULATION TANK	9483.1988 IS
ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTS	94S3.1966 01
ACCUMULATION OF HAZARDOUS WASTE IN TANKS (90-DAY)	9453.1962 01
ACCUMULATION OF SECONDARY MATERIAL, ABANOONED VS. DISPOSED OF	9441.19651 25
ATON BATTERIES. GENERATOR DEFINITION FOR	9453.1968 03
EVAPORATOR USEO TO REMOVE WATER FROH HAZARDOUS WASTE	9432.1967103
EXCLUSION FROM RCRA PERMITTING REQUIREMENTS FOR LESS THAN 90-DAY ACCUMULATORS OF DIOXIN CONTAINING WASTES	9453.1965 02
EXEMPTION FOR WASTEWATER DISCHARGES AND GENERATOR ACCUMULATION PROVISIONS	9441.1967 96
EXTENSION TO GENERATOR ACCUMULATION TIME LIMITS FOR UNFORESEEN. TEMPORARY CIRCUMSTANCES	9453.196705
FOUNDRY SANDS RECYCLED AND RETURNED TO THE FOUNDRY	9441.1967113
GENERATOR ACCUMULATION TIME REQUIREMENTS	9453.1969 05
GENERATOR RECYCLING HAZARDOUS WASTE ON-SITE	9453.1967 04
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROH SHIPS. DEFINITION	9432.1966 05
INCINERATOR RESIDUES/RECYCLING DEFINED/ACCUMULATION	9551.1969 06
LIABILITY AND RESPONSIBILITY FOR TRANSPORTATION AND DISPOSAL OF SMALL QUANTITIES OF HAZAROOUS WASTE	9451.1966 07
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER	9441.19661 73
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS	9441.1966 21
ON-SITE TREATMENT BY GENERATORS UNDER 262.34	9453.1967(03
ON-SITE TREATMENT EXEMPTION	9521.1987 03
ON-SITE TREATMENT EXEMPTION. RE INTERPRETATION OF	9453.1967(06
PERMITTING OF TREATMENT ACTIVITIES IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERS	9453.1966 04
RECYCLABLE CLOTH WIPERS AND DISPOSABLE INDUSTRIAL WIPERS USEO TO CLEAN UP HAZARDOUS WASTES	9441.1986 53
RECYCLING OF MOLDING AND CASTING SANDS	9441.1986 01
RELEASES OF HAZARDOUS WASTE. RCRA APPLICABILITY TO	9502.1967 05
SATELLITE ACCUMULATION AREA AND REGULATIONS	9453.1987 01
SATELLITE ACCUMULATION PROVISION, CLARIFICATION	9453.1969 06
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS	9441.1966 69
SPENT SULFURIC ACID ACCUMULATED SPECULATIVELY	9441.1966 19
STILL BOTTOMS GENERATED AND REMOVED FROM A RECYCLING UNIT	9453.1969 04
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM	9432.1967101
TOTALLY ENCLOSED TREATMENT EXEMPTION AND ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY	9432.1987 10
TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWED FOR ALL GENERATORS	SUBJECT TO 262.34 9453.1966107
TREATMENT OF HAZAROOUS WASTE IN GENERATOR'S ACCUMULATION TANKS	9453.1987 02
TREATMENT OF HAZAROOUS WASTE IN A GENERATORS ACCUMULATION TANKS ANO CONTAINERS	9453.1966108
USED OIL FILTERS, REGULATORY DETERMINATION	9442.1990(05
06/01/91
06/30/66
12/30/65
04/30/66
05/30/64
07/30/68
04/16/86
06/31/62
07/01/85
02/25/88
05/01/87
03/12/85
12/10/87
08/12/67
03/04/67
04/21/69
07/14/87
02/05/66
05/03/69
03/24/86
09/25/66
03/13/66
07/01/87
12/15/87
12/15/87
07/25/86
07/03/86
01/06/66
04/02/87
02/22/87
06/02/69
12/02/66
05/26/66
04/16/69
03/17/67
08/28/87
12/05/86
03/25/87
12/22/86
10/30/90
Biennial Reports
aI Reports
•AMENDMENTS TO PART 262 HAZAROOUS WASTE DETERMINATION ANO RECORDKEEPING REQUIREMENTS
BIENNIAL REPORTS
STATE/REGIONAL BIENNIAL REPORTS
WASTE MINIMIZATION ANO INCLUSION OF RECYCLING
WASTE MINIMIZATION ANO INCLUSION OF RECYCLING
9451.1991(02)
9454.1984 01)
9454.1986(05
9452.1966 03
9452.1966 03
03/01/91
03/30/84
06/13/66
02/06/66
02/06/86
OOT
•GENERATOR STANDARDS APPLICABLE TO TRANSPORTERS
BULKING AND CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WITH DIFFERENT HAZARDOUS CODES
CONTAINERS STORING HAZARDOUS WASTE, REQUIREMENTS
DOT'S ROLE IN THE TRANSPORTATION OF HAZAROOUS WASTE
LABELING OF STEEL DRUMS NEED NOT INCLUDE PREVIOUS CONTENTS
LABORATORIES. RCRA REGULATION IMPACT
UNIFORM MANIFEST FORM. USE OF CONTINUATION SHEET
9461.1969(02
9461.1965(01
9482.1986	01
9463.1980 01
9453.1987	07
9441.1990(32
9452.1907(02
04/30/89
09/19/65
01/21/66
06/16/60
11/17/87
11/20/90
04/30/07

-------
Pag
04/1
« No.
06/92
KEYWQRO INDEX
DELISTING PETITIONS FOR K-WASTES MANAGED IN ON-SITE LAND-BASED UNITS-MONITORING REQUIREMENTS
DELISTING, INTERIM STATUS, AND SAMPLING ISSUES AT U.S. NAMEPLATE COMPANY
DRAINAGE WATER BENEATH LAND TREATMENT UNITS AT OIL REFINERIES
ENFORCING GROUNDWATER MONITORING REQUIREMENTS IN RCRA PART B PERMIT APPLICATIONS
F006 WASTES. VMS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION FOR
GC/MC RATHER THAN GC FOR GROUNDWATER MONITORING PURPOSES
GROUND-WATER QUALITY AT CLOSURE
GROUNDWATER CONTAMINATION AS A BASIS TO DENY A DELISTING PETITION
GROUNDWATER MONITORING AT REGULATED UNITS NEAR SWNUl THAT HAVE IMPACTEO GROUND WATER
GWM DATA IN PART B APPLICATIONS
K035 LISTING AND DELISTING ISSUES:GROUNDWATER CONTAMINATION
NEUTRALIZATION SURFACE IMPOUNDMENTS. GROUNDWATER MONITORING FOR CLOSURE OF INTERIM-STATUS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS
RCRA METHODS AND qA ACTIVITIES (NOTES)
SPENT CARBON USED TO REMDVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATER
SULFIDE REACTIVITY CHARACTERISTIC
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 300SII1 OF RCRA TO
TIME OF TRAVEL METHOD FOR THE GUIDANCE CRITERIA FOR IDENTIFYING AREAS OF VULNERABLE HYDROGEOLOGY
VULNERABLE HYDROGEOLOGY GUIOANCE CRITERIA
Alternate Concentration Limit (ACL)
ACLs APPLIED TO SURFACE IMPOUNDMENT RETROFITTING PROVISION 3005(J)(3)
ACLs PROPOSED BY UNION CARBIOE CORP.. INSTITUTE, WV, COMMENTS ON
ACLs UNDER THE RCRA AND CERCLA PROGRAMS. USE OF
ALTERNATE CONCENTRATION LIMIT (ACL) POLICY FOR HSWA PROVISIONS
GROUNDWATER CLEANUP STANOAROS/ACLs IN ORAFT HSWA PERMIT (INTERNATIONAL PAPER COMPANY)
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
*Aqulfer

METAL. K061 WASTES IN SURFACE IMPOUNDMENT-DEL1STING PETITION
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
UPPERMOST AQUIFER IN FILL, IDENTIFICATION OF
Assessment Monitoring
~GROUNDWATER MuNITORING-ASSESSMENT MONITORING/CORRECTIVE ACTION AT CLOSED INTERIM STATUS FACILITIES
GWM DEFICIENCIES IN PART B's. RESPONSE TO AND MECHANISMS TO PREVENT
Compllance Monitoring
'GROUNDWATER HONITOR IN6-C0MPLIANCE PERIOD/POST-CLDSURE CARE PERIOD
PHYSICAL COMLIANCE IN GROUNDWATER MONITORING, DEFINITION
Groundwater Standards
ACLs PROPOSED BY UNION CARBIOE CORP.. INSTITUTE, WV, COMMENTS ON
ACLs UNDER THE RCRA AND CERCLA PROGRAMS. USE OF
ALTERNATE CONCENTRATION LIMIT (ACL) POLICY FOR HSWA PROVISIONS
GROUNDWATER CLEANUP STANOAROS/ACLs IN ORAFT HSWA PERMIT (INTERNATIONAL PAPER COHPANY)
Hvdraqeologlcal Data
ACLs PROPOSED BY UNION CARBIDE CORP.. INSTITUTE, WV. COMMENTS ON
ORAFT SAMPLING AND ANALYSIS PLAN FOR NH PLATING COHPANY
VULNERABILITY GUIOANCE
9433.1987(21)
9433.1987(03)
9486.1988101)
9504.1984 01
9433.1987(09)
9481.1986(08)
9476.1985(02
9433.1987(08)
9481.1907 05)
9523.1984(07)
9433.1987(27)
9484.1986(03)
9476.1985(04)
9445.1985(04)
9444.1986(05)
9443.1985(04)
9523.00-17
9523.00-15
9476.1987(01
9472.1986(06
9481.1987(03
9484.1987(08)
9461.1987(04
9481.1986(06
9481.1987 07
9481.1987(02
9523.00-14
9432.1984(06
9431.1984 01
9433.1987(18
9523.00-14
9481.1986(01)
9481.1988(02)
9504.1984(02)
9481.1988(03)
9481.1985(04)
9481.1987
9481.1986
9461.1987
9481.1987
04)
06
07)
02
9481.1987(04)
9433.1990(06)
9481.1987(01)
09/28/87
02/25/87
01/02/88
08/16/84
06/08/87
09/26/86
08/27/85
04/24/87
06/17/87
09/10/84
12/11/87
04/09/86
09/25/05
06/30/85
03/03/86
07/16/85
09/02/88
03/30/88
06/09/87
07/08/86
06/03/87
07/14/87
06/19/87
08/06/86
07/24/87
03/10/87
03/14/86
11/30/84
09/10/84
08/07/87
03/14/86
05/15/86
04/30/88
11/29/84
04/30/88
10/30/85
06/19/87
08/06/86
07/24/07
03/10/87
06/19/87
11/27/90
02/25/87

-------
I« Mo.
06/92
KEYWORD INDEX
SHAN INCINERATION AND TREATMENT OF K048-K052 WASTES IN CEHENT KILNS AND INDUSTRIAL FURNACES
SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMEO XYLENE
SULFUR RECOVERY FURNACES ARE INDUSTRIAL FURNACES SUBJECT TO THE WASTE-AS-FUEL RULES
USE/REUSE EXCLUSION TO RED WATER (K0471 FROM WHICH SODIUM SULFITE IS RECOVERED AND WHICH IS USED AS A
USED OIL DEFINITION APPLICABILITY TO OPEN-GEAR LUBRICANT
HAZARDOUS WASTE IDENTIFICATION
FUEL
9494.1991(02
9441.1987(24
9432.1986(04
9441.1987(42
9441.1990(33
03/29/91
04/15/87
01/21/86
06/09/87
11/30/90
(Sat also Characteristic Hazardous Waste, Listed Hazardous Waitat)
•BURNING/BLENDING OF UNUSED COMMERCIAL CHEMICAL PRODUCT (XYLENE) WITH USED OIL
•ORIP GAS EXCLUSION
•OYES USEO IN INK FORMULATION (K086)
•F006 SLUDGE FROM ACID WASTE MIXTURE
•FOSSIL FUEL COMBUSTION WASTE EXCLUSION
•HAZARDOUS WASTE FUEL
•HAZARDOUS WASTE FUEL BROKERS
•SOLID AND HAZARDOUS WASTE, DEFINED FOR SPENT SULFURIC ACID
•SPENT SOLVENT LISTING
•SPENT SOLVENT LISTINGS
•TREATABILITY STUDIES SAMPLE EXEMPTION
ANTARCTICA WASTE DISPOSAL PRACTICES
AUTOMOTIVE FLUIDS, REGULATION OF
BYPRODUCT MATERIAL AND MIXED WASTE. AEA ANO DOE INTERFACE
CARBON REGENERATION FACILITIES
CARBON SCRUBBER WASTES IN WHICH PRODUCT MATERIALS ME CAPTURED
CAUSTIC RINSING METAL PARTS
CEMENT KILN DUST WASTE
CHIOROFLUOROCARBON RECYCLING
CHLOROFLUOROCARBONS (CFCsl AS REFRIGERANTS, RECYCLING OF SPENT
CHLOROFLUOROCARBONS iCFCs FROM PRODUCTION OF FOAM PRODUCTS
CLOSURE PERFORMANCE STANDARD
COMMERCIAL CHEMICAL PRODUCT P LISTING APPLIES ONLY TO UNUSED PRODUCT, NOT USED RESIDUES
CONTAINERS USED TO HOLD LISTED CHEHOTHERAPV DRUGS
CORRECTED LISTING DESCRIPTION FOR K062
DELISTING CRITERIA/LEACHATE LEVELS
DELISTING PETITION - FUJI PHOTO FILM WASTEWATER TREATMENT SLUDGE !
DELISTING PETITION, USE OF VHS MODEL
DELISTING TESTING REQUIREMENTS, CYANIDE AND OTHER WASTES, STEEL INDUSTRY
DEMILITARIZATION OF MUNITIONS
DEMONSTRATING EQUIVALENCE OF PART 265 CLEAN CLOSURE WITH PART 264 REQUIREMENTS
DENTAL AMALGAM DISPOSAL
DEPLETED MIXTURES OF ETHYLENE GLYCOL AND WATER FROM HEAT EXCHANGERS
DIMETHYL BENZENE-LISTING CLARIFICATION
DINOSES FORMULATIONS, REGULATORY STATUS
ORY CLEANING ANO MAINTENANCE SERVICES WASTE HOT EXCLUDED AS HOUSEHOLD WASTE
0RYCIEAN1NG INDUSTRY WASTES
ECOSCINT A 1 ECOSCENT D
ELECTRIC UTILITY POLES
ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE F006 LISTING
ELECTROLESS ZINC PLATING WASTE NOT IN F006 LISTING
EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCT
END-USERS OF CHLORDIMEFORM EXEMPTION
ENFORCEMENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENDING DELISTING PETITIONS
ENVIRONMENTAL MEDIA CONTAMNATEO WITH RCRA-LISTID HAZAROOUS WASTE
ETCKANTS USED TD MANUFACTURE COPPER SALTS
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
XREF
9442.1965(01)
9441.1989(05
9441.1990(19
9441.1987 11
9441.1986 16
9494.1986(03
9454.1986(01
9441.1986(17
9441,1909(55
9444.1986(14
9441.1989(56
9442.1989(04
9441.1967 14
9441.1986(46
9441.1986 26
9444.1987(15
9444.1987(33
9441.1988(36
9441.1988(32
9441.1989(40
9441.1990(05
9476,00-13
9444.1986(291
9441.1987(451
9444.1987(31a)
9433.1986(01)
9433.1991(01)
9433.1985 05
9433.1984(06)
9441.1987(03)
9476.00-18
9441.1989(31)
9441.1989(42
9444.1990(03
9441.1990(01
9441.1986(32
9444.1987(07
9443.1988(04
9441.1990(21
9444.1987(031
9444.1987(23
9441.1985(41
9441.1990 04
9433.1987(14
9441.1989(30
9441.1906(82
9441.1986(03
/ /
12/30/85
02/28/89
06/30/90
02/28/87
02/28/86
03/30/86
01/30/86
02/28/86
10/30/89
06/30/86
11/30/89
04/26/89
03/06/87
06/02/86
04/02/86
05/18/87
08/07/87
07/29/88
07/21/88
08/02/89
02/26/90
02/08/88
12/08/86
06/16/87
07/30/87
01/07/86
03/07/91
11/27/85
12/18/84
01/07/87
05/12/88
06/30/89
08/04/89
04/05/90
02/09/90
04/21/86
03/06/87
03/14/88
07/19/90
01/27/87
06/30/87
12/12/85
02/14/90
07/20/87
06/19/89
11/08/86
01/07/86

-------
Pag« No.
04/06/92
KEYWORD INDEX
Manlfast
•LAND DISPOSAL RESTRICTIONS - MANIFEST REQUIREMENTS
*MAINTAINING COPIES OF MANIFESTS AND BIENNIAL REPORTS
•MANIFEST REQUIREMENT FOR TRANSPORTATION OF SPENT SOLVENTS
•MANIFEST REQUIREMENTS FOR SMALL QUANTITY GENERATORS
•MANIFESTING REQUIREMENTS
•PRECIOUS METAL RECYCLING (SILVER). SHALL QUANTITY GENERATOR
•RECORDING STATE-REGULATED WASTES ON THE UHWM
•SQG 100-1000 Kg/MO. GENERATORS, AND THE MANIFEST
•STORAGE PRIOR TO RECYCLING
•WASTE MINIMIZATION CERTIFICATION
ADMINISTRATIVE CONTROLS AND STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
BRASS OROSS SKIMMINGS, SEPARATION OF METALS AND OXIOES. BY-PRODUCT
CONSOLIDATION OF SHIPMENTS ANO MIXING OF HAZARDOUS WASTE BY TRANSPORTERS
DESIGNATED FACILITY UNDER THE TREATABILITY STUOY EXCLUSION
DOT MANIFEST REQUIREMENTS
EXPORT OF HAZARDOUS WASTES UTILIZED FOR PRECIOUS METALS RECLAMATION
GENERATION OF AIDS TO NAVIGATION (ATON BATTERIES)
IDENTIFICATION NUMBERS FOR RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE
LABELING OF STEEL ORUHS NEED NOT INCLUDE PREVIOUS CONTENTS
MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OF
M1XE0 SOLVENT WASTES
MIXING LOW AND HIGH BTU WASTES - SHAM BURNING. BLENDING, MANIFESTING
MIXTURES OF LISTED AND CHARACTERISTIC WASTES
MIXTURES OF WASTES AND LEGITIMATE BURNING FOR ENERGY RECOVERY
MODIFIED MANIFEST WASTE MINIMIZATION CERTIFICATION FOR SHALL QUANTITY GENERATORS
RDID PERMIT FOR A SLUDGE TOYING PROCESS IN A WASTEWATER SYSTEM
RECOVERED LEAO AND LEAD ALLOYS FROM BATTERIES
REQUIREMENTS OF A FACILITY GENERATING. STORING, AND MANIFESTING F001
, SMALL QUANTITY GENERATOR REGULATIONS APPLICABILITY TO LABORATORIES
TRANSFER FACILITY REGULATION INTERPRETATION
UNIFORM HAZARDOUS WASTE MANIFEST COMPLETION INSTRUCTIONS
UNIFORM MANIFEST FORM, USE OF CONTINUATION SHEET
VIOLATION OF EPA HAZARDOUS WASTE MANIFEST REGULATIONS BY FEDERAL FACILITIES
WASTE MINIMIZATION AND INCLUSION OF RECYCLING
WASTE MINIMIZATION CERTIFICATION REQUIREMENTS
Small Quantity Generator
•100-100 Kg/MONTH GENERATORS
•CARBON FILTERS IN DRY CLEANING FOR FILTERING PERCHLOROETHYLENE
•INTERIM STATUS ANO SQG
•INTERIM STATUS FOR RECEIVING SQG WASTE
•LAND DISPOSAL RESTRICTIONS - MANIFEST REQUIREMENTS
•LAND DISPOSAL RESTRICTIONS DEFINITIONS
•MANIFEST REQUIREMENTS FOR SMALL QUANTITY GENERATORS
•PARTS WASHING WITH MINERAL SPIRITS, SMALL QUANTITY GENERATORS
•PRECIOUS METAL RECYCLING (SILVER), SMALL QUANTITY GENERATOR
•SATELLITE ACCUMULATION STANDARDS FOR SQG*
•SMALL QUANTITY DETERMINATION FOR SOLVENT RECLAIMER
•SQG 100-1000 Kg/MONTH GENERATORS. ANO THE MANIFEST
•SQG ACCUMULATION
•SQG QUANTITY DETERMINATION, MULTIPLE COUNTING EXEMPTION
•WASTE DERIVED FROM TREATING EXEMPT OR EXCLUDED WASTES
A10S TO NAVIGATION (ATON) BATTERIES AND «CRA REQUIREMENTS				 r
COUNTING DRY CLEANING INDUSTRY WASTE ONLY AFTER REMOVAL FROM THE PROCESS - SQG RULE
DELISTING REGULATORY STANBAROS FOR FREON 	
DRY TOLUENE AND CARBON TETRACHLORIDE, SAFE DISPOSAL OF
9551.1960(041
9475.1984	01
9541.1985(0?
9452.1985	01
9462.1907(02
9441.1985(20a)
9452.1904(03)
9475.1905	02
9475.1987(01
9475.1985	01
9494.1986	05
9441.1985(21
9461.1963 01
9432.1991(01
9461.1907 05
9455.1991(01
9461.1987(03
9442.1906C 01
9453.1907(07
9494.1986(01
9444.1968 02
9442.1986(05
9441.1987(68
9494.1987	03
9452.1986(02
9503.51-1A
9455.1991(03)
9475.1986 Ola)
9441.1985(341
9461.1990 02
9452.1991(01)
9452.1987(02)
9452.1984 021
9452.1906	03
9452.1986 01
05/30/88
04/30/84
05/30/85
06/30/85
10/30/87
07/30/85
11/30/84
10/30/85
04/30/87
09/30/85
04/11/86
06/06/85
01/30/03
09/27/91
09/30/87
02/05/91
07/30/87
01/16/86
11/17/87
02/09/86
01/22/88
08/31/87
08/19/87
08/31/87
10/20/86
12/24/85
12/10/91
10/30/86
10/30/85
10/30/90
07/26/91
04/30/87
10/25/84
02/06/86
04/28/86
(04
(05
9451.1987 (
9444.19841
9521.1986 05s)
9528.1986 06)
9551.1988(041
9551.1986(23)
9452.1985	01)
9441.1986	45)
9441.1985?28a)
9453.1990 01)
9441.1987(10
9475.1985	02)
9453.1986(02)
9441.1986	64
9441.1987(31
9451.1967(03)
9441.1986(67)
9433.1987(20)
9451.1986(06)
08/30/87
04/30/84
05/30/86
07/30/86
05/30/88
12/30/86
06/30/85
05/30/86
07/30/85
04/30/90
02/26/87
10/30/85
04/30/86
08/30/86
04/30/87
07/30/87
09/08/86
09/03/87
12/15/86

-------
Pays No.
04/06/92
KEYWORD INDEX
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES	9451.1986(01
FREON TF RECOVERY STILL BOTTOMS	9444.19S1 04
GENERATOR 1.0. NUMBERS TO COLLEGES AND UNIVERSITIES, ASSIGNING	9451.1983 02
HOUSEHOLD HAZAROOUS WASTE COLLECTION PROGRAMS, CERCLA AND RCRA LIABILITY OF MUNICIPAL SPONSORS OF	9441.1986 09
HOUSEHOLD WASTE EXCLUSION SCOPE	9574.1991 01
HSWA PROHIBITION ON THE USE OF HAZAROOUS VASTI AS A DUST SUPPRESSANT	9493.00-1A
LABORATORY WASTE EXCLUSION	9441.1985(03
LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS	9443.1987(28
MERCURY ORY CELL BATTERIES AND APPLICABLE REGULATIONS	9443.1986(18
MODIFIED MANIFEST WASTE MINIMIZATION CERTIFICATION FOR SMALL QUANTITY GENERATORS	9452.1986(02
OIL AND GAS EXPLORATION EXCLUSION	9441.1987(04
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS	9441.1986(21
PAINT FILTER WASTE	9444.1982 01
PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATOR	9441,1986(47
PART B PERMIT APPLICATION REQUIREMENTS FOR SQG TREATMENT FACILITIES	9522.1985 06
RAILROAD TIES AS HAZARDOUS WASTES UNDER THE MIXTURE RULE, SMALL QUANTITY GENERATOR	9441.1960 04
RECYCLABLE CLOTH WIPERS AND DISPOSABLE INDUSTRIAL WIPERS USED TO CLEAN UP HAIAROOUS WASTES	9441.1986(53
SCRAP AMALGAM FILLINGS FROM DENTISTS, DISPOSAL OF	9441.1989 22
SCRAP DENTAL AMALGAM	9441.1989(43
SMALL QUANTITIES OF WASTE GENERATED BY LARGE NUMBERS OF GENERATORS	9451.1987(02
SHALL QUANTITY GENERATOR (SQG) REQUIREMENTS AND LIABILITIES	9451.1991 01
SHALL QUANTITY GENERATOR APPLIES TO AGGREGATE AMOUNT OF WASTES GENERATED AT A FACILITY	9441.1980 05
SMALL QUANTITY GENERATOR REGULATIONS APPLICABILITY TO LABORATORIES	9441.1985 34
SMALL QUANTITY GENERATOR WASTE STREAMS - TANK RISK ANALYSIS	9441.1986(25
SP COMPLIANCE WITH TC RULE	9441.1990 26
TC RULE RELATIONSHIP TO USED OIL FILTER DISPOSAL	9451.1991 03
TOTALLY ENCLOSED TREATMENT EXEMPTION ANO ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY	9432.1987(10
TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWED FOR ALL GENERATORS SUBJECT TO 262.34	9453.1986 07
TREATMENT OF HAZAROOUS WASTE IN PIPELINES LEA01NG TO A WASTEWATER TREATMENT PLANT	9441.1986(62
USED AUTOMOBILE ANTIFREEZE DISPOSAL	9442.1991(18
WASTE MINIMIZATION CERTIFICATION REQUIREMENTS	9452.1986(01
03/17/86
06/22/81
09/30/83
01/28/86
05/30/91
05/31/86
07/31/85
11/20/87
09/04/86
10/20/86
01/13/87
03/13/86
08/19/82
06/02/86
12/20/85
11/17/80
07/03/86
05/17/89
08/17/89
02/18/87
03/13/91
11/17/80
10/31/85
03/26/86
09/20/90
04/16/91
08/28/87
12/05/86
08/19/86
12/19/91
04/28/86
Universities
GENERATOR I.D. NUMBERS TO COLLEGES AND UNIVERSITIES. ASSIGNING
9451.1983(02) 09/30/83
3*
GEOLOGICAL REPOSITORIES
(See Subpart X, Land Disposal Facilities)
GROUNDWATER MONITORING
XREF
/ /
(See also Post-closure)	XREF
•APPENDIX VIII GROUNDWATER MONITORING	94J5.198701
'HAZARDOUS WASTE TANKS ANO GROUND-WATER MONITORING	9483.1986 04
•LABORATORY AUDIT INSPECTION	|«J- JHJfg.
ANALYSIS OF APPENOIX IX CHEMICALS, PROPOSED	9481.1986 02
APPENDIX VIII CONSTITUENTS IN GROUNDWATER, REQUIREMENTS FOR ANALYSIS OF	9481,1985 01
CLOSURE AND POST-CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS	9476.1987lo8
CLOSURE PERFORMANCE STANDARD	9476.00-13
COMBINED NRC-EPA SITING GUIDELINES FOR OISPOSAL OF COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE 9480.00-14
CONOCO'S NO-MIGRATION PETITION DENIAL	„	'"3.1990104
CONTAMINATED GROUND WATER ANO VOLATILIS FROM AIR STRIPPING, TREATMENT OF	9441.1986 86
CONTAMINATED GROUNDWATER, REGULATORY STATUS OF	9528.1987 02
CORRECTIVE ACTION TECHNOLOGY, HQ SUPPORT	9502.1986 19
DELISTING PETITION, USE OF VHS MODEL	5433.19851 05
/ /
03/30/87
08/30/86
07/30/87
07/25/86
10/15/85
12/17/87
02/08/88
03/13/89
09/24/90
11/20/86
03/11/87
10/07/86
11/27/85

-------
Page No,
04/06/92
KEYWORD INDEX

Monitoring
'COMPLIANCE TO DETECTION GROUNDWATER MONITORING, CHANGE FROM	9481.1985(06)
•GROUNDWATER MONITORING FOR RADIONUCLIDES	9481.1987(05)
FIBER OPTICS FOR IN-SITU MONITORING	9502.1987(09)
NO-MIGRATION PETITION FOR AMOCO REFINERY	9551.1990 13
NO-MIGRATION PETITION FOR ARCO PRODUCTS, WA	9551.1990(08)
NO-MIGRATION PETITION FOR ATLANTIC REFINING I MARKETING, PA	9551.1991(06$
NO-MIGRATION PETITION FOR KERR-MCGEE REFINING. OK	9551.1991(05)
NO-MIGRATION PETITION FOR KOCH'S REFINING. TX	9551.1991(01)
NO-MIGRATION PETITION FOR KOCH REFINING, TX	9551.1991 12
HO-HICRAT ION PETITION FOR MARATHON PETROLEUM. IL	9551.1990 09)
NO-MIGRATION PETITION FOR SHELL OIL, WA	9551.1990(11)
NO-HIGRATION PETITION FOR SINCLAIR OIL. OK	9551.1990(12)
NO-MIGRATION PETITION FOR STAR ENTERPRISE, DE	9551.1990 10
NO-MIGRATION PETITION FOR SUN REFINING, OK	9551.1991(02)
Student's T Test
ANALYSIS OF RETESTING PROCEDURES PAPER	9481.1991(01
THERMAL TREATMENT UNITS, SCOPE OF SUBPART X	9489.1988(01
Unsaturated Zone Monitoring
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS	9523.00-12
VHS Model
COMBINATION OF SLUDGES FROM ALL IMPOUNDMENTS TO DETERMINE WASTE VOLUME FOR VHS ANALYSIS	9433.1987
DELISTING ISSUES RELATING TO EPA'S MOBILE INCINERATOR	9433.1986
DELISTING PETITION. USE OF VHS MODEL	9433.1985
DELISTING PETITIONS FOR K-WASTES MANAGED IN ON-SITE LAND-BASED UNITS-MONITORING REQUIREMENTS	9433.1987
DELISTING REGULATORY STANDARDS FOR FREON	9433.1907
« DENIAL OF DELISTING PETITION BASED ON EXISTING GROUNDWATER CONTAMINATION	9433.1987
DETECTION LIMIT REQUIREMENTS AND INFORMATION ON APPENDIX VIII COMPOUNDS FOR A DELISTING PETITION	9433.1986
F006 WASTES, VHS AND GROUNDWATER MONITORING OATA TO EVALUATE A DELISTING PETITION FOR	9433.1987
K103/K104 WASTE STREAMS - RELATIONSHIP OF CWA BAT, LAND OISPOSAL RESTRICTIONS, BOAT, AND DELISTING CRITERIA	9433.1987!
RECONSIDERATION OF OELISTING DENIAL BASED ON USE OF VHS, TOTAL CHROMIUM STANDARD, AND HCL	9433.19861
SURFACE IMPOUNDMENT OELISTING PETITIONS. USE OF VHS MODEL	9433.1987
Well Construction
*GROUND-WATER MONITORING: ESTABLISHING BACKGROUND VALUES	9481.1986(04
'GROUNDWATER MONITORING WELL CONSTRUCTION	9481.1985(05
07)
20)
05)
21)
20)
05
19)
09)
06)
08)
25)
12/30/85
06/30/87
09/03/87
11/08/90
10/24/90
04/22/91
02/05/91
01/03/91
12/10/91
11/06/90
11/07/90
11/08/90
11/07/90
01/17/91
10/16/91
05/18/88
03/30/87
04/13/87
12/11/86
11/27/85
09/28/87
09/03/87
03/19/87
12/09/86
06/08/87
04/02/87
03/24/86
10/26/87
07/30/06
10/30/85
GUIDANCE
DEMONSTRATING EQUIVALENCE OF PART 265 - CLEAN CLOSURE WITH PART 264 REQUIREMENTS
HAZARDOUS CONSTITUENTS
9476.00-18
05/12/88
iSee Also Appendix VIII, Appendix IX. Corrective Action. Delisting)
[LISTING PETITION INFORMATION REQUIREMENTS FOR RESIDUE^ FROM INCINERATION OF 2,4,S-T AND S1LVEX PESTICIDES
K035 LISTING ANO OELISTING ISSUES:GROUNDWATER CONTAMINATION
BfLISTING HAZARDOUS VASTE
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS
WASTES CONTAINING F001-F00S CONSTITUENTS
XREF
9433.1987(26
9433.1987(27
9442.1986(08
9433.1986(23
9441.1988(05
/ /
10/28/87
12/11/87
08/21/86
12/30/86
02/22/88

-------
Page No.
04/06/92
KEYWORD INDEX
HAZARDOUS WASTE FUELS
<-./*
< J
Fuel
(Sea also Burning anil Handing, Uied Oil)
ADMINISTRATIVE CONTROLS AND STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
BURNING AND BLENDING OF HAZARDOUS WASTE AND USED OIL FUELS
CEMENT KILN BURNING HAZARDOUS WASTE FUELS OURING INTERIM STATUS
FIRE TRAINING PITS, REGULATORY REQUIREMENTS FOR
FOSSIL FUEL COMBUSTION WASTE EXCLUSION IN 261.4(b)(4). FUEL MIXTURES
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES AND THE RESIDUALS GENERATED (LOUISIANA REG)
K051 SLUDGE RE-USED ON-SITE. EXEMPTION
MIXTURES OF WASTES ANO LEGITIMATE BURNING FOR ENERGY RECOVERY
*HAZARDOUS WASTE FUEL
*HAZARDOUS WASTE FUEL BROKERS
*HAZARDOUS WASTE FUEL IN INCINERATORS
*HAZARDOUS WASTE FUEL MARKETERS
•USE CONSTITUTING OISPOSAL, RESIDUES FROM FIRE TRAINING EXERCISES
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
BOILERS AM) INCINERATORS, DISTINCTION BETWEEN/INTEGRAL DESIGN STANDARD
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PROOUCTS FOR ENERGY RECOVERY
BURNING OF USED OIL IN THE MARINE INDUSTRY AND USED OIL GENERATOR NOTIFICATION REQUIREMENTS
BURNING OFF-SPECIFICATION USED OIL FUEL IN GREENHOUSES
BURNING USEO OIL ANO THE LEAD SPECIFICATION
BURNING USEO OIL IN SPACE HEATERS, INDUSTRIAL FURNACES, ANO BOILERS
BY-PRODUCT CRUOE OIL TANK BOTTOMS
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)
ENFORCEMENT POLICY ON WASTE BURNING FOR ENERGY RECOVERY
t HAZARDOUS WASTE HAS BEEN MIXED WITH USED OIL (tOOQpm total halogens) (REBUTTABLE PRESUMPTION)
INTERIM STATUS QUALIFICATION REQUIREMENTS TO HAZARDOUS WASTE FUEL STORAGE FACILITIES, APPLIED
LUBRICATING OIL ANO JET FUELS USEO TO PRODUCE PETROLEUM PRODUCTS
MARKETING OR BURNING HAZARDOUS WASTE FUEL. NOTIFICATION OF
MIXING HAZAROOUS WASTE WITH USEO OIL (REBUTTABLE PRESUMPTION)
MIXTURES OF LISTED ANO CHARACTERISTIC WASTES
NOTIFICATION BY BURNERS OF USEO OIL WHO FIRST CLAIM THAT USED OIL MEETS SPECIFICATIONS
OFF-SPECIFICATION JET FUEL BURNED AS KEROSENE FUEL
RECYCLED GASOLINE/WATER ANO FUEL OIL/WATER MIXTURES
SPENT SOLVENT RECOVERY. WASTE MANAGEMENT TAX
SULFUR RECOVERY FURNACES ARE INDUSTRIAL FURNACES SUBJECT TO THE WASTE-AS-FUEL RULES
TRANSFER FACILITY REGULATION INTERPRETATION
USEO OIL ANO OIL BEARING HAZARDOUS WASTE-DERIVEO REFINERY PROOUCTS
USED OIL CONTAMINATION THROUGH NORMAL USE OR PURPOSEFUL MIXING WITH HAZAROOUS WASTES-RECYCLING DEFINED
USEO OIL FIRED SPACE HEATERS
USED OIL INTRODUCED INTO REFINERY PROCESS UNDER HAZARDOUS WASTE DERIVED REFINERY FUEL PRODUCTS EXEMPTION
WASTE-AS-FUEL RULES AT 000 FACILITIES, IMPLEMENTATION
WASTE-OERIVEO FUELS AT IRON ANO STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIRED
Waita-Oerlved Fuel
HAZAROOUS WASTE FUEL CADENCE PRODUCT 312, REGULATION OF
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE
WASTE ACID AS WASTEWATER CONDITIONER AND AS INGREDIENT IN FERTILIZER
WASTE-DERIVED FUELS BURNED IN CEMENT KILN, REGULATION OF
Wa>t«-«l-Fua1
•SHAM RECYCLING POLICY APPLIEO TO CERTIFIED BIFs
B1F REGULATIONS EFFECTS ON INDUSTRIAL BOILER
XREF
9494.1986(05
9495.1985(03
9528.1987 10
9489.1987 02
9441.198101
9494.1987(02
9494.1985(02
9494.1987(03
9494.1986(03}
9454.1986	01)
9441.1986(87}
9453.1985 04
9493.1985 04
9441.1987	76
9432.1986(02
9441.1986(95)
9495.1986(09)
9495.1966(0$
9495.1986(28
9495.1986(03)
9441.1986(37)
9441.1987(96)
9494.1986(06)
9495.1986(08)
9528.1986(101
9494.1985	01)
9494.1986(01)
9495.1906 04
9441.1987(68)
9495.1987 01)
9441.1986	19)
9441.1986 22)
9441.1986(41)
9432.1986(04)
9461.1990(02)
9495.1986(02)
9441.1984(30$
9495.1986(21)
9441.1986(11)
9494.1986(02)
9441.1986(08)
9494.1986
9493.1991
9441.19861
9494.1985)
04)
or
80
03
9488.1991(05
9488.1991(03
/ /
04/11/86
12/12/85
09/03/87
07/22/87
01/13/81
04/15/87
07/30/85
08/31/87
03/30/86
01/30/86
11/30/86
11/30/85
11/30/85
09/1S/87
01/03/86
12/23/86
04/21/06
03/0S/86
11/12/86
02/13/86
05/01/86
12/24/87
07/14/86
04/08/86
11/13/86
10/01/85
02/09/86
02/28/86
08/19/87
01/20/87
03/08/86
03/19/86
05/20/86
01/21/86
10/30/90
01/11/86
10/22/84
09/15/86
02/11/86
03/19/86
01/24/86
04/11/86
01/08/91
10/20/86
10/11/85
10/01/91
09/23/91

-------
\
\
KEYWORD INDEX
r/^
EXEMPTION FOR WASTEWATER DISCHARGES AND GENERATOR ACCUMULATION PROVISIONS
F003 10X RULE AND ASSOCIATED REGULATIONS
FOOS LISTING FOR PYRIDINE STILL BOTTOMS
FOOfi AND F019 ELECTROPLATING LISTINGS
FOOS LISTING AND DEFINITION OF CONVERSION COATING
F006 LISTING DOES NOT INCLUDE ZINC PHOSPHATING WASTEWATER TREATMENT SLUDGES
FOOS LISTING FOR PICKLING AND ETCHING WASTES AND DELISTING ISSUES
F009 LISTING AND THE MIXTURE RULE TO ELECTROPLATING RINSEWATERS AND RESINS
F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPHENOLIC COMPOUNDS
F027 LISTING-USED AND UNUSEO FORMULATIONS IN WOOD PRESERVING
FLOATING PLASTIC BALLS USEO TO CONTROL VAPORS FROM TANKS CONTAINING LISTED PRODUCT
GASEOUS EMISSIONS FROM LANDFILLS
GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
GROUNDWATER CONTAMINATED WITH HAZARDOUS WASTE LEACNATE
HOUSEHOLD HAZARDOUS WASTE EXCLUSION GENERATED BY CONTRACTORS
IRON CAKE WASTE GENERATED DURING THE PRODUCTION OF METHYLDOPA
K03S LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATER
LABORATORY WASTES (INCLUDING CARCASSES, BEDOING, CAGES) CONTAINING DIOXIN
LAND DISPOSAL RESTRICTIONS REGULATION OF CYANIDES
LUBRICATING OIL AND JET FUELS USEO TO PRODUCE PETROLEUM PRODUCTS
MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS
MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONS
METAL FINISHING SLUDGES
MIXEO RADIOACTIVE HOSPITAL WASTES AND THE DOMESTIC SEWAGE EXCLUSION
MIXTURE OF CHARACTERISTIC WASTE AND LISTEO WASTE, ASH FROM INCINERATION
MIXTURES OF SOLID WASTE AIM A WASTE LISTED SOLELY BECAUSE IT EXHIBITS A CHARACTERISTIC
MIXTURES OF WASTES AND LEGITIMATE BURNING FOR ENERGY RECOVERY
MOBILE SOLVENT RECYCLER, GENERATOR DETERMINATION FOR
MUNICIPAL WASTE COMBUSTION, DISPOSAL OF RESIDUAL ASH
OIL AND GAS EXPLORATION EXCLUSION
PACKAGES CONTAINING RESIOUAL URETHANE COATING CHEMICALS
PCB DECHLORINATION TREATMENT PROCESS
PERSONAL PROTECTIVE GEAR OISPOSAL
PESTICIDE APPLICATOR WASHING RINSE WATER
PETROLEUM FACILITIES INCLUDED IN THE KOS! LISTING FOR API SEPARATOR SLUDGE
PRECIPITATION WHICH IS CORROSIVE OUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)
RAGS AND SIMILAR MATERIALS ABSORBING VOLATILES AND F-WASTES, HANDLING
RAW MATERIAL TRANSPORT VESSEL EXCLUSION FOR ALL WASTES GENERATED ON SUCH VESSELS
REACTIVE CHARACTERISTICS OF OISCHARGEO L1/S02 BATTERIES
RECLAIMED METHANOL IS A PRODUCT RATHER THAN A WASTE
RECYCLABLE CLOTH WIPERS ANO DISPOSABLE INDUSTRIAL WIPERS USEO TO CLEAN UP HAZARDOUS WASTES
RECYCLED GASOLINE/WATER ANO FUEL OIL/WATER MIXTURES
RECYCLED PRECIOUS METALS. BATTERIES FROM DEFENSE DEPT. SUPPLIES
RECYCLING EXCLUSION OF WASTES
RECYCLING OF MOLDING AND CASTING SANDS
REFRACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY
REINJECTED GROUNDWATER RESULTING FROM CORRECTIVE ACTION TREATMENT
RELISTING HAZAROOUS WASTE
REQUIREMENTS OF A FACILITY GENERATING, STORING, AND MANIFESTING FOOI
RESIDUES GENERATED FROM THE TREATMENT OF HAZAROOUS WASTE, I.O. NUMBERS FOR
RESIDUES REMAINING IN EMPTY CONTAINERS, BURNING OF
RINSE WATERS CONTAINING TCE SOLVENT
SCINTILLATION COCKTAIL. REGULATION OF LIQUID
SCINTILLATION COUNTING COCKTAIL
SCRAP DENTAL AMALGAM
SECONDARY MATERIAL SUBJECTED TO NOTICE REQUIREMENTS UNDER THE US-CANADIAN BILATERAL TREATY
9441.1987(96)
9444.1987(30
9444.1967
9444.1986(09
9444.1987(09
9444.1987(27
9444.1987
9444.1987(31
9444.1987(42
9444.1987
9444.1986
9487.1986(03
9451.1986(03
9432.1986
9441.1986
9441.1990(09
9443.1987(32
9444.1987
9444.1986
9S54.1991
9494.1985(01
9444.1987(40!
9443.1986(18
9444.1988(01
9441.1986(94
9441.1985(32
9441.1985(38
9494.1987
9432.1986
9443.1987
10
(25
05
(83
52
(30
(01
(03
(13
(06
9441.1987(04
(09
I4'
(15
31
50
9443.1987(
9441.1988
9441.1990
9441.1985	42
9444.1987 20
9441.1986
9441.1989
9441.1986 65
9443.1987(05
9441.1985(33
9441.19861
9441.1986(22)
9441.1986(85)
9441.1990(06
9441.1986(01
9444.1988(05
9554.1991(03
9442.1986(08
9475.19B6tOla)
9441.1986(05)
9441.1986(04
9441.1987(59
9443.1987(18
9443.1987(04
9441.1989 43
9441.1989(29i

-------
Page Mo. •>
04/06/92
KEYWORD INDEX
<.P
V
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY
SOIL CONTAMINATED WITH USED AND UNUSED PESTICIDES
SOLVENT LISTING ANO LAND DISPOSAL RESTRICTIONS
SOLVENT LISTINGS, SCOPE OF
SOLVENT/MIXTURE BLENDS
SOLVENTS USEO AS REACTANT ANO SOLVENT WASTES GENERATED SV A PRODUCTION PROCESS
SPENT ANTI-FREEZE COOLANT REGULATORY STATUS
SPENT FLUIDIZED BEO MEDIA AND CHANGES UNDER INTERIM STATUS
SPENT ION EXCHANGE RESINS ANO FILTER AS HAZARDOUS WASTE
SPENT PICKLE LIQUOR, REUSE OF
SPENT PIPELINE FILTER CARTRIDGES
SPENT SULFURIC ACID PICKLE LIQUOR USED TO PRODUCE FERTILIZER
STABILIZED WASTE PICKLE LIQUOR FROM STEEL/IRON INDUSTRY
STATUS OF FACILITY WHERE A TEMPORARY DELISTING EXCLUSION WAS NEVER GRANTEO
STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION
STILL BOTTOMS FROM LISTED SOLVENT RECLAMATION
SUPERNATANT FROM TREATMENT OF SPENT PICKLE LIQUOR (K062)
TEMPORARILY AND INFORMALLY DELISTED WASTES, REGULATORY STATUS
TOLUENE AS A OILUANT OR CARRIER ANO THE SCOPE OF THE FOOS LISTING
TRUCK OR RAIL SHIPMENT OF HAZARDOUS WASTE TO A POTW
USED X-RAY FILM AS A SPENT MATERIAL - SILVER RECLAMATION
VEHICLE FILTERS CONTAMINATED WITH PESTICIDES
WASHWATERS GENERATED FROM WASHING PESTICIDE APPLICATOR TRUCKS
WASTE FROM CHEMICAL ETCHING USING CYANIDE
WASTE FROM ELECTROLESS PLATING PROCESSES NOT COVERED UNDER REINTERPRETED F006 LISTING
WASTE LISTINGS FOOfi AND K062. SCOPE OF
WASTES FROM BRIGHT DIPPING UNDER THE REINTERPRETED FOOfi LISTING
WASTES FROM ENVIRONMENTAL CHEMISTRY LABORATORY
WASTES FROM ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL EXCLUDEO FROM FOOS
~ WASTEWATER TREATMENT SLUDGE EXEMPTION FOR ANODIZING OF ALUMINUM
WASTEWATER TREATMENT SLUDGES CONTAINING METHANOL
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE
Aerosol Cans
AEROSOL CAN PUNCTURING, CRUSHING, OR SHREDDING, NON-EMPTY
AEROSOL CANS, ON-SITE DEPRESSURIZATION OF
AEROSOL CANS, RCRA REGULATON OF
9441.1987(02
9444.190/(12
9444.1987 18
9444.1966 26
9444.1908 06
3444.1986(27
9441.1990 25
9444.1985(20
9444.1907 13
9441.1987(17
9444.1988(03
9493.1985(02
9441.1990116
9433.1986	06
9444.1987(38
9444.1987(05
9444.1987(47
9433.1986(05
9444.1987(36
9441.1986(88
9441.1986(42)
9443.1987
9441.1986(44)
9444.1987(16!
9444.1987(51
9444.1986(32
9444.1987 28
9444.1987 34)
9444.1987(14
9441.1986(29
9441,1989(52
9444.1987(39
9442.1989(07)
9432.1908(04j
9432.1980(01)
01/06/87
04/18/87
05/20/87
11/07/86
03/31/88
12/05/86
08/24/90
12/05/86
05/05/87
03/31/87
02/11/88
11/14/85
06/19/90
03/10/86
09/01/87
02/02/87
10/23/87
02/24/86
08/17/87
11/30/86
05/20/86
08/13/87
05/30/86
05/20/87
12/04/87
12/12/86
07/13/87
08/07/87
05/08/87
04/09/66
10/06/89
09/02/87
09/12/89
09/30/88
12/30/80
Asbestos
ASBESTOS AS A HAZARDOUS WASTE
Ballast Fluid
BALLAST FLUID CLASSIFICATION
9444.1980(05)
9444.1984(07)
11/18/80
05/30/84
latteries
HOUSEHOLD WASTE EXCLUSION SCOPE
LEAD-ACID BATTERY IMPROPER DISPOSAL
PARTICLE SIZE REDUCTION PROCEDURE FOR TCLP SAMPLES OF ORY CELL BATTERIES
RECOVERED LEAD AND LEAD ALLOYS FROM BATTERIES
USEO BATTERIES RETURNED FOR REGENERATION EXEMPTION
9574.1991(01
9497.1986(02
9442.1991 07
9455.19911 03
9497.1991 01
05/30/91
07/11/86
05/29/91
12/10/91
03/04/91
Carbon Ft 1 tars
•CARBON FILTERS IN ORY CLEANING FOR FILTERING PERCHLOROETHYLENE
ACTIVATED CARBON CANISTERS SATURATED WITH SPENT SOLVENTS			
ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED DURING PAINT APPLICATION
CARBON REGENERATION UNITS - REGULATORY STATUS
ELECTROPLATING RINSEWATERS
9444.1984(
9441.1986!
9444.1986
9489.1991
9442.1987
04/30/84
07/15/86
05/02/86
08/02/91
07/28/87

-------
Page Mo.
04/06/92
KEYWORD INDEX

Chemical Deodorants
DEODORANTS FOR PORTABLE TOILETS
FORMALOEHYDE-BASEO TOILET DEODORANTS
Caroreised Gas Cylinders
GASES VENTED FROH COMPRESSED CYLINDERS - TREATING OF FLUORINE AND OTHERS
Contaminated Groundwater
CLASSIFICATION OF LEACHATE CONTAMINATED GROUNDWATER
CLOSURE STANDARDS FOR HAZARDOUS WASTE LAND TREATMENT UNITS
CONTAMINATED ENVIRONMENTAL MEDIA - SOIL ANO GROUND WATER
CONTAMINATED GROUNDWATER. RCRA REGULATORY STATUS
DRAINAGE WATER BENEATH LAND TREATMENT UNITS - NO MIGRATION PETITIONS
NO-MIGRATION PETITION FOR KOCH REFINING, TX
NO-MIGRATION PETITION FOR TEXACO, WA
SHELL OIL FACILITY - TC COMPLIANCE
UNDERGROUND INJECTION WELLS USEO IN HYDROCARBON RECOVERY
Contaminated Soli
•MULTISOURCE LEACHATE (F039I WASTE CODE AS IT APPLIES TO CONTAMINATION FROH SPILLS
•PETROLEUM CONTAMINATED MEDIA AND DEBRIS UNDER THE TC UST TEMPORARY DEFERAL
•SOIL CONTAMINATED WITH CHLORDANE
•SOLVENT HIXTURE RULE APPLIED TO SPILL OF TOLUENE/BENZENE MIXTURE - CERCLA INTERFACE
CONTAINED-IN POLICY
CONTAMINATED ENVIRONMENTAL MEDIA - SOIL AND GROUND WATER
CONTAMINATED SOIL AND DEBRIS TREATED REPLACEMENT UNDER A TREATABILITY VARIANCE
EXCAVATED CONSTRUCTION SOIL CONTAINING QUANTITIES OF VOLATILE ORGANIC COMPOUNDS
INTERIM SOIL CLEAN-UP LEVELS FOR LEAD AT SUPERFUND SITES
* K001. P093, AND U059 CONTAMINATED SOIL TREATMENT STANDARDS
LAND DISPOSAL RESTRICTIONS CLARIFICATIONS
LAND DISPOSAL RESTRICTIONS: SOILS AND DEBRIS FROH RCRA CORRECTIVE ACTION
LEACH TESTING PROCEDURE TO REMOVE LEAO-CONTAMINATED SOILS FROM RESIDENTIAL AREAS
LEACHATE TESTING FOR EVALUATING SOILS CONTAMINATED WITH LEAD
LEAD-BASED PAINT RESIOUES AND CONTAMINATED SOILS
MOBILE TREATMENT (WITS QUALIFIED FOR INTERIM STATUS
SOIL CLEANUPS FOR LEAD - CLEANUP STANDARDS FOR CLEAN CLOSURE
SOIL CONTAMINATED WITH PESTICIOE
SOIL CONTAMINATED WITH TOLUENE
SOILS CONTAHINATED WITH CHLORDANE AND HEPTACHLOR DURING TREATMENT OF BUILDINGS FOR TERMITES
SOILS FROH MISSOURI DIOXIN SITES. WHETHER HAZARDOUS
USE OF PETROLEUM-CONTAMINATED SOILS AS AN INGREDIENT IN ASPHALT BATCHING
Creosote
CREOSOTE TREATEO CROSS-TIES DISPOSAL
K035 LISTING AND DELISTING ISSUES:GROUNDWATER CONTAMINATION
WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOL
WOOD TREATED WITH CREOSOTE, DISPOSAL OF
WOOD TREATMENT CYLINDER CREOSOTE SUMPS
Daffnftlon
•BOAT FOR WASTEWATER
•ELECTROPLATING AND ELECTROLESS PLATING LISTINGS
•F001-F005 WASTEWATER DEFINITION
•OIL AND GAS EXCLUSION APPLICABILITY
ANTI-NEOPLASTIC AGENTS IN HOSPITAL WASTES, DISPOSAL DF
BERYLLIUM WASTE OUST
9444,1984(00
9441.1986
06/06/84
05/01/86
9441.1984(36) 12/17/84
9554.1991(02)
9478.1991{Oil
9443.1989(041
9442.1984 01)
9551.1988(15
9551.1991(12)
9551.1991 08)
9431.1991(02)
9521.1991(02)
9444.1991(06)
9441.1990(31)
9444.1985(01
9443.1985(11)
9441.1991(04
9443.1989(04)
9551.1990(05)
9443.1985(01)
9502.1990 01)
9554.1990 09)
9551.1987(01)
9551.1988(14)
9431.1989101)
9443.1987(24)
9443.1987(28)
9528.1991(02)
9502.1989(02)
9441.1987(21)
9445.1985(01)
9441.1987 15
9441,1984(01)
9493.1991(02)
9441.1990i
9433.19871
9444.19841
9441.19861
9441.19861
20)
27 i
04 >
10'
69
9432.1986(181
9432.1989 01)
9441.1990(18)
9441.1988(42)
9442.1986 02)
9434.1989(01)
01/01/91
05/02/91
05/23/89
12/26/84
01/21/88
12/10/91
05/29/91
05/09/91
08/30/91
11/01/91
10/01/90
02/28/85
11/30/85
03/26/91
05/23/89
10/09/90
02/21/85
05/07/90
08/13/90
01/20/87
12/30/88
06/26/89
11/05/87
11/20/87
02/27/91
05/25/89
04/08/87
04/05/85
03/11/87
01/06/84
06/20/91
07/03/90
12/11/87
04/26/84
02/11/86
09/12/86
12/30/86
08/30/89
06/30/90
09/30/88
01/30/86
03/17/89

-------
Page No.
04/06/92
KEYWORD INDEX
BOILERS USED IN GREENHOUSE OPERATIONS ME INDUSTRIAL BOILERS
SV-PROOUCT VS. SWAP METAL	<
HEAT RECOVERY UNIT AS A BOILER OR AN INCINERATOR
IGH1TABIL1TY CHARACTERISTIC UNDER STANDARO TEMPERATURE AND PRESSURE
I6N1TABILITT OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITION
K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRY
LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENT
MARINE DEBRIS IN WATERS. DISPOSAL OF
OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITY
SHOOTING RANGES. APPLICABILITY OF RCRA TO
SOLID WASTE MANAGEMENT UNIT DEFINEO FOR CORRECTIVE ACTION UNOER 3004(h)
SPENT PICKLE LIQUOR USED/REUSED IS NOT SOLID WASTE
STEW-SPRAYING OF AN EMPTY TANK
STILL BOTTOM WASTE GENERATCO BY A POLYSTYRENE PRODUCTION FACILITY
SUBMARINE REACTOR COMPARTMENTS - LANO DISPOSAL RESTRICTIONS
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
USED OIL AND IDENTIFICATION OF LISTEO HAZARDOUS WASTE
USED OIL DEFINITION TO OPEN-GEM LUBRICANT "GEMITE"
ZINC OXIOE OUST RECLAIMED OR USED AS FERTILIZER
Dlbutylttn 0)fluoride
DIBUTYLT1N 0IFLU0R10E NOT A LISTED RCRA WASTE
Dredged Sediment!
DREDGE SEOIMENTS
LEAKS, SPILLS, AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WATERS, MIXTURE RULE APPLIED TO
9432.1986(031
9441.1990 07)
9433.1985	08
9443.1900 08
9432.1990 01
9444.1987 08
9442.1986(04)
9432.1907 12a)
9441.1989(49)
9441.1988(41
9502.1987	07
9441.1966 61
9441.1990(10
9432.1988	01
9554.1990(07
9432.1986	07
9432.1987(01
9495.1990(01)
9441.1990 27
9441.1987(61
01/09/86
03/30/90
11/20/85
09/09/88
02/16/90
03/16/87
05/06/86
11/04/87
09/28/89
09/06/88
07/24/87
08/18/86
04/10/90
02/11/88
07/30/90
02/11/86
03/17/87
06/13/90
11/30/90
08/12/87
9441.1984(27) 09/20/84
9443.1989(08}
9441.1986(07)
08/11/89
01/23/86
. r.
Electric Arc Furnace
~ COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE
ELECTRIC MC FURNACE OUST AFTER ENCAPSULATION TREATMENT PROCESS
EXCLUSIONS FOR K-WASTES DENIED (LACLEDE STEEL)
MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY
PRIMARY AND SECONDMY PRODUCTION OF STEEL IN ELECTRIC MC FURNACES
RECYCLING OF ELECTRIC MC FURNACE DUST
RECYCLING OF K061 AS AN INGREDIENT IN CEMENT
STAINLESS STEEL PRODUCTION RESIDUES
9441.1986(68)
9444.1986(33)
9441.1989(48)
9441.1986(48
9444.1986(02)
9441.1988(27)
9441.1990(03)
9441.1988(07)
09/11/86
12/29/86
09/12/89
06/10/86
01/27/86
06/15/88
02/13/90
03/10/88
F-Wastes
•F001-F005 WASTEWATER DEFINITION
CADMIUM WASTES FROM MILITARY COATING MATERIALS
CHEMICAL ETCHING PROCESS-HAZMDOUS WASTE IDENTIFICATION
LAND 01SP0SAL BAN - TRACES OF NATURALLY OCCURRING BENZENE AND TOLUENE
USED OIL AND IDENTIFICATION OF LISTED HAZARDOUS WASTE
WASTE TREATMENT FACILITIES ACCEPTING F006 ELECTROPLATING WASTES
ZIRCONtUM PHOSPHATING SLUDGES EXEMPTION
9441.1990(18
9441.1990(11
9441.1990(14
9553.1986(02
9495.1990(01
9554.1988(05
9444.1990(04
06/30/90
04/12/90
06/12/90
04/30/86
06/13/90
08/11/88
05/02/90
Ferrous Metalt
COMMERCIAL CHEMICAL PRODUCTS USED IN AIR BAGS - EFFECT ON RECYCLE OF FERROUS SCRAP FROM AUTOMOBILES
FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)
9441.1985(02)
9441.1988(48)
01/16/85
11/21/88
Food Processing Waste
FOOD PROCESSING WASTE NOT UNDER AGRICULTURAL WASTE EXCLUSION
FOOO PROCESSORS, IMPACT OF HAZARDOUS WASTE REGULATIONS ON
9441.1980(02)
9443.1980(02)
08/19/80
09/16/80
Formaldehyde
BALLAST FLUID CLASSIFICATION
9444.1984(07) 05/30/84

-------
Page No,
04/06/92
KEYWORD INDEX
DEODORANTS FOR PORTABLE TOILETS
DISCARDED COMMERCIAL CHEMICAL PRODUCTS
EMBALMING FLUIOS, USED
FORMALDEHYDE-BASED TOILET DEODORANTS
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING NSVA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS
CHARACTERISTIC OF 1GNITABI11TY
DELISTING REGULATORY STANDARDS FOR FREON
FREON TF RECOVERY STILL BOTTOMS
USED REFRIGERANTS UNDER 40 CFR 261.2
High Tech Wastes
SOLAR CELL AND HIGH TECH INDUSTRIES HAZARDOUS WASTE
Freon
Iron Sponge
OIL AND GAS EXEMPTION IN 3001
SPENT IRON SPONGE REGULATION
OF RCRA:
MENT
IRON SPONGE PROCESS
Manufacturing
*i
:tur1ng Process Units
MANUFACTURING PROCESS UNITS
•PARTS WASHING WITH MINERAL SPIRITS, SMALL QUANTITY GENERATORS
DECANNING AND CRUSHING OPERATIONS
WASTES GENERATED IN MANUFACTURING PROCESS UNIT NOT SUBJECT TO LAND DISPOSAL RESTRICTIONS UNTIL REMOVEO
Mercur
Allowable holding tines when testing rcra samples
FLUORESCENT AND MERCURY VAPOR LAMPS AND CLASSIFICATION USING THE EP TOXICITY TEST
MERCURY SUITABLE FOR DIRECT USE (99X PURE) NOT SOLID WASTE
MERCURY THERMOMETERS, RECLAIMED OFF-SPEC AND BROKEN
MERCURY. REFINING/REUSE OF SCRAP
NATIONAL CAPACITY VARIANCE FOR INORGANIC SOLIDS DEBRIS
SCRAP AMALGAM FILLINGS FROM DENTISTS. DISPOSAL OF
WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS - MERCURY

Metals
CERTIFICATION/NOTIFICATION FOR MULTIPLE-CONSTITUENT WASTES SUBJECT TO LDRs
COPPER PLATING SOLUTION
ELECTROPLATING WASTES
FLUE DUST AND METAL HYOROXIDE SLUDGE RECYCLING/RECLAMATION
METAL. K061 WASTES IN SURFACE IMPOUNDMENT-DELISTINQ PETITION
WOOD ^RESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
Munitions
•UNDETONATED EXPOSIVES, DISPOSAL OF OFF-SPECIFICATION
DOD POLICY FOR OEMILITIZATION OF MILITARY MUNITIONS
MUNITIONS REGULATED AS HAZARDOUS WASTES
TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONS
OHy Waste
•EP TOXICITY FOR OILY WASTES
•EP TOXICITY TEST ON OILY WASTES
•USED OIL FOR DUST SUPPRESSION/ROAD TREATMENT
BY-PRODUCT CRUDE OIL TANK BOTTOMS
DISPOSAL OF RAGS TO WIPE CRUDE OIL
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEDURE FOR OILY WASTE
9444.1904
9444.198S
9444.1985
9441.1986
9433.19B6
08)
OS i
07
38
23
9443.1987(07
9433.1987
9444.1981
9441.1990
9441.1983(03)
9443.1986(02)
9441.1987(71
9441.1966 45
9432.1984(03
9441.1987(53
9445.1987
9443.1986
9441.1986
9441.1986
9441.1986
9551.1990
9441.1989
9441.1988
04)
09)
43)
27)
06)
07)
221
45)
9551.1991(10
9443.1986(04
9441.1991(06
9441.1909 10
9433.1987(18
9441.1986(28
9441.1984(28
9444.1905(18
9441.1990(23
9442,1991(16
9443.1985
9443.19841
9441.19901
9441.1986<
9441.1989!
9441.1986!
9443.19871
06/06/84
05/14/01
05/17/85
05/01/06
12/30/86
04/16/87
09/03/87
06/22/81
10/18/90
9444.1903(03) 07/20/03
05/25/83
01/17/86
08/30/87
05/30/86
04/26/04
06/29/87
12/04/87
04/30/06
05/30/86
04/02/86
01/21/86
10/14/90
05/17/89
11/02/68
06/05/91
01/22/86
05/29/91
03/27/09
08/07/87
04/07/06
00/31/04
10/03/85
08/21/90
05/01/91
09/30/85
07/30/84
03/30/90
05/01/86
05/31/89
01/07/86
08/11/87

-------
Pago No.
04706/92
'•	KEYWORD INDEX
OILY WASTEWATER TREATMENT PONDS. PERMITTING COVERAGE OF
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS
SQG COMPLIANCE WITH TC RULE
TCLP EXTRACTIONS AS THEY APPLY TO OIL* WASTE
USED OIL FILTERS CLASSIFICATION
Paint Waste
LEAD PAINT REMOVAL DEBRIS AND THE TCLP PROCEDURE
LEADED PAINT SANDBLASTING WASTE TESTING USING TCLP
PAINT FILTER WASTE
PAINT FILTERS. USEO
PAINT RESIDUES ON CONVEYOR HOOKS
PAINT SPRAY BOOTH AIR FILTERS
PAINT WASTES AND SPENT SOLVENT LISTINGS
PAINT WASTES AS HAZAROOUS WASTES. RECYCLED/REUSED PAINT WASTES
PAINTING CONTRACTOR WASTES-SHALL QUANTITY GENERATOR
PAINTS CONTAINING SOLVENTS
PROCESS WASTES CONTAINING INKS. PAINTS, AND ADHESIVES
TCLP AND LEAD PAINT REMOVAL OEBRIS
WASTES FROM ELECTROSTATIC WATERFALL CURTAIN PAINTING OPERATIONS
Phosphate Wastes
PHOSPHATE AND GAS PROCESSING INDUSTRY WASTES
Process Wastes
*MANUFACTURING PROCESS UNIT
~NOTIFICATION REQUIREMENTS FOR RECYCLABLE MATERIALS
•POINT V GENERATION - LAND DISPOSAL RESTRICTIONS
~ *S0LI0 WASTE VARIANCE FOR SPENT SOLVENT
•SPENT SOLVENT LISTINGS
•WASTES GENERATED IN PROCESS UNITS
ACID PLANT BLOWOOWN SLURRY/SLUDGE FROM PRIMARY COPPER PRODUCTION
ASBESTOS AS A HAZARDOUS WASTE
v.P	CARBON REGENERATION FACILITY. MIXTURE OF SOLIO AND HAZAROOUS WASTES (CALGON)
<>"	CHLORIDE-ILMENITE PROCESS WASTES
CHROMIUM WASTES, EXCLUSION FOR CERTAIN
CHROMIUM WASTES: TRIVALENT AND HEXAVALENT, CHROMIUM IN TANNERY WASTES
COLORED GLAZE SOLIDS COLLECTED IN POTTERY MANUFACTURING OPERATIONS
DEI0N1ZATION ACIO REUSED. NOT A WASTE
F019 LISTING AND THE CONVERSION COATING PROCESS
FILTER CAKE WASTE CONTAINING SOLVENT USEO TO SOLUBULIZE PRODUCT
FILTER PRESS PROPOSED AS PART OF CORRECTIVE ACTION - NOT EXCLUDED FROM PERMITTING
INK FORMULATION WASTES AS BOTH K086 AND F001-005 WASTES
LIME STABILIZED WASTE PICKLE LIQUOR SLUDGE EXCLUSION
METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS
PRE-COAT WASTE CONTAINING 2-ETHOXYETHANOL (EXTRUDING PROCESS WASTE)
PROCESS WASTES CONTAINING INKS. PAINTS, AND ADHESIVES
PROCESS WASTEWATER FROM METAL OEGREASING OPERATIONS
REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENT
RECLAMATION OF SPENT ALKALINE ETCHANT-REQUEST FOR VARIANCE UNDER MOO. CLOSEO-LOOP PROVISION
REJECT SUBSTRATES CONTAINING VENAOIUH PENTOXIDE
RiSIOUE FROM STREAM-STRIPPING OF PROCESS WASTE CONTAINING TOLUENE
SOLVENT LISTINGS FOR PAINT WASTES/REMOVER AND SPILL RESIDUE
SOLVENT-CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTURE
SOLVENTS USED AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCT
SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY
9502.1984(01;
9493.1991(01
9433.1986 23
9441.1990 26
9442.1991(08
9441.1990(22
9442.1991(12
9442.1991(01
9444.1962 01
9444.1988(13
9443.1900(03
9442.1990(01
9444.1987(17
9441.1981(03
9441.1986(47
9444.1988(11
9441.1987(09
9442.1991(10
9444.1987(04
9441.1969(54
9441.1986(13
9554.1990(12
9433.1985(03
9444.1988(09
9441.1986(96
9441.1989(32
9444,1900(05
9441.1986(33
9441.1991(05
9441.1988(03
9441.1966(24
9441.1988(17
9441.1986(39
9444.1987(22
9444.1987(43
9433.1987(10
9444.1987(41
9441.1987(74
9441.1987(46
9444.1966 15
9441.1987 09
9553.1988(02
9444.1987 49
9433.1985(06
9444.1906(17
9441.1984(10
9444.1987(11
9442.1987(06
9441.1986(92)
9441.1989(34)
12/07/84
01/08/91
12/30/86
09/20/90
06/13/91
08/17/90
08/30/91
01/08/91
00/19/82
07/28/88
12/20/80
05/03/90
05/20/87
04/06/81
06/02/86
05/05/88
02/19/87
07/03/91
01/28/87
9443.1983(04) 07/05/83
10/30/89
04/30/88
08/30/90
09/30/85
04/30/88
12/30/86
07/06/89
11/18/80
04/23/86
04/22/91
01/13/88
03/21/86
05/18/88
05/12/86
06/24/87
10/09/87
06/12/87
09/15/87
09/02/87
06/17/87
08/04/86
12/19/87
03/08/88
10/26/87
10/29/8S
09/04/06
05/15/84
04/14/87
10/26/87
12/05/86
07/06/89

-------
Pago No.
04/08/92
KEYWORD INDEX
STILL BOTTOM VAST! GENERATED OURING THE PRODUCTION OF POLYSTYRENE
SUPERNATANT FORMED IN LINE STABILIZATION OF WASTE PICKLE LIQUOR AS HAZARDOUS WASTE
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
TOTALLY ENCLOSED TREATMENT EXEMPTION AND ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
WASTES GENERATED FROM EXTRACTION PROCESS
WASTES GENERATEO IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER
WASTEWATER TREATMENT SLUDGES RESULTING FROM METAL CLEANING PROCESS
WATER WALL SPRAY BOOTH WASTES AND THE SOLVENT LISTINGS
Regulated Wastes
•SPENT SOLVENT LISTINGS
DREOGE SEDIMENTS
HAZARDOUS WASTES THAT ARE RECYCLED, HANDLING
SEDIMENT SAMPLE DISPOSAL FROM BIOASSAY TESTING
STORAGE FACILITIES, RCRA APPLICABILITY TO
Smltlna Wast*
'MINING WASTE EXCLUSION REINTERPRETATION
CHARACTERISTIC HAZARDOUS WASTES GENERATED AT PRIMARY METAL SMELTING ANO REFINING SITES
DROSS FROM ALUMINUM SMELTING USED IN MANUFACTURE OF CEMENT
RESIDUES FROM SECONOARY LEAD SMELTERS THAT RECYCLE K069 WASTES
SECONDARY LEAD SMELTER VARIANCES
9441.1988(40
9441.1987
9432.1987
9432.1987
9432.19861
9442.1986
9441.1986
9444.1989
9444.1987
183
01
15
07
52
08
06
9444.1986(14)
9443.1989(081
9441.1986(76)
9441.1989(12
9432.1983(02)
9441.1985(35
9443.1986(16
9441.1989(01
9496.1991(01
9444.1988(14
09/01/88
10/23/87
03/17/87
08/28/87
12/22/86
07/02/86
07/02/86
08/21/89
02/28/87
06/30/86
08/11/89
10/08/86
03/31/89
11/29/83
10/30/85
07/09/86
02/07/89
08/05/91
08/26/88
Soil
DESTRUCTION OF OIOXIN CONTAMINATED SOIL USING MOBILE INCINERATION
FIRE TRAINING PITS, REGULATORY REQUIREMENTS FOR
LEAD-BASEO PAINT RESIDUES AND CONTAMINATED SOILS
LEAKS, SPILLS. ANO ILLEGAL DISCHARGES OF LISTEO WASTES TO SURFACE WATERS, MIXTURE RULE APPLIED TO
SOIL CONTAMINATED WITH CHLOROANE AS A RESULT OF PESTICIDE APPLICATION
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 3005(1) OF RCRA TO
9433.1986(10
9489.1907(02
9443.1987(28
9441.1986(07)
9444.1986(20
9476.1987(01
04/24/86
07/22/87
11/20/87
01/23/86
09/29/86
06/09/87
TCLP
< A
—1
TNT
ADOPTION OF TCLP FOR DELISTING DEMONSTRATIONS
•PRODUCT WASHWATERS FROM DINITROTOLUENE - Kill LISTING
TNT RED WATER, REUSE OF
Toxlclt*
FEDERAL POLICY REGARDING OIOXIN DISPOSAL
L050 AS CRITERIA FOR LISTING HAZARDOUS WASTE
LEACHING TESTING FOR EVALUATING SOILS CONTAMINATED WITH LEAO
PENTACHLOROPHENOL AS A WOOD PRESERVATIVE
RCRA TESTING TECHNIQUES
REGULATION OF MUNICIPAL WASTE COMBUSTION ASH
RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES
SPENT PICKLE LIQUOR DELISTING PETITION
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
TOXICITY OF 2.4.D WASTE
9433.1990(03) 06/14/90
9441.1988(20]
9441.1981(04)
9444.1987(26)
9443.1988 09)
9443.1987(24)
9444.1988(15)
9441.1987 81
9573.199101)
9487.1986(08)
9433.1991(02)
9523.00-14
9444.1984(03)
05/30/88
04/10/81
07/02/87
09/09/88
11/05/87
00/25/88
10/20/87
05/01/91
05/27/86
04/26/91
03/14/86
04/30/84
HAZARDOUS WASTE IMPORTATION
(See Import)
XREF

-------
Page Ho.
04/06/92
KEYWORD INDEX
HEALTH AND SAFETY
OSHA HAZARDOUS WASH SITE ACTIVITY
SELECTION OF NON-USEPA APPROVED METHODS FOR SUBPART X PERMITS
9504.1987(02)
9442.1990(03)
HEALTH ASSESSMENTS
06/05/87
11/19/90
(Set Risk Assessment)
HIGH TECH WASTES
XREF
/ /
(See Hazardous Waste Identification)
HOUSEHOLD HAZARDOUS WASTE
XREF
/ /

(See also Subtitle D)
¦HOUSEHOLD HAZARDOUS WASTE
*HEDICAL WASTE - HOUSEHOLD KE01CAL WASTE
DRY CLEANING AND MAINTENANCE SERVICES WASTE NOT EXCLUDED AS HOUSEHOLD WASTE
HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS, CERCLA AND RCRA LIABILITY OF MUNICIPAL SPONSORS OF
HOUSEHOLD WASTES - DISPOSAL OF CARBON-ZINC BATTERIES
LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS
MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONS
PROPER OISPOSAL OF OLD MEDICATIONS
RESIOUES FROM U.S. NAVY SALVAGE FUEL BOILER
* USED AUTOMOBILE ANTI-FREEZE OISPOSAL
USED CRANKCASE OIL DISPOSED OF BY DO-IT-YOURSELFERS
Collection Programs
HOUSEHOLD HAZAROOUS WASTE - COLLECTION PROGRAMS, CLARIFICATION OF ISSUES
HOUSEHOLD WASTE EXCLUSION SCOPE
XREF
9441.1908
9441.19891
9441.1986(32
9441.1986	09
9441.1984
9443.1987
9443.1986
9574.1990
9441.1987
9442.1991
9441.1987
30)
24
HOUSEHOLD WASTES
(Sea Solid Waste)
9574.00-01
9574.1991(01)
XREF
/ /
06/30/88
08/16/89
04/21/86
01/28/86
04/19/84
11/20/87
09/04/86
11/28/90
03/17/B7
12/19/91
08/13/87
11/01/88
05/30/91
I /
HSWA
(See Hazardous and Solid Waste Amendments)
HSWA (HAZAROOUS AND SOL 10 WASTE AMENDMENTS)
XREF
/ f
(See also Corrective Action, Delisting, Joint Permits, Land Disposal Restrictions, Leachate Collection)
'ENFORCEMENT USING 3001(h) AUTHORITY AND 3013 ORDERS
•EXISTING PORTION. DCFINITION AND HSWA IMPACT
EXISTING UNITS UNDER HSVA-APPLICABIL1TY OF HTR TO EXPANSIONS
GROUND-WATER QUALITY AT CLOSURE
HSWA EFFECT ON STATE DELISTING DECISIONS
XREF
9502.1906(18)
9432.1985(05)
9522.1985 03}
9476.1988(01)
9432.1905 04
9176,1985 02
9433.1965(02)
/ /
09/30/86
08/08/85
07/05/85
01/29/88
08/30/85
W/27/B5
05/16/85

-------
Pag* No.
04/06/92
KEYWORD INDEX
HSWA MINIMUM TECH REQUIREMENTS FOR LINERS AND LEACHATE COLLECTION SYSTEMS
IMMEDIATE PERMIT REQUIREMENTS
INTERPRETATION OF 3005(11(1)
NONHAZARDOUS LIQUID WASTEWATERS AND SLUDGES IN SANITARY LF UNDER RCRA ft HSWA, DISPOSAL OF
PARTIAL PERMITTING OF INCINERATOR UNIT (DOW)
RCRA PERMITS WITH HSWA CONDITIONS - JOINTLY ISSUED PERMITS
STAYING HSWA PERMIT CONDITIONS
TREATMENT SURFACE IMPOUNDMENTS, REGULATORY OPTIONS AVAILABLE TO WOOD PRESERVERS
WAST! MINIMIZATION: PERMIT CERTIFICATION AND JOINT PERMITTING
WASTES NEWLY REGULATED UNDER HSWA. MANAGEMENT OF
HSWA Provisions
AUTHORIZATION OF STATE PROGRAMS TO IMPLEMENT LAND DISPOSAL RESTRICTIONS PROGRAMS
EFFECT OF LAND OISPOSAL RESTRICTIONS ON PERMITS
HSWA AUTHORIZATION ISSUES - JOINT PERMITTING
INDUSTRIAL FURNACES BURNING HAZAROOUS WASTES AND THE RESIDUALS GENERATED (LOUISIANA REG)
TEMPORARY AND INFORMAL DELISTINGS AND HSWA EFFECTS ON BOTH
HYDROGEOLOGICAL DATA
9480.198S(
9501.1984
9484.19851
9574.19851
9522.19851
9502.19871
9521.19891
9484.1987
9560.1985
9541.1985
9541.1986(13
9551.1986(15
9541.1905(09)
9494.1987(02.
9433.1986(14)
04/01/85
11/09/84
07/25/85
01/22/85
08/30/85
06/30/87
04/19/88
11/25/87
09/11/85
05/06/85
06/24/86
09/15/86
07/01/85
04/15/87
05/27/86
(See GrounAater Monitoring)
IDENTIFICATION
XREF
/ /
r/>
(See EPA I.D. Numfatr)
IDENTIFICATION NUMBERS
~
(Sen EPA I.D. Number)
IGNITAB1L1TY
IMPORT
(See Characteristic Hazardous Waste)
{See also Generator, Transporter)
ANA01AN MANIFEST FOR SHIPMENTS ENTERING THE U.S.
GENERATOR RESPONSIBILITIES FOR IMPORTATION OF HAZARDOUS WASTE
XREF
XREF
XREF
XREF
9462.1985(01
9455.1985(01
/ /
/ /
/ /
/ /
11/25/85
06/25/05
INCINERATION
(Stt also Subpart X under Thermal Treatment)	XREF	/ /
'RECIRCULATING TANK, REGULATION OF	9483.1984(03)	11/30/84
•WASTE DERIVED FROM TREATING EXEMPT OR EXCLUOEO WASTES	9441.1987(31)	04/30/87
ACCEPTABLE LEVELS OF RESIDUAL CONTAMINANTS IN THE EPA INCINERATOR RESIDUES (REVISION)	9488.1985(03)	04/01/85
DELISTING PETITION INFORMATION REQUIREMENTS FOR RESIDUES FROM INCINERATION OF 2,4.5-T ANO SILVIX PESTICIDES	9433.1987(26)	10/28/87
OOD MUNITIONS BECOME SOLIO WASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO OISPOSE OR OESTROY THEN	9441.1985 31)	10/31/85
ENFORCEMENT POLICY ON WASTE BURNING FOR ENERGY RECOVERY	9494.1986(06)	07/14/86
INCINERATOR PERMITS TO BURN D10XIN WASTES, MODIFICATION OF	9488.1985(04)	05/30/85
INCINERATORS THAT RECEIVE GASEOUS EMISSIONS, RCRA EXCLUSION, CAA APPLIES	9441.1984 15	07/31/84

-------
Page
04/01
No.
06/92	y
KEYWORD INDEX
JURISDICTION AND REGULATION OF MIXED WASTE MANAGEMENT INCLUDING INCINERATION AND LOCATION CRITERIA
METALS PRODUCTION WASTES. MINING WASTE EXCLUSION-COMBUSTION OF WASTES AS INCINERATION
MIXTURE OF CHARACTERISTIC WASTE AND LISTED WASTE, ASH FROM INCINERATION
MUNICIPAL WASTE COMBUSTION ASH
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL AND HAZARDOUS
REFACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY
RESIDUES REMAINING IN EMPTY CONTAINERS. BURNING OF
SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCPJ FROM GROUNDWATER
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
THERMAL RELIEF VENTS ON HAZARDOUS WASTE INCINERATORS, ACCEPTABILITY OF
BIF Rule
*SHAM RECYCLING POLICY APPLIED TO CERTIFIED BIF*
BIF REGULATIONS EFFECTS ON INDUSTRIAL BOILER
BIF RULE APPLIED TO NEWLY REGULATED UNITS AT INTERIM STATUS FACILITIES
CARBON REGENERATION UNITS - REGULATORY STATUS
HAZARDOUS WASTEWATERS USEO AS QUENCHWATER IN CEMENT PRODUCTION
INTERIM STATUS UNDER THE BIF RULE
K-WASTE FILTER CAKE IN THE MANUFACTURE OF CEMENT
REGION V FUEL-BLENDING FACILITIES CONCERNS
RESIDUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES
Bagbouse Dust
'BAGHOUSE DUST GENERATED FROM REMELT1NG PRIMARY PRODUCEO STEEL
BAGKOUSE OUSTS USEO AS. OR TO PRODUCE, AGGREGATE
EXCLUSIONS FOR K-WASTES DENIED (LACLEDE STEEL)
LAND DISPOSAL RESTRICTIONS CLARIFICATIONS
RECYCLING OF ZINC OXIDE BAGHOUSE OUST
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
*Bo<1er
~HAZAROOUS WASTE FUEL
BOILER VARIANCE FOR A WASTE HEAT RECOVERY BOILER NOT OF INTEGRAL DESIGN, DENIM. OF
BOILERS AND INCINERATORS, DISTINCTION BETWEEN/INTEGRAL DESIGN STANOARO
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY
-------
Page No.
04/06/92
KEYWORD INOEX
METALS RECOVERY
Destruction Removal Efficiency (ORE)
VIABILITY OF TRIAL BURN RESULTS WITH INCOMPLETE VOST DATA
Electric Arc Furnace
EMISSION CONTROL OUST/SLUDGE FROM ELECTRIC ARC FURNACE AT FOUNDRY NOT A K0S1 WASTE
EXCLUSIONS FOR K-WASTES DENIED (LACLEDE STEEL)
PRIMARY AND SECONDARY PRODUCTION OF STEEL IN ELECTRIC ARC FURNACES
RECYCLING OF ELECTRIC ARC FURNACE DUST
RECYCLING OF K061 AS AN INGREDIENT IN CEMENT
STAINLESS STEEL PRODUCTION RESIDUES
Furnace
BURNING USED OIL GENERATEO BY PRIVATE BOAT OWNERS ON-SITE
DEPARTMENT OF ARMY MUNITION DEACTIVATION POPPING FURNACE
POPPING FURNACES-DOO DISPOSAL OF OUTDATED ORDNANCE BY INCINERATION
RECOVERY KILN AS AN INDUSTRIAL FURNACE
Hazardous Waste Fuels
USED OIL FUELS BURNED IN INCINERATORS
Incinerator Residue
INCINERATOR RESIDUES FROM TRIAL BURN
REGULATION OF MUNICIPAL WASTE COMBUSTION ASH
SCRUBBER BRINE/SLUDGE PROOUCED IN INCINERATION OF A LISTED HAZAROOUS WASTE
WASTE GENERATEO BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TR1CHL0R08ENZENE AND HEXACHLOROETHANE
Incinerators
•CHANGES TO INTERIM STATUS FACILITIES
~FUME INCINERATORS
* 'HAZARDOUS WASTE FUEL IN INCINERATORS
BOILER VARIANCE FOR A WASTE HEAT RECOVERY BOILER NOT OF INTEGRAL DESIGN, DENIAL OF
BOILERS AND INCINERATORS, DISTINCTION BETWEEN/INTEGRAL DESIGN STANDARD
CHEMICAL AGENT/MUNITIONS SYSTEM (CADMS) IS NOT TOTALLY ENCLOSED AND SUGGESTED RDM PERMIT
_£>	CHLORINE EMISSIONS FROM HAZARDOUS WASTE INCINERATORS
Z,	CLEAN CLOSURE AND DISPOSAL OF AN INCINERATOR
CLOSURE PLAN FOR THE HAZARDOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT
CONSTRUCTION OF A NEW INCINERATOR WITH THE CHANGES DURING INTERIM STATUS
CONTROL DEVICES REQUIRED BY THE ORGANIC AIR EMISSION STANOARD
DEACTIVATION (POPPING) FURNACES AS INCINERATORS
DELISTING PETITION FOR INCINERATOR ASH
DESTRUCTION OF OIOXIN CONTAMINATED SOIL USING MOBILE INCINERATION
OIOXIN TRIAL BURNS FOR PURPOSES DF CERTIFICATION OR A RCRA PERMIT
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE
HEAT RECOVERY UNIT AS A BOILER OR AN INCINERATOR
INCINERATOR METALS EMISSIONS CONTROLS
INCINERATOR NOT CONSIDERED TOTALLY ENCLOSED TREATMENT
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS, HIGH PRIORITY PERMITTING
INTEGRAL OESIGN STANDARD IN BOILER DEFINITION (LUBRIZOL)
INTERIM STATUS EXPANSION TO ADO AN INCINERATOR
INTERIM STATUS EXPANSION TO ADD AN INCINERATOR
LOR RULES REGARDING ALTERNATIVE TREATMENT STANDARDS FOR LAB PACKS
MUNICIPAL WASTE INCINERATOR ASH MANAGEMENT
NEW JERSEY ZINC COMPANY K06) STORAGE PILE
OMNIBUS AUTHORITY TO CONTROL EMISSIONS OF METALS, HCL ft PICs FROM INCINERATORS
PARTIAL PERMITTING OF INCINERATOR UNIT (DOW)
PERMITTING INCINERATORS
9468.1987(09) 10/15/87
9441.19841
9441.1989
9444.19861
9441.1988
9441.1990
9441.1988
08)
48)
02)
27)
03
07)
9494.1991(04)
9488.1987(03)
9441.1983(04
9488.1989(02)
9488.1990(01
9573.1991(01
9441.1984(05
9441.1988(04
9528.1989(11
9488.1986(03
9441.1986(87
9433.1987(01
9432.1986(02
9432.1985	07
9488.1990 02
9488.1987(04
9488.1987(01
9528.1986(07
9534.1991(01
9432.1987(07
9433.1991(03
9488.1986(05
9488.00-1A
9441.1988(11)
9432.1985(08
9488.1989(03
9432.1987(06
9501.1986	01
9432.1985	10
9528.1987(15
9528.00-1
9554.1990
9573.1986
9481.1988
9524.1989
9522.1985
9488.00-2
05/03/84
09/12/89
01/27/86
06/15/88
02/13/90
03/10/88
04/23/91
03/25/87
06/08/83
10/04/89
9495.1986(13) 06/27/86
03/29/90
05/01/91
02/19/84
01/14/88
07/30/89
03/30/86
11/30/86
01/07/87
01/03/86
11/19/85
04/19/90
06/12/87
02/09/87
09/19/86
12/03/91
07/17/87
07/10/91
04/24/86
05/07/86
04/21/88
11/20/85
10/17/89
07/02/87
09/11/86
12/30/85
11/25/87
11/25/87
11/20/90
06/27/86
01/25/88
02/27/89
08/30/85
06/10/86
-------
ge No,
mm
KEYWORD INDEX
PERMITTING OF HAZARDOUS WASTE INCINERATORS
PERMITTING REQUIREMENTS FOR A PCS INCINERATOR
PICKLE LIQUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE
POHC SELECTION FOR RCRA HAZARDOUS WASTE TRIAL BURN - USE OF 1,2,1-TRICHLORDBENZENE
PROPOSED RULES IMPACT ON PERMIT DEADLINES
QUANTUM TECH PLASMA ARC UNIT - REGULATORY CLASSIFICATION
REYNOLOS METALS COMPANY INCINERATOR
SPENT FLUIDIZED BED MEDIA AND CHANGES UNDER INTERIM STATUS
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MINITIONS
THERMAL OXIDATION UNIT/FUME INCINERATOR AND CYANURIC CHLORIDE WASTE
THIRD THIRD LAND DISPOSAL RESTRICTIONS
TOTALLY ENCLOSED TREATMENT EXEMPTION AND ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY
Industrial Furnace
BOILERS AND INCINERATORS. DISTINCTION BETWEEN/INTEGRAL OESIGH STANDARD
BOILERS USED IN GREENHOUSE OPERATIONS ARE INDUSTRIAL BOILERS
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY
DEACTIVATION (POPPING) FURNACES AS INCINERATORS
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE
HALOGEN ACID FURNACES AS INDUSTRIAL FURNACES OR BOILERS
INDUSTRIAL FURNACE WHICH CEASES BURNING STATUS UNDER BIF REGULATION
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES AND THE RESIDUALS GENERATED (LOUISIANA REG)
PICKLE LIQUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE
SULFUR RECOVERY FURNACES ARE INDUSTRIAL FURNACES SUBJECT TO THE WASTE-AS-FUEL RULES
WASTE-DERIVED FUELS BURNED IN CEMENT KILN, REGULATION OF
9501.1982(01
9488.1986(04
9432.1907 13
9488.1991(01
9501.1987 03
9488.1991(04
9523.1988(04
9444.1906(28
9523.00-17
9442.1991(16
9488.1986(06
9551.1990(15
9432.1987 10
9432.1986(02)
9432.1986(03
9441.1986(95
9432.1987(07
9441.1988(11
9433.1986(16
9488.1991(02
9494.1987(02
9432.1987(13
9432.1986(04
9494.1985(03)
07/09/82
04/11/86
11/10/87
02/05/91
12/28/87
09/30/91
10/27/86
12/05/86
09/02/88
05/01/91
04/30/86
12/20/90
08/28/67
01/03/86
01/09/86
12/23/86
07/17/87
04/21/88
08/12/86
06/06/91
04/15/87
11/10/87
01/21/86
10/11/65
POHCs
DEPARTMENT OF ARMY MUNITION DEACTIVATION POPPING FURNACE
WATER-STRIPPED POHCs ON INCINERATOR ORE
9488.1987(03)
9488.1985(07)
03/25/67
06/26/85
Scrubber Water
WASTE CODES AND TREATMENT RESIDUES
Trial Burn
-------
I
Page No,
04/06/92
KEYWORD INDEX
INSPECTIONS
(See Compliance)
INSURANCE
XREF
/ /
(Sm Financial Responsibility)
INTERIM AUTHORIZATION
XREF
/ /
(See State Authorization)
INTERIM STATUS PROCESS
XREF
/ /
_o
(See also Construction)
'EXISTING PORTION OF A IAN0 DISPOSAL UNIT, DEFINITION (260.10)
•EXISTING PORTION. DEFINITION AND HSWA IMPACT
*HAZARDOUS WASTE TANKS - EXISTING VS. NEW TANK
•INTERIM STATUS FOR MILITARY FACILITIES OPEN BURNING AREA
HAND DISPOSAL RESTRICTION, OIOXINS AND 90-DAY ACCUMULATION
BIF RULE APPLIED TO NEWLY REGULATED UNITS AT INTERIM STATUS FACILITIES
BURNING HAZARDOUS WASTE IN BOILERS ANO INDUSTRIAL FURNACES (BIFs)
CLOSURE PLANS-MOBILE TREATMENT UNITS
DELISTING. INTERIM STATUS. AND SAMPLING ISSUES AT U.S. NAMEPLATE COMPANY
SLUDGE WASTE HANDLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY
•
Change During Interim Status •
» OWNERSHIP SPLIT OF ONE FACILITY INTO TWO FACILITIES
•ADDITION OF A SURFACE IMPOUNDMENT TO AN EXISTING INTERIM STATUS FACILITY
•ADDITION OF NEW HAZARDOUS WASTE MANAGEMENT UNIT
•CHANGES AT INTERIM STATUS TANK FACILITIES
•CHANGES DURING INTERIM STATUS - CORPORATE REORGANIZATION
•CHANGES DURING INTERIM STATUS-CORRECTIONS
•CHANGES TO INTERIM STATUS FACILITIES
•CHANGES TO INTERIM STATUS TANK FACILITIES
•CONSTRUCTION OURING INTERIM STATUS WHERE ORIGINAL UNITS ARE CLOSED
•CONSTRUCTION OURING INTERIM STATUS - RECONSTRUCTION LIMIT WHERE SOME UNITS HAVE CLOSED
•DELISTING OF K051 WASTE AT PETROLEUM REFINERY-EFFECT ON INTERIM STATUS
•INTERIM STATUS VS. PERMIT MODIFICATION FOR NEWLY REGULATED UNITS
•RETROFITTING INTERIM STATUS SURFACE IMPOUNDMENTS
CHANGES IN INTERIM STATUS - SELLING PART OF A FACILITY
CHANGES TO FACILITIES DURING INTERIM STATUS
CONSTRUCTION OF A NEW INCINERATOR WITH THE CHANGES DURING INTERIM STATUS
CONSTRUCTION OF A NEW LANDFILL CELL AND THE OMNIBUS PROVISION
CONTAMINATED GROUNDWATER. REGULATORY STATUS OF
FACILITY CHANGES DURING INTERIM STATUS
FACILITY TRANSFER/RECONSTRUCTION DURING INTERIM STATUS
IMPROVEMENTS TO SURFACE IMPOUNDMENTS UNDER INTERIM STATUS
INTERIM STATUS EXPANSION TO AM AN INCINERATOR
INTERIM STATUS EXPANSION TO ADD AN INCINERATOR
INTERIM STATUS OF PROPOSED LANOFILl CELLS
NEW WASTE STREAMS AT INTERIM STATUS FACILITIES
NEWLY IDENTIFIED WASTE STREAMS AS A RESULT OF NEW TC
XREF
9432.1982(01
9432.1985(05
9463.1968 09
9441.1984(04
9551,1987(04
9520.1991 0!
9494.199101
9476.1968(02
9433.1987(03
9433.1986(17
9528.1987(16
9528.1985(01
9528.1983(01
9528.1987(09
9528.198504
9528.1988	05
9528.1989	11
9483.1988	16
9528.1987(03
9528,1987 04
9433.1986	12
9525.1989	01
9528.1988(03
9528.1987	16
9528.1982(01
9528.1986 07]
9528.1986(01
9528.1987(02
9528.1982(02
9477.1986(01
9528.1984(01
9528.00-1
9528.1987i
9487.198li
9528.19901
9528.1990!
15)
01
01)
03)
/ /
08/30/82
08/08/85
05/30/88
02/18/84
01/30/87
08/07/91
02/04/91
08/22/68
02/25/87
09/30/86
11/30/87
12/30/85
03/30/83
08/30/87
10/30/85
10/30/88
07/30/89
09/30/88
03/30/87
03/30/87
04/30/86
05/30/89
05/30/86
11/30/87
05/28/82
09/19/86
03/03/86
03/11/87
07/20/82
01/03/86
09/10/84
11/25/87
11/25/87
03/12/81
04/02/90
07/11/90
-------
Paoe No.
04/06/92
\
KEYWORD INDEX
-c
NEWLY REGULATED UNITS AT PERMITTED FACILITIES
PERMITTING UNITS CREATED FOR FACILITY CLOSURE
REDESIGNATE OF SURFACE IMPOUNDMENTS AS LANDFILLS DURING INTERIM STATUS
SPENT FLU1DIZED BED MEDIA AND CHANGES UNDER INTERIM STATUS
TRANSFER OF A HAZARDOUS HASTE STORAGE OPERATION TO A NEW SITE
Cloture
•GROUNDWATER MONITORING-ASSESSMENT MONITORING/CORRECTIVE ACTION AT CLOSED INTERIM STATUS FACILITIES
'LEASING OF PROPERTY PRIM TO CLOSURE
3008(h) OF THE SOLID WASTE DISPOSAL ACT. INTERPRETATION OF
CLOSURE PLANS-MOBILE TREATMENT UNITS
DEADLINES APPLICABLE TO PROPOSED DELAY OF CLOSURE REGULATION, GUIDANCE ,
DEMONSTRATING EQUIVALENCE OF PART 265 CLEAN CLOSURE WITH PART 264 REQUIREMENTS
MUNITIONS REGULATED AS HAZARDOUS WASTES
NEUTRALIZATION SURFACE IMPOUNDMENTS. GROUNDWATER MONITORING FOR CLOSURE OF INTERIM-STATUS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS
PUBLIC PARTICIPATION REQUIREMENTS FOR CLOSURE PLAN APPROVAL
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 3005(1) OF RCRA TO
Corrective Action
•CORRECTIVE ACTION FOR INTERIM STATUS SURFACE IMPOUNDMENT
GROUNDWATER CONTAMINATED WITH HAZARDOUS WASTE LEACHATE
RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
RELEASES OF HAZAROOUS WASTE, RCRA APPLICABILITY TO
Loss of Interim Status
•APPEAL/RECOURSE PROCESS FOR PERMIT OENIAL
•LOSS OF INTERIM STATUS - LAND DISPOSAL FACILITIES
•SURFACE IMPOUNDMENTS LOSING I.S. BECAUSE OF NON-COMPLIANCE WITH GWM I FINANCIAL RESPONSIBILITY REQS.
~ «TSDF ClOSURE/P-C AFTER LOSS OF INTERIM STATUS
CALL-IN OF STORAGE ANO TREATMENT APPLICATIONS PRIOR TO 11/00/88 DEADLINE
CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUS
CORRECTIVE ACTION AUTHORITY AT FACILITIES THAT LOSE INTERIM STATUS
ENFORCEMENT OF APPLICABLE RCRA REGULATIONS AT FACILITIES WITH PENOING OELISTING PETITIONS
LOSS OF FINANCIAL RESPONSIBILITY COVERAGE ON INTERIM STATUS AND PERMIT ISSUANCE
LOSS OF INTERIM STATUS FROM NEWLY IDENTIFIED TC WASTES
OWNER/OPERATOR RESPONSIBILITY IF FACILITY'S INTERIM STATUS IS TERMINATED
PENALTIES FOR FAILURE TO SUBMIT A COMPLETE ANO ADEQUATE PART B APPLICATION
PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
RCRA 3001(f)(2)(b) AND STATES' EXCLUSION OF WASTES FROM REGULATION AS HAZARDOUS
RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
STATE PROGRAM ADVISORY *2 - RCRA AUTHORIZATION TO REGULATE MIXED WASTE
TEMPORARILY AND INFORMALLY DELISTED WASTES, REGULATORY STATUS
Obtaining Interim Status
•BURNING AND BLENDING AND INTERIM STATUS
•CIRCUMSTANCES FOR OBTAINING INTERIM STATUS FOR UNITS AT AN INTERIM STATUS FACILITY
•INTERIM STATUS ANO SQG
•INTERIM STATUS FOR RECEIVING SQS WASTE
•LANO DISPOSAL RESTRICTION, DIOXINS ANO 90-DAY ACCUMULATION
•LAND DISPOSAL RESTRICTIONS - STORAGE OF HAZARDOUS WASTE
CALL-IN OF STORAGE ANO TREATMENT APPLICATIONS
CEMENT KILN BURNING HAZAROOUS WASTE FUELS DURING INTERIM STATUS
COMPLYING WITH RCRA INTERIM STATUS STANOARDS WHILE DEVELOPING *«?HIT APPLICATION
EXTENSION OF OEAOLINE FOR PART A SUBMITTAL AND INTERIM STATUS APPLICABILITY FOR CEMENT KILNS
INTERIM STATUS QUALIFICATION-REQUIREMENTS TO HAZARDOUS WASTE FUEL STORAGE FACILITIES. APPLIED
9528.1986
9476.1985
9528.1908
9444.1986(
9528.19861
9481.1988(02
9528.1983 01
9502.1985 09
9476.1908(02
9476.1988(04
9476.00-18
9441.1990(23
9484.1906 03
9476.1985 04
9476.1989 03
94?6.1987|01
9464.1906(07)
9441.1986(83)
9502.1986(02)
9502.1987(05)
9521.1966104a)
9528.1981 031
9470.1985(01
9476.1991(021
9521.1988(02)
9484.1986(02)
9528.1987(01)
9433.1987(14)
9528.1985 09
9528.1990(02)
9471.1985(01)
9523.1984(10)
9528.1986(11)
9528.1986(08)
9433.1986(09)
9502.1986(02)
9541.00-6
9433.1986(05)
9528.1985
9522.1984
9521.1986
9528.1986
9551.1987
9511.1987
9528.1988
9528.1907
9528.1986
9528.1987
9528.1986
11
01
05a)
06)
04)
05)
06)
10)
09)
12)
tO)
01/30/86
09/11/85
05/11/88
12/05/86
03/03/86
04/30/88
03/30/83
12/16/85
08/22/88
05/31/88
05/12/88
08/21/90
04/09/86
09/25/85
09/07/89
06/09/87
07/30/86
11/13/86
01/31/86
04/02/87
04/30/86
09/30/85
02/28/85
10/01/91
04/19/88
04/02/86
01/30/87
07/20/87
10/27/85
07/11/90
12/30/84
12/18/84
12/10/86
11/20/86
04/16/86
01/31/86
07/30/87
02/24/86
12/30/85
12/31/84
05/30/86
07/30/86
01/30/87
02/20/87
04/19/80
09/03/87
10/27/86
09/18/67
11/13/86
-------
Page No.
04706/92
KEYWORD INDU
INTERIM STATUS REQUIREMENTS FOR NRC LICENSEES MANAGING RADIOACTIVE MIXEO VASTE, CLARIFICATION
INTERIM STATUS UNDER THE BIF RULE
MARKETING OR BURNING HAZARDOUS VASTE FUEL, NOTIFICATION OF
MOBILE TREATMENT UNITS QUALIFIED FOR INTERIM STATUS
REGULATION OF RADIOACTIVE MIXEO VASTE AT DEPARTMENT OF ENERGY FACILITIES
REQUIREMENT THAT STATE-PERMITTED HAZAROOUS VASTE FACILITIES HAVE INTERIM STATUS
STATE AUTHORIZATION AND REGULATION OF RADIOACTIVE MIXEO VASTES
STATE PROGRAM ADVISORY 12 - RCRA AUTHORIZATION TO REGULATE MIXED VASTE
USE OF PETROLEUM-CONTAMINATED SOILS AS AN INGREDIENT IN ASPHALT BATCHIN^
Protective Fliers
•INTERIM STATUS PART A APPLICATION VITHORAVL
LAND DISPOSAL OF UNTREATED HAZAROOUS VASTE
REYNOLDS METALS COMPANY INCINERATOR
9518.19891
9528.19911
9494.19861
9528.19911
9528.19871
9542.19801
9541.1987
9541.00-6
9493.1991(02)
03
01
02
14
01
04
9453.1991(01
9551.1990 04
9523.1986(04
10/15/89
08/19/91
02/09/86
02/27/91
11/12/87
10/03/80
06/29/87
07/30/87
06/20/91
06/01/91
10/03/90
10/27/86
INVENTORY
(See Federal Facilities)
IRON FOUNDRY VASTE
XREF
/ /
(See Listed Hazardous Vaste)
IRON SPONGE
XREF
/ /
(See Hazardous Vaste Identification)
JOINT PERMITTING
XREF
/ /
-D
c i\
(See State Authorization)
LABORATORY ANALYSIS
XREF
/ /
(See Analytic Methods)
LABORATORY VASTES
XREF
/ /
•LAB EXCLUSION, APPLICATION OF
•LABORATORY AUDIT INSPECTION
•LABORATORY TESTING FOR DIOXIN
CONTINUED LANDFILL OISPDSAL OF LAB PACKS
DI0X1N-C0NTAINING LABORATORY VASTE VITH RADIOACTIVE PROPERTIES
LABORATORIES. RCRA REGULATION IMPACT
LABORATORY VASTE EXCLUSION
	 CONTAUHNG 010XIN
REGULATION MID PERMITTING OF LABORATORIES
SEOIMENT SAMPLE DISPOSAL
SMALL QUANTITY GENERATOR REGULATIONS APPLICABILITY TO LABORATORIES
SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS
TEST SAMPLES, EXCLUSION FROM HAZARDOUS VASTE
9441.1984(221
9431.1987(03)
9441.1985(11
9487.1985 02
9441.1985(26)
9441.1990 32
9441.1985(03}
9444.1986(30)
9554.1990 13
9441.1988(39
9441.1989(12)
9441.1985 34)
9487.1986(13)
9431.1989(03)
07/31/84
07/30/87
03/30/85
05/10/85
07/05/85
11/28/90
07/31/85
12/10/86
11/20/90
08/30/88
03/31/89
10/30/85
12/31/86
12/31/89
-------
e No.
06/92
KEYWORD INDEX
THIRD THIRD LAND DISPOSAL RESTRICTIONS
THIRD THIRO LAND DISPOSAL RESTRICTIONS FINAL RULE
LAND BAN
9551.1990(15)
9551.1991{13f
12/20/90
12/20/91
(Set Land Disposal Restrictions)
LAND DISPOSAL
XREF
/ /
(Set Land Disposal Facilities)
LAND DISPOSAL BAN
XREF
/ /
(Set Land Olsposal Restrictions)
UNO DISPOSAL FACILITIES
XREF
/ /
Requirements, Land Disposal Restrictions)
BE FROM
'GROUNDWATER MONITORING ESTABLISHING BACKGROUNO VALUES
*MULTISOURCE LEACHATE (F039) WASTE CODE AS IT APPLIES TO CONTAMINATION FROM SPILLS
~TOXICITY CHARACTERISTIC HASTE PART B PERMIT APPLICATION DEADLINES
•TREATMENT SURFACE IMPOUNDMENTS LOSING I.S. BECAUSE OF NON-COMPLIANCE MITH 6WM 1 FINANCIAL RESPONSIBILITY REQS.
COMBINED NRC-EPA SITING GUIDELINES FOR OISPOSAL OF COMMERCIAL NIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE
DENIAL OF RCRA OPERATING PERMITS
• GRAY IRON FOUNDRY WASTE OISPOSAL
LAND OISPOSAL FACILITIES NOT ON A PERMITTING OR CLOSURE SCHEDULE
LAND DISPOSAL UNIT CLOSURE CLARIFICATION OF PROPOSED AND PROMULGATED RULES
LOSS OF FINANCIAL RESPONSIBILITY COVERAGE ON INTERIM STATUS AND PERMIT ISSUANCE
PHYSICAL COMPLIANCE IN GROUNDWATER MONITORING, DEFINITION
_0	POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATEO UNITS
C,-	RCRA 3001(f)(2)(b) AND STATES' EXCLUSION OF WASTES FROM REGULATION AS HAZARDOUS
RCRA FACILITY ASSESSMENTS, IMPLEMENTATION
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT] COMMENTS
VERTICLE EXPANSION AT U.S. ECOLOGY'S TRENCH 10, BEATTY, NEVADA FACILITY
VULNERABLE HYOROGEOLOGY GUIDANCE CRITERIA
Gas Condensate
LANDFILL GAS CONDENSATE, REGULATION OF
Geologic Repositories
PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT MINES
Land Disposal
•LAND DISPOSAL RESTRICTIONS - STORAGE OF HAZARDOUS WASTE
•LOSS OF INTERIM STATUS - LAND OISPOSAL FACILITIES
ABOVE-GROUND LAND EMPLACEMENT FACILITIES, N.J. LAW
COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZER
EFFECT OF LAND OISPOSAL RESTRICTIONS ON PERMITS
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES
EXEMPTION FOR COMMERCIAL FERTILIZERS ONCE THE FERTILIZER IS PRODUCED
HSWA MINIMUM TECH REQUIREMENTS FOR LINERS AND LEACHATE COLLECTION SYSTEMS
INDUSTRIAL WASTE DISPOSAL IN PROXIMITY TO WETLANDS
XREF
9481.1985(06
9481.1966(04
9444.1991(06
9501.1990(01
9470.1985(01
9480.00-14
9523.00-11
9486.1981(01
9501.1987 01
9476.1985(05
9528.1985(09
9481.1985(04
9476.1985(04)
9433.1986(09)
9502.00-4
9523.00-14
9487.00-9
9481.1987(03)
9441.1985(01)
9472.1986(04)
9551.1987(05)
952B.1985(03)
9467.1986(04
9493.1986(01)
9551.1986(15)
9451.1986(01
9493.1986(03)
9480.1985(01)
9551.1990(01)
/ /
12/30/85
07/30/86
11/01/91
07/31/90
02/28/85
03/13/89
12/10/86
06/18/81
09/17/87
12/13/85
10/27/85
10/30/85
09/25/85
04/16/86
08/21/86
03/14/86
02/10/8B
06/03/87
01/11/85
06/04/86
02/28/87
09/30/85
03/26/86
01/22/86
09/15/86
03/17/86
08/21/86
04/01/85
05/09/90
-------
i	)
Pagt No.
04/06/92
KEYWORD INDEX
\
..D
O
INTERPRETATION OF 40 CFR 260.7 REQUIREMENTS
LAND DISPOSAL OF HAZAROOUS HASTES - USE OF NUCLEAR TEST SITES
LAND DISPOSAL PERMIT STRATEGY
UNER/LEACHATE COLLECTION SYSTEM COMPATIBILITY
LOSS OF INTERIM STATUS (ION NEWLY IDENTIFIED TC WASTES
MIXEO WASTE DISPOSAL FROM RADIOACTIVE MATERIALS MANUFACTURING OPERATIONS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS
RCftA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
WASTE ACID AS WASTEWATER CONDITIONER AND AS INGREDIENT IN FERTILIZER
Land Treatment
*LANQ TREATMENT
•WASTE STORAGE IN A WASTE PILE
BULK LIQUIDS AND DRAIN/LEACHING FIELDS
CLOSURE STANDARDS FOR HAZARDOUS WASTE LAND TREATMENT UNITS
DEGRADATION, TRANSFORMATION OR IMMOBILIZATION IN TREATMENT ZONE
DRAINAGE WATER BENEATH LAND TREATMENT UNITS AT OIL REFINERIES
INITIAL SOIL SURFACE TERN DEFINED IN LAND TREATMENT REGULATIONS
LAND TREATMENT UNITS, DEPTH TO WATER TABLE REQUIRMENT
LEACHATE AND PRECIPITATION RUN-OFF AT LFs, WASTE PILES, AND LT UNITS. HAZARDOUS WASTE FROM MIXTURE OF
NO-MIGRATION PETITION FOR AMOCO REFINERY
NO-MIGRATION PETITION FOR ARCO PRODUCTS, WA
NO-MIGRATION PETITION FOR ATLANTIC REFINING I MARKETING, PA
NO-MIGRATION PETITION FOR CONOCO, NT
NO-MIGRATION PETITION FOR EXXON, TX
NO-MIGRATION PETITION FOR KERR-NC6EE REFINING, OK
NO-MIGRATION PETITION FOR KOCH'S REFINING, TX
NO-MIGRATION PETITION FOR KOCH REFINING, TX
NO-MIGRATION PETITION FOR MARATHON PETROLEUM, IL
NO-MIGRATION PETITION FOR ROBINSON, IL
NO-MIGRATION PETITION FOR SHELL OIL, WA
NO-MIGRATION PETITION FOR SINCLAIR OIL. OK
NO-MIGRATION PETITION FOR STAR ENTERPRISE, OE
NO-MIGRATION PETITION FOR SUN REFINING, OK
NO-MIGRATION PETITION FOR TEXACO, WA
POSTPONEMENT OF A LAND TREATMENT DEMONSTRATION FOR NAVAJO REFINING CO., ARTESIA, NM
SUMMARY OF PERMIT ASSESTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNOHENTS/LAND TREATMENT UNITS REGULATION IF ASSOCIATED WWT SLUDGES ARE LISTED
WATER TABLE REQUIREMENT FOR LAND TREATMENT UNITS
Landfill
•EXISTING UNITS AND MINIMUM TECHNOLOGY STANDARDS
•HAZARDOUS WASTE TANK CLOSURE AND POST CLOSURE
•LANDFILLS WITH EP TOXIC LEACHATE. REGULATION OF
•NON-HAZARDOUS LIQUIDS BAN
ABOVE-GROUND LAND EMPLACEMENT FACILITIES, N.a. LAW
ABSORBENTS FOR CONTAINERIZED LIQUID HAZARDOUS WASTES, USE OF
BAN ON DISPOSAL OF LIQUIDS IN LANDFILLS
BAN ON USE OF LIQUIDS IN LANDFILLS
BULK LIQUID HAZAROOUS WASTE SOLIDIFICATION REQUIREMENTS
BULK LIQUIDS AND DRAIN/LEACHING FIELDS			
CLOSURE PLAN FOR THE HAZAROOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT
CLOSURE REQUIREMENTS	„
CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN RCRA LANDFILLS
CONTINUED LANDFILL DISPOSAL OF LAB PACKS
9554.1988(03)
9480.1964 01
9501.1962(02)
9487.1986 10
9528.1990 02
9554.1960(04)
9521.1995 01
9502.1986 02
9441.1905 39
9441.1986(80)
9486.1987(01
9485.1904(01!
9407.1906(09
9476.1991(01
9486.1990	01
9486.1988(01;
9486.1988 02
9486.1986 03
9441.1904(97'
9551.1990(13
9551.1990(08
9551.1991	06|
9551.1991 09;
9551.1991(03!
9551.1991(05
9551.1991(01
9551.1991(12
9551.1990(09;
9551.1991(14
9551.1990(11
9551.1990 12
9551.1990(10
9551.1991(02;
9551.1991(00
9524.1989(03
9523.00-IS
9523.00-12
9480,1985(02)
9483.1986(03)
9487.1986(14)
9476.1906(02
9487.1984	04
9487.1985	06
9487.1986(04
9487.1985	05
9487.1985(03
9487.1986	07
9487.1987(01
9487.1986 09
9480.1907(01
9476.00-12
9407.1986(12
9407.1985
'ill
05/13/88
06/12/84
12/29/02
08/07/06
07/11/90
06/13/00
09/25/85
01/31/86
11/25/05
10/20/86
07/30/07
11/30/84
06/12/86
05/02/91
04/27/90
01/02/00
04/11/08
07/15/86
11/14/84
11/00/90
10/24/90
04/22/91
05/29/91
01/29/91
02/05/91
01/03/91
12/10/91
11/06/90
05/01/91
11/07/90
11/08/90
11/07/90
01/17/91
05/29/91
03/23/09
03/30/88
03/30/87
07/17/85
07/25/86
12/30/86
09/30/86
08/30/84
09/30/85
03/26/06
09/20/85
05/20/85
04/27/86
01/20/87
06/12/86
02/09/87
02/02/88
12/30/86
05/10/85
-------
Page No.
04/06/92
KEYWORD INDEX
DRV TOLUENE AND CARBON TETRACHLORIDE, SAFE DISPOSAL OF
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
LAND DISPOSAL UNIT CLOSURE CLARIFICATION OF PROPOSED AND PROMULGATED RULES
LEACHATE AND PRECIPITATION RUN-OFF AT LFs. WASTE PILES, AND LT UNITS, HAZARDOUS WASTE FROM MIXTURE OF
LINER/LEACHATE COLLECTION SYSTEM COMPATIBILITY
LIQUID HAZARDOUS WASTES IN LANDFILLS
PCB-CONTAHINATEO WASTES, STABILIZATION OF
POST-CLOSURE PERMIT REQUIREMENT (ARMCQ STEEL)
PROHIBITION ON PLACING LIQUIDS IN LANDFILL
REDESIGNATE OF SURFACE IMPOUNDMENTS AS LANDFILLS DURING INTERIM STATUS
RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES
SAMPLING PLAN FOR DELISTING PETITION FOR WASTES IN LANDFILL TRENCHES
SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS
STANDARDS AGAINST WHICH 3004(c)(2) EQUIVALENCY PETITION SHOULD BE COMPARED-DOUBLE LINER
SUBSURFACE FATE AND TRANSPORT MODEL
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS	i
TEL GASOLINE SLUDGE OISPOSAL
Landfill Gas
GASEOUS EMISSIONS FROM LANOF ILLS
Wasta PIlas
•CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT & WASTE PILE
•WASTE PILE LINERS - MTR (264.251)
•WASTE STORAGE IN A WASTE PILE
ADJACENT WASTE PILES INTO REGULATEO SURFACE IMPOUNDMENT, PLACEMENT OF (CIBA-GEIGY)
	 CUW( CL0SM pi CODIFICATION RULE 12/01/87
LEACHATE AND PRECIPITATION RUN-OFF AT LFs, WASTE PILES, AND LT UNITS, HAZARDOUS WASTE FROM
INTERIM STATUS SURFACE IMPOUNDMENTS I
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
THREE AND FOUR-SIDED, FLOORED STRUCTURES, REGULATORY CLASSIFICATION OF
WASTE PILES AND POST-CLOSURE PERMITS, APPLICATION OF NOVEMBER 1968 DEADLINE TO
MIXTURE OF
9451.1986(06)
9441.1986(03)
9476.1985(05)
9441.1984(371
9487.1986(10)
9487.1981(04)
9487.1960 01
9522.1986(03)
9487.1985 10)
9528.1986(02)
9487.19861081
9433.1986(211
9487.1906 13
9487.1986(11)
9431.1991(01}
9523.00-17
9523.00-12
9553.1989(01)
9522.1988(01)
9485.1985 01
9485.1984(01)
9484.1987(06)
9522.1988(05
9441.1984(37)
9523.00-12
9432.1987(02)
9501.1985(01)
12/15/86
01/07/86
12/13/85
11/14/84
08/07/86
08/07/85
02/03/88
11/20/66
12/05/85
05/11/88
05/27/86
12/13/86
12/31/86
12/04/86
03/26/91
09/02/88
03/30/87
07/28/89
9487.1986(03) 03/06/86
02/28/88
03/30/85
11/30/84
06/26/87
11/30/88
11/14/84
03/30/87
04/02/87
10/01/85
LAND DISPOSAL RESTRICTIONS
-.0
rf*
BDAT
•CHANGES TO INTERIM STATUS TANK FACILITIES
•LAND DISPOSAL RESTRICTION
•LAND OISPOSAL RESTRICTIONS DEFINITIONS
•PROHIBITION ON STORAGE OF RESTRICTED WASTES
CONOCO PART B PERMITS
LAB PACKS - LAND OISPOSAL RESTRICTIONS ASPECTS
LAND BAN ISSUES - 1988 UPOATE
LAND OISPOSAL RESTRICTIONS APPLIEO TO EXPORTED WASTES
LANO DISPOSAL RESTRICTIONS CLARIFICATIONS
LAND DISPOSAL RESTRICTIONS EFFECT ON PERMITS
LEAD SHEILDING FOR RADIOACTIVE WASTE IS A RCRA SOL 10 WASTE
PERFORMANCE STANDARDS FOR OISPOSAL IN SALT DOMES
PERSONAL PROTECTIVE GEAR DISPOSAL
RECYCLABLE MATERIALS WHERE PRECIOUS METALS ARE RECLAIMED
SHAN INCINERATION AND TREATMENT OF K048-K052 WASTES IN CEMENT KILNS AND INDUSTRIAL FURNACES
•TREATMENT STANDARDS - BDAT
PLACEMENT OF STABILIZED WASTES THAT 00 NOT MEET LANO RESTRICTION REQUIREMENTS
PROPOSIO BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) FOR K06I WASTE
REINJECTED GROUNOWATER RESULTING FROM CORRECTIVE ACTION TREATMENT
9483.1988(16
9541.1987
9551.1986
9453.1986(06
9553.1990(01
9551.1990(02
9551.1988(08
9551.1991 07
9551.1987(01
9522.00-1
9444.1991(02
9489.1991105
9441.1990! 15
9551.1989103
9494.1991102
9554.1986(04)
9554.1989(02)
9441.1988(06)
9554.1991(03)
09/30/88
12/30/87
12/30/86
11/30/86
05/11/90
08/08/90
06/16/88
04/23/91
01/20/87
09/15/87
04/30/91
02/22/91
06/14/90
12/20/89
03/29/91
12/30/86
05/05/89
03/09/88
04/01/91
-------
B No.
06/92
KEYWORD INDEX
D
„A>
TECHNICAL SUPPORT DOCUMENT FOR BOAT
TEL GASOLINE SLUDGE DISPOSAL
Bulk Liquids
•STORAGE PRIOR TO RECYCLING
BULK LIQUID HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTS
CONTAINERIZED ANO BULK HAZARDOUS LIQUIDS IN RCRA LANDFILLS
PCB-CONTAMINATED WASTES. STABILIZATION OF
PROHIBITION ON PLACING LIQUIDS IN LANDFILL
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
California List	,
•CALIFORNIA LIST
~LAND DISPOSAL RESTRICTIONS - CALIFORNIA LIST
•LAND OISPOSAL RESTRICTIONS ~ HALOGENATED ORGANIC CARBONS
•LAND OISPOSAL RESTRICTIONS: POINT OF GENERATION
•MIXED WASTE AND LAND BAN
APPROPRIATE TREATMENT METHODS FOR ELEMENTAL MERCURY
CALIFORNIA LIST HOC LAND BAN REGULATIONS
CALIFORNIA LIST LAND DISPOSAL RESTRICTIONS ARE APPLICABLE TO LIQUID WASTES
CALIFORNIA LIST LAND DISPOSAL RESTRICTIONS, EPA's IMPLEMENTATION OF
CALIFORNIA LIST PROHIBITIONS APPLICABILITY AFTER THIRD THIRO RULE
COMPLIANCE WITH CALIFORNIA LIST FINAL RULE
HAZARDOUS WASTES CONTAINING HALOGENATED ORGANIC COMPOUNDS (HOCs)
PAINT FILTER LIQUIDS TEST USED TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONS
RESTRICTED WASTE DEFINITION
SOLIOIFICATION OF CALIFORNIA LIST LIQUID WASTES AND THE DILUTION PROHIBITION
TESTING REQUIREMENTS AND SOLIOIFICATION ISSUES UNDER LAND OISPOSAL REQUIREMENTS
Caae-by-Casa Extension
HAND DISPOSAL RESTRICTION. 01 OX INS AND 90-DAY ACCUMULATION
CASE-BY-CASE EXTENSION PETITION, INFORMATION REQUIRED
CASE-BY-CASE EXTENSION UNDER THE LAND DISPOSAL RESTRICTIONS, INFORMATION REQUIRED
EXTENSION OF APPLICABLE EFFECTIVE OATE OF THE LAND DISPOSAL RESTRICTIONS
EXTENSIONS TO STORAGE PROHIBITION AND LAND DISPOSAL RESTRICTIONS
GENERATOR REQUEST FOR EXEMPTION FROM OR EXTENSION OF LAND OISPOSAL RESTRICTIONS
LAND DISPOSAL RESTRICTIONS FOR SOLVENTS AND DIOXINS, EXEMPTIONS TO
SOLVENT-CONTAINING WASTE SOLIDIFIED WITH VERM1CULATE
Fret Liquids
•LIQUIDS AND FREE LIQUIDS, DEFINITION OF
BAN ON USE OF LIQUIOS IN LANDFILLS
BULK LIQUIDS ANO DRAIN/LEACHING FIELDS
COMPRESSIVE STRENGTH OF TREATED WASTES
CONTAINERIZED AND BULK HAZARDOUS LIQUIOS
LIQUID WASTE, DEFINITION OF
PAINT FILTER LIQUIDS TEST USED TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONS
PERFORMANCE AND PERMITTING STANDARDS IN 3004(b), PROHIBITION OF PLACEMENT OF HAZARDOUS WASTE IN SALT DOMES
SOLIDIFICATION OF CALIFORNIA LIST LIQUID WASTES AND THE DILUTION PROHIBITION
WASTE AS LIQUID OR SOLID, DETERMINATION OF
USE OF SW-846 METHOOS, WASTE IDENTIFICATION
IN RCRA LANDFILLS
9553.1986(04]
9553.19891
01]
9475.19871
01
9487.1987
01
9487.1986
12
9487.1988
01
9487.1985
10
9523.00-1"

9554.1987(03)
9551.1987(09)
9553.1987(13
9554.1989(03
9511.1989(021
9553.1907 16
9554.1989(04)
9553.1987(09)
9553.1907 14
9551.1991(11
9551.1987(21)
9551.1989 01
9553.1987(15)
9551.1987(16)
9551.1987(23)
9551.1988(01)
9551.1987(04)
9551.1987 14
9551.1986(11)
9551.1988(09)
9555.1987 01)
9551.1987(12)
9553.1987 02)
9551.1987 06
9432.1985(03)
9487.1986(07)
9487.1986(09)
9445.1987(03a)
9487.1986(12)
9432.1981(01)
9553.1987(15
9489.1985(01)
9551.1987 23
9445.1984(06
12/30/86
07/28/89
04/30/87
01/20/87
12/30/86
02/03/88
12/05/85
03/14/86
07/30/87
03/30/87
09/30/87
10/30/89
03/30/89
11/18/87
11/28/89
09/18/87
10/15/87
09/27/91
10/28/87
01/06/89
12/03/87
09/04/87
11/13/87
05/05/88
01/30/87
07/16/87
08/11/86
08/11/88
10/02/87
06/26/87
01/13/87
03/10/87
05/30/85
04/27/86
06/12/86
11/17/87
12/30/86
06/28/81
12/03/87
09/20/85
11/13/87
07/30/84
Land Disposal Ban
•LAND DISPOSAL BAN OF SOLVENTS
•LAND OISPOSAL RESTRICTIONS - SOLVENT AND DIOXIN WASTES
•NON-HAZARDOUS LIQUIDS BAN
•STORAGE OF RESTRICTED WASTES
APPROPRIATE TREATMENT METHODS FOR ELEMENTED MERCURY
9551.1986(03
9553.1988(01
9487.1985(06
9551.1986(24
9553.1987(16)
02/28/86
02/28/88
09/30/85
12/30/86
11/18/87
-------
Paoa no.
04/06/92
KEYWORD 1N0EX
DRY CLEANING CARTRIDGE FILTERS, DISPOSAL OF
LAND DISPOSAL BAN - TRACES OF NATURALLY OCCURRING BENZENE ANO TOLUENE
LAND DISPOSAL PROHIBITION RULE FOR SOLVENTS
LAND DISPOSAL RESTRICTIONS EFFECT ON STORAGE/DISPOSAL OF COMMERCIAL MIXED WASTE
LAND DISPOSAL RESTRICTIONS ON THE METAL FINISHING INDUSTRY
PERMITTING ANO CORRECTIVE ACTION REQUIREMENTS AFFECTING COMPLIANCE WITH LAND DISPOSAL RESTRICTIONS
RISK-BASEO METHODOLOGIES ON LAND DISPOSAL RESTRICTIONS
SMALL VOLUME MIXED WASTE LABORATORY GENERATED MATERIALS AND LEAD
THERMAL TREATMENT UNITS, SCOPE OF SUBPART X
National Variance •
•LAND DISPOSAL RESTRICTIONS - IX NATIONAL VARIANCE (SOLVENTS)
•LAND DISPOSAL RESTRICTIONS - SOLVENT AND DIOXIN WASTES
*LOR REQUIREMENTS DURING NATIONAL CAPACITY VARIANCE
•VARIANCES TO BAN - EFFECTIVE DATES FOR SOLVENTS AND DI0X1NS
ASBESTOS/LEAD/SOIL/OEBRIS AS INORGANIC SOLID DEBRIS
MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONS
NATIONAL CAPACITY VARIANCE FOR INORGANIC SOLIDS OEBRIS
NON-APPLICABILITY OF THE LESS-THAN-1X EXTENSION TO TREATMENT RESIDUALS
PROCESS WASTEWATER FROM METAL DECREASING OPERATIONS
RESIDUALS FROM TREATMENT OF RESTRICTED WASTES NOT COVERED BY LESS-THAN-1X SOLVENT EXTENSION
SOLVENT-BEARING WASTEWATER, SLUDGE, AND BRINE TREATED AND STORED IN SURFACE IMPOUNDMENTS
WASTES GENERATED IN MANUFACTURING PROCESS UNIT NOT SUBJECT TO LAND DISPOSAL RESTRICTIONS UNTIL REMOVED
No-Mtgratlon Variance
•LAND DISPOSAL RESTRICTIONS VARIANCES
•LAND DISPOSAL RESTRICTIONS: DISPOSAL OF WASTES GRANTED A VARIANCE
CONCRETE LINERS FOR HAZAROOUS WASTE TANK SYSTEMS
CONOCO'S NO-MIGRATION PETITION DENIAL
* DRAINAGE WATER BENEATH LAND TREATMENT UNITS AT OIL REFINERIES
ORAINAGE WATER BENEATH LAND TREATMENT UNITS • NO MIGRATION PETITIONS
LAND DISPOSAL OF UNTREATED HAZARDOUS WASTE
—	NO-MIGRATION PETITION FOR AMOCO REFINERY
O	NO-MIGRATION PETITION FOR ARCO PRODUCTS, WA
O	NO-MIGRATION PETITION FOR CONOCO, MT
NO-MIGRATION PETITION FOR EXXON, TX
NO-MIGRATION PETITION FOR KERR-MCGEE REFINING. OK
NO-MIGRATION PETITION FOR KOCH'S REFINING. TX
NO-MIGRATION PETITION FOR KOCH REFINING, fX
NO-MIGRATION PETITION FOR MARATHON PETROLEUM, II
NO-MIGRATION PETITION FOR ROBINSON, IL
NO-MIGRATION PETITION FOR SHELL OIL, WA
NO-MIGRATION PETITION FOR SINCLAIR OIL. OK
NO-MIGRATION PETITION FOR STAR ENTERPRISE, OE
NO-MIGRATION PETITION FOR SUN REFINING, OK
NO-MIGRATION PETITION FOR TEXACO, WA
PLACEMENT OF STABILIZED WASTES THAT DO NOT MEET LAND RESTRICTION REQUIREMENTS
STANDARDS FOR AIR PATHWAY FOR METALS ANO ORGANIC CHEMICALS
9553.1986
9553.1986
9513.198?
9555.1990
9554.1987
9502.1986
9551.1986
9551.1988
9489.1988
9551.1967(24
9553.1988 01
9551.1990(16
9551.1966(22
9551.1990114
9554.1990(08
9551,1990(07
9553.1987(11
9553.1988(02
9553.1987 07
9553.1987 01
9441.1987(53
9551.1986(19)
9551.1988 OS)
9483.1906 04
9433.1990(04)
9486.1988(011
9551.1968(15)
9551.1990(04)
9551.1990(13
9551.1990(06)
9551.1991(09
9551.1991(03)
9551.1991(05)
9551.1991 01)
9551.1991 12)
9551.1990(09)
9551.1991(14)
9551.1990(11)
9551.1990 12)
9551.1990(10)
9551.1991(021
9551.1991(08)
9554.1969(02)
9551.1991(04
12/11/86
04/30/66
08/10/67
09/2B/90
02/03/87
06/16/86
06/19/86
06/13/8S
05/18/88
11/30/87
02/28/66
12/01/90
12/30/86
12/11/90
07/31/90
10/14/90
07/16/87
03/08/66
04/27/67
01/12/87
06/29/87
10/30/66
05/30/66
03/16/86
09/24/90
01/02/88
01/21/68
10/03/90
11/08/90
10/24/90
05/29/91
01/29/91
02/05/91
01/03/91
12/10/91
11/06/90
05/01/91
11/07/90
11/08/90
11/07/90
01/17/91
05/29/91
05/05/69
01/30/91
CORROSIVE WASTE
MANIFEST REQUIREMENTS
Notifications
•LAND DISPOSAL RESTRICTIONS
•LAND DISPOSAL RESTRICTIONS
•SOFT HAMMER CERTIFICATIONS/DEMONSTRATIONS
OISPOSAL FACILITY REQUIREMENTS FOR LAND OISPOSAL RESTRICTIONS CERTIFICATION
INTERPRETATION OF 49 CFR 268.7 REQUIREMENTS
LAND OISPOSAL RESTRICTIONS TESTING AND RECORD KEEPING REQUIREMENTS
NOTIFICATION REQUIREMENT WHEN SHIPPING RESTRUCTED WASTES TO A STORAGE FACILITY
9551.1987(19
9551.1988(04
9551.1966(13
9551.1907(07)
9554.1988(03)
9551.1988(03)
9551.1987(20)
09/30/67
05/30/6#
11/30/88
03/10/67
05/13/68
05/13/08
10/28/87
-------
KEYWORD INDEX
THIRD THIRD LANO DISPOSAL RESTRICTIONS FINAL RULE
Treatment Standards
•AMENDMENTS TO PART 262 HAZARDOUS WASTE DETERMINATION AND RECORDKEEPING REQUIREMENTS
•CALIFORNIA LIST
•DELETION OF LAND OISPOSAL RESTRICTED WASTE
•DILUTION TO MEET TREATMENT STANDARDS
•F00I-F005 WASTEWATER DEFINITION
•LAB PACKS - LANO DISPOSAL RESTRICTIONS
•LAND DISPOSAL PROHIBITION
•LAND DISPOSAL RESTRICTIONS - FIRST THIRO
•LAND DISPOSAL RESTRICTIONS - HAIOGENATEO ORGANIC CARBONS
•METHANOL TREATMENT STANDARDS
•POINT OF GENERATION - LANO OISPOSAL RESTRICTIONS
•SOFT HAMMER CERTIFICATIONS/DEMONSTRATIONS
•TREATED WASTES - MAXIHIM CONCENTRATIONS
•VARIANCE FROM A TREATMENT STANDARO
AUTHORIZATION OF STATE PROGRAMS TO IMPLEMENT LAND DISPOSAL RESTRICTIONS PROGRAMS
BIAS CORRECTION APPLIED TO THE TCLP
CADMIUM WASTES FROM MILITARY COATING MATERIALS
CALIFORNIA LIST HOC LAND BAN REGULATIONS
CERTIFICATION/NOTIFICATION FOR MULTIPLE-CONSTITUENT WASTES SUBJECT TO LOR«
CLASSIFICATION OF LEACHATE CONTAMINATED GROUNDWATER
CONTAMINATED SOIL AND DEBRIS TREATED REPLACEMENT UNDER A TREATABILITY VARIANCE
DOOl CHARACTERISTIC WASATES - LAND OISPOSAL RESTRICTIONS
F024 REVISED TREATMENT STANDARDS
GENERATION AND TREATMENT OF K044 WASTE
KOOl, P093. AND U059 CONTAMINATED SOIL TREATMENT STANDARDS
LAND DISPOSAL RESTRICTIONS HEARING ON FEB 24. 198S RESPONSES
LANO OISPOSAL RESTRICTIONS REGULATION OF CYANIDES
LOR DETERMINATION OF WASTE STREAM DILUTION
LOR RULES REGARDING ALTERNATIVE TREATMENT STANDARDS FOR LAB PACKS
LEAD AND ARSENIC WASTES TREATMENT STANDARDS
LEAD-BEARING WASTES TREATMENT STANDARDS
LEADED PAINT SANDBLASTING WASTE TESTING USING TCLP
MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND OISPOSAL RESTRICTIONS
NO-MIGRATION PETITION FOR ATLANTIC REFINING » MARKETING. PA
PRETREATMENT OF CHARACTERISTIC WASTES SUBJECT TO LAND DISPOSAL RESTRICTIONS
RECYCLING OF K061 AS AN INGREDIENT IN CEMENT
SLUOGE CONTAINING 1,1,i-TRICHLOROETHANE ITCE)
SOLVENT LISTINGS ANO LAND DISPOSAL RESTRICTIONS
SUBMARINE REACTOR COMPARTMENTS - LANO OISPOSAL RESTRICTIONS
SW-846 TEST METHODS
TREATMENT OF RADIOACTIVE WASTES AT HAZARDOUS WASTE PERMITTED TSOF
TREATMENT STANDARDS ANO THE SEVILLE EXCLUSION
TREATMENT STANDARDS FOR CERTAIN MIXED RADIOACTIVE WASTES
VOLUNTARY TREATMENT PRIOR TO LANO DISPOSAL
WASTE ANALYSIS REQUIREMENTS IN INCOMING WASTE SHIPMENTS-LOR
WASTE CODES AND TREATMENT RESIDUES
WASTE TREATMENT FACILITIES ACCEPTING F006 ELECTROPLATING WASTES
LANO TREATMENT
(See Land Disposal Facilities)
9551.1991(13) 12/20/91
9451.1991(021
9554.1967(03
9551.1988(02
9554.1986	05
9441.1990(16>
9554.1990(01
9551.1986(08
9551.1988(10
9553.1987(13
9554.1990(04
9554.1990 12
9551.1988(13
9554.1986(03
9433.1986(24
9541.1986(13
9442.1990(02
9441.1990(11
9554.1989(04
9551.1991(10
9554.1991(02
9551.1990(05
9554.1990(02
9554.1990(05
9551.1988(13a)
9554.1990(09)
9S54.1986(01)
9554.199101
9551.1990(06)
9554.1990(13)
9554.1990(11)
9554.1990(06)
9442.1991(01)
9554.1990(08)
9551.1991(06
9551.1990(031
9441.1990(03)
9551.1987(13)
9444.1987(18)
9554.1990 07)
9554.1991(04
9525.1990(02)
9554,1990 10
9554.1990(14)
9553.1987(03)
9551.1987	10
9554.1990 03
9554.1988(05)
03/01/91
07/30/87
05/30/88
12/30/86
06/30/90
01/30/90
07/30/86
09/30/88
09/30/87
03/07/90
08/30/90
11/30/88
12/30/86
12/30/86
06/24/86
11/08/90
04/12/90
11/28/89
06/05/91
01/01/91
10/09/90
02/22/90
06/25/90
11/04/88
08/13/90
03/27/86
01/08/91
10/14/90
11/20/90
08/24/90
06/25/90
01/08/91
07/31/90
04/22/91
09/30/90
02/13/90
06/26/87
05/20/87
07/30/90
12/01/91
10/17/90
06/23/90
12/27/90
01/20/87
06/12/87
03/07/90
08/11/88
XREF
/ /
-------
KEYWORD INDEX
LANDFILL
(See Land Olsposal Facilities)
LANDFILL GAS
XREF
/ /
(Sea Land Dlipoial Facilities)
LARGE VOLUME HASTE
XREF
/ /
O
(See Mining Wastes)
LEACHATE
(Sea alto Appendix VIII)
*MULTISOURCE LEACHATE (F039) WASTE CODE AS IT APPLIES TO CONTAMINATION FROM SPILLS
•TREATMENT TANKS FOR LEACHATE OR LIQUID WASTES
CLASSIFICATION OF LEACHATE CONTAMINATED GROUNDWATER
DELISTING CHITERIA/LCACHATE LEVELS
DETECTION LIMIT FOR EP-LEACHATE CONCENTRATION OF SELENIUM
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND L1STEO WASTES - LEACHATE LEVELS
GROUNDWATER CONTAMINATED WITH HAZARDOUS WASTE LEACHATE
LEACHATE AND PRECIPITATION RUN-OFF AT LFi. WASTE PILES, AND LT UNITS, HAZARDOUS WASTE FROM MIXTURE OF
LEACHATE FROM A MUNICIPAL LANDFILL, REGULATION OF
SURFACE IMPOUNDMENT RECEIVING LEACHATE, REGULATION OF
~
LEACHATE COLLECTION/DETECTION SYSTEM
(See Minimum Technology Requirements)
XREF
XREF
9444.1991(06)
9471.1984101I
9554.1991(02)
9433.1986(01
9443.1986(06)
9441.1906(03)
9441.1986(83)
9441.1984(37)
9441.1983(08)
9484.1985(010
XREF
/ /
11/01/91
03/30/64
01/01/91
01/07/86
03/12/86
01/07/86
11/13/86
11/14/84
10/21/83
11/14/85
/ /
LEAD
(Sea Characteristic Hazardous Waste)
LEAK DETECTION
XREF
/ /
(See Secondary Containment)
LEAKAGE
(See Secondary Containment)
XREF
XREF
LIABILITY
/ /
/ /
(See Financial Responsibility)
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
LIABILITY COVERAGE
(Set Financial Responsibility)
LIHERS
XREF
/ /
(See Minimum Technology Requirements) (See alto Land Disposal Facility)
LIQUID WASTE
XREF
/ /
c?
(See also Land Disposal Restrictions, Characteristic Hazardous Waste)
HiqUlOS AND FREE LIQUIDS, DEFINITION OF
*PH TESTING OF SOLID/WATER MIXTURE
•TREATMENT TANKS FOR LEACHATE OR LIQUID WASTES
BAN ON DISPOSAL OF LIQUIDS IN LANDFILLS
CLOSURE 1 POST-CLOSURE REQUIREMENTS REGAROING HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES
CONTINUED LANDFILL OISPOSAL OF LAB PACKS
CORROSIVE CHARACTERISTIC APPLIEO TO LIQUID ANO AQUEOUS WASTES
DETERMINATION OF THE IGNITABILITY CHARACTERISTIC
DISTILLATION BOTTOM TARS AS K022 WASTE
IGNITABILITY OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITION
LIQUID AS IT APPLIES TO 1GNITABLE Oft CORROSIVE WASTES
LIQUID HAZARDOUS WASTES IN LANDFILLS
LIQUID WASTE, DEFINITION OF
LIQUID. FREE LIQUIO. RELEASABLE LIQUID DEFINITIONS
NONHAzArDOUS LIQUID WASTEWATERS AND SLUDGES IN SANITARY LF UNDER RCRA AND HSWA, DISPOSAL OF
PLACEMENT OF BULK LIQUIDS IN LANDFILL
* SCINTILLATION COCKTAIL,.REGULATION OF LIQUID
SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY
WASTE AS LIQUID OR SOLID, DETERMINATION OF
Absorbents
•ADDING ABSORBENT TO WASTE CONTAINERS
*LAB PACK AT GENERATOR SITES
ABSORBENTS FOR CONTAINERIZED LIQUID HAZARDOUS WASTES. USE OF
BULK LIQUIO HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTS
COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-846 METHODS, WASTE IDENTIFICATION
CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN RCRA LANOFILLS
POSITION PAPER ON SPENT ABSORBENT MATERIALS
PROHIBITION ON PLACING LIQUIDS IN LANDFILL
Bulk Liquids
•STORAGE PRIOR TO RECYCLING
BULK LIQUID HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTS
BULK LIQUIDS ANO DRAIN/LEACHING FIELDS
CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN RCRA LANDFILLS
PCB-CONTAMINATED WASTES, STABILIZATION OF
PLACEMENT OF STABILIZED WASTES THAT DO NOT MEET LAND RESTRICTION REQUIREMENTS
PROHIBITION ON PLACING LIQUIDS IN LANDFILL
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
Non-Hazardous Liquids
BAN ON USE OF LIQUIDS IN LANDFILLS
XREF
9432.1965(03)
9443.1983 03
9471.1984(01I
9467.1985 03
9476.1983 02
9407.1985(02)
9443.1987 17
9443.1991 01
9444.1989(041
9432.1990 01
9441.1989 51
9487.1985(04)
9432.1981(01)
9432.1989(04)
9574.1985 01
9487.1984(05)
9443.1987(18)
9441.1969(34)
9445.1964(06)
9453.1990(02)
9453.1988102
9487.1985(05
9487.1987(01
9445.1987103a)
9487.1986(12
9441.1991(09
9487.1965(10
9475.1987(01
9487.1987(01
9487.1986 09
9487.1986(12
9487.1988(01
9554.1989(02
9487.1985(10
9523.00-14
/ /
05/30/85
02/28/63
03/30/84
05/20/85
01/11/83
05/10/85
08/16/87
09/06/91
07/13/89
02/16/90
10/05/89
08/07/85
06/28/81
07/20/89
01/22/85
11/12/84
08/19/87
07/06/69
07/30/84
07/30/90
01/30/88
09/20/85
01/20/87
11/17/87
12/30/86
06/21/91
12/05/85
04/30/87
01/20/67
06/12/86
12/30/86
02/03/68
05/05/89
12/05/85
03/14/86
9487.1986(07) 04/27/86
-------
Ho.
01/92
KEYWRO INDEX
LISTED HAZARDOUS WASTE
o
r*
(Set alas Solid Waste, Delisting, Characteristic Hazardous Waste, Hazardous Wast* Identification, Oloxln)
^DELISTING BY STATES
•HAZARDOUS WASTE LISTED SOLELY FOR SUBPART C CHARACTERISTICS
AUTOMOTIVE FLUIDS, REGULATION OF
CARBON REGENERATION FACILITIES
CHEMICAL AGENTS G8, VX. AND HX AT MUNITIONS DISPOSAL FACILITY
DELISTING CRITER IA/LEACHATE LEVELS
ELECTRIC ARC FURNACE DUST AFTER ENCAPSULATION TREATMENT PROCESS
ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTS
ETCHANTS USED TO MANUFACTURE COPPER SALTS
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
FEDERAL POLICY REGARDING OIOXIN DISPOSAL
K006 WASTE ANO ONSITE OISPOSAL UNIT CONTAINING THESE WASTES
K03S LISTING ANO INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS
LDSO AS CRITERIA FOR LISTING HAZARDOUS WASTE
LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENT
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER
MECHANICAL PLATING WASTES IN THE F006 LISTING. NON-INCLUSION OF
MIXTURE OF CHARACTERISTIC WASTE AND LISTED WASTE, ASH FROM INCINERATION
MIXTURES OF SOLID ANO HAZARDOUS WASTES
MIXTURES OF SOLIO WASTE ANO A WASTE LISTED SOLELY BECAUSE IT EXHIBITS A CHARACTERISTIC
PETITION TO WITHDRAW K090 AND K091 LISTINGS
PETROLEUM FACILITIES INCLUDED IN THE K05S LISTING FOR API SEPARATOR SLUDGE
PROCESS WASTES CONTAINING INKS, PAINTS, AND ADHES1VES
RECYCLEO CHARACTERISTIC HAZARDOUS WASTE SLUDGES
RELISTING HAZARDOUS WASTE
RESPONSE TO REGION HI IMPLEMENTATION AND OVERSIGHT ISSUES
SCINTILLATION COCKTAIL. REGULATION OF LIQUIO
SCRAP DEHP AND SMALL CAPACITORS CONTAINING DEHP. OISPOSAL REQUIREMENTS FOR
SCRUBBER BRINE/SLUDGE PRODUCED IN INCINERATION OF A LISTED HAZARDOUS WASTE
SLUDGES GENERATED FROM THE FIRST CLEANING STAGES OF PHOSPHATING PROCESS
SOLVENTS USED AS REACTANT ANO SOLVENT WASTES GENERATED BY A PRODUCTION PROCESS
SPENT FLU1DIZED BED MEDIA AND CHANGES UNDER INTERIM STATUS
SPENT SOLVENT MIXTURE (NALCAST 6015/WATER/WAX1
TOLUENE-CONTAINING PAINT PRODUCTS FROM WOOD PIECES. REGULATORY STATUS
USED OIL, BURNING OF OFF-SPECIFICATION FUEL - OUMPlNG
WASTE COOE LISTINGS AND TECHNICAL CORRECTIONS
WASTE FROM ELECTROLESS PLATING PROCESS NOT COVERED UNDER REINTERPRETATION OF F006 LISTING
Chior!nation Tank
ORAGOUT FROM F007
SPENT CYANIDE PLATING BATH SOLUTIONS
Connerclal Chemical Products
•BURNING/BLENDING OF UNUSED COMMERCIAL CHEMICAL PRODUCT (ZYLENE) WITH USED OIL
'DISCARDED MERCURY THERMOMETERS
•F006 SLUDGE FROM ACID WASTE MIXTURE
•HAZAROOUS WASTE FUEL IN INCINERATORS
*LANO OISPOSAL RESTRICTIONS - HALOGENATEO ORGANIC CARBONS
•METHYL CHLOROFORM
•OFF-SPECIFICATION CIRCUIT PRINTING BOARDS - REGULATORY STATUS
•SOLVENT MIXTURE RULE
•SPILLS OF COMMERCIAL CHEMICAL PRODUCTS
BATTERY RECONDITIONING
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY
XREF
9541.1986(24
9441.1986 74
9441.198? 14
9441.1986 26
9443.1984(03
9433.1986(01
9444.1936(33
9444.1906(07
9441.1986(82
9441.1986 03
9444.1987(26
9432.1987(09
9444.1987(52
9443.1988(09
9442.1986(04
9441.1986(73
9444.1986	13
9441.1985(32
9441.1987106
9441.1985(38
9444.1989(11
9444.1987(20!
9441.1987(09
9441.1985(39
9442.1986(08
9541.1986(10
9443.1987(18
9441.1985(23
9441.1984(05
9444.1986(11
9444.1986(27
9444.1986(28
9444.1985(15
9443.1988(01
9441.1986(40
9444.1989(12
9444.1987
un
9442.1985(01
9444.1989(09
9441.1987(11
9441.1986(87
9553.1987(13
9444.1984
9441.1991
9441.1987
9444.1989
9441.1986(56
9441.1986(95
l7\
14)
18)
141
10/30/86
09/30/86
03/06/87
04/02/86
06/04/84
01/07/86
12/29/86
04/07/86
11/08/86
01/07/86
07/02/87
08/19/87
12/11/87
09/09/88
05/06/86
09/25/86
06/24/86
10/07/85
01/27/87
11/20/85
10/03/89
05/26/87
12/19/87
11/25/85
08/21/86
05/01/86
08/19/87
06/27/85
02/19/84
05/22/86
12/05/86
12/05/86
06/24/85
01/04/08
07/31/86
10/05/89
12/04/87
9444.1984(14J 07/30/84
12/30/85
08/30/89
02/28/87
11/30/86
09/30/87
08/30/84
08/01/91
03/30/87
11/30/89
07/28/86
12/23/86
-------
Page No.
04/06/92
KEYWORD INDEX
c >
(K
CARBON SCRUBBER WASTE IN WHICH PRODUCT MATERIALS ARE CAPTURED	9444.1987(15
CHLORDANi AND HEPTACHLOR PESTICIDE WASTE	9444.1988(10
COMMERCIAL CHEMICAL PRODUCT P LISTING APPLIES ONLY TO UNUSED PRODUCT, NOT USED	RESIDUES 9444.1986(29
COMMERCIAL CHEMICAL PRODUCTS UNDER 261.33	9444.1980(01
COMMERCIAL CHEMICAL PRODUCTS USED IN AIR BAGS - EFFECT ON RECYCLE OF FERROUS	SCRAP FROM AUTOMOBILES 9441.1965(02
COMMERCIAL CHEMICAL PRODUCTS. RECYCLING A MIXTURE OF	9441.1986(34
CONTAINERS THAT HELD COMMERCIAL CHEMICAL PRODUCTS, DEFINITION OF EMPTY	9441.1984 26
CONTAINERS USED TO HOLD LISTED CHEMOTHERAPY DRUGS	9441.1967(45
COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL	FERTILIZER 9493.1966(01
CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PRODUCTS, REACTIVE WASTES DEF1NE0	9443.1904 09
OIMETHYL BENZENE-LISTING CLARIFICATION	9444.1990(03
OISCARDED COMMERCIAL CHEMICAL PRODUCTS	9444.1988 12
01 SCARDEO COMMERCIAL CHEMICAL PRODUCTS	9444.1985 OS
DRAGOUT FROM F007 - SPENT CYANIDE PLATING BATH SOLUTIONS	9444.1984 14
ELECTROLESS 21NC PLATING WASTE NOT IN F006 LISTING	9444.1987 23
ELECTROPLATING RINSIWATERS	9442.1987 03
EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCT	9441.1985(41
EXEMPTION FOR COMMERCIAL CHEMICAL PRODUCTS BURNED FOR ENERGY RECOVERY	9441.1988(33
EXEMPTION FOR COMMERCIAL FERTILIZERS 0f(CE THE FERTILIZER IS PRODUCED	9493.1986 03
F SOLVENT WASTES	9444.1985(03
F006 LISTING DOES NOT INCLUDE ZINC PHDSPHATING WASTEWATER TREATMENT SLUDGES	9444.1967 27
FOOS LISTING FOR PICKLING ANO ETCHING WASTES AND DELISTING ISSUES	9444.1987(55
F019 LISTING AND THE CONVERSION COATING PROCESS	9444.1967(22
FLOATING PLASTIC BALLS USED TO CONTROL VAPORS FROM TANKS CONTAINING LISTED PRODUCT WOULD BE HAZARDOUS WASTE	9444.1986(25
F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPHENOLIC COMPOUNDS	9444.1987(42
HAZARDOUS WASTE LISTING FOR F006 WASTE	9441.1986(76
LABORATORIES, RCRA REGULATION IMPACT	9441.1990(32
LUBRICATING OIL AND JET FUELS USED TO PRODUCE PETROLEUM PRODUCTS	9494.1965(01
MANUFACTURING WASTE CONTAINING COMMERCIAL CHEMICAL PRODUCTS IN 261.33	9444.1981 01
MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS	9444.1987(40
MERCURY SUITABLE FOR DIRECT USE (99X PURE) NOT SOLID WASTE	9441.1986 43
MERCURY THERMOMETERS, RECLAIMEO OFF-SPEC AND BROKEN	9441.1966 27
METAL FINISHING SLUDGES	9444.1968 01
MICRO-CLEAR REGULATORY STATUS	9444.1990(02
MIXED SOLVENT WASTES	9444.1968(02
MIXTURE OF F003 AND A SOLID WASTE AND DELISTING REQUIREMENTS	9441.1987 65
OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITY	9441.1969(49
OFF-SPECIFICATION JET FUEL BURNED AS KEROSENE FUEL	9441.1966 19
OFF-SPECIFICATION JET FUELS. RECYCLING OF UNUSED	9441.1989(39
P AND U-LISTED WASTES	9444.1989(07
PAINTS CONTAINING SOLVENTS	9444.1966 11
PERCHLOROETHYLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAINING	9441.1965(10
PESTICIDE APPLICATOR WASHING RINSE WATER	9441.1965 42
PLASTIC PACKING MEDIA FROM AIR STRIPPING TOWER TREATING CONTAMINATED GROUNDWATER	9441.1969 17
RECYCLED GASOLINE/WATER AND FUEL OIL/WATER MIXTURES	9441.1986 22
RECYCLING OF ELECTROPLATING SLUDGES 1F006) FOR CEMENT/AGGREGATE MANUFACTURE	9441.1989 19
SOIL CONTAMINATED WITH CHLOROANE AS A RESULT OF PESTICIDE APPLICATION	9444.1966(20
SOLVENT ANO COMMERCIAL CHEMICAL PRODUCT WASTE STREAMS	9444.1909(03
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER	9441.1988 49
SOLVENTS USEO AS REACTANT AND SOLVENT WASTES GENERATEO BY A PRODUCTION PROCESS	9444.1966(27)
SOLVENTS USED AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL	PRODUCT 9441.1986(92
SPENT PIPELINE FILTER CARTRIDGES	9444.1988 03
STILL BOTTOM WASTE GENERATEO BY A POLYSTYRENE PRODUCTION FACILITY	9432.1988(01
TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMINATED OR RADIOACTIVE LEAD	9441.1967(52)
USEO REFRIGERANTS UNOER 40 CFR 261.2	9441.1990(28
WASHWATERS GENERATEO FROM WASHING PESTICIDE APPLICATOR TRUCKS	9441.1986 44
WASTE GENERATEO BY AN INCINERATOR TRIAL BURN OF SAND SPIKEO WITH TRICHLOROBENZENE AND HEXACHLOROETHANE	9441.1988 04
05/16/67
05/03/68
12/08/86
09/04/80
01/16/65
04/28/66
09/11/64
06/16/87
01/22/86
11/29/84
04/05/90
05/19/66
05/14/65
07/30/64
06/30/87
07/28/87
12/12/65
07/27/88
06/21/86
04/01/85
07/06/87
12/26/87
06/24/87
11/03/66
09/23/67
10/12/86
11/28/90
10/01/65
03/12/81
09/09/87
05/30/86
04/02/86
01/11/68
03/22/90
01/22/88
08/17/87
09/28/89
03/08/66
07/31/69
08/21/89
05/05/88
04/10/85
12/13/85
04/14/89
03/19/66
04/26/89
09/29/86
06/28/89
12/06/86
12/05/66
12/05/66
02/11/88
02/11/88
06/26/87
10/18/90
05/30/86
01/14/66
-------
Page No,
04/06/92
\
KEYWORD INDEX
< >
<>"
WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS - MERCURY
' WASTES CONTAINING F001-F005 CONSTITUENTS
WASTES COVERIO UNDER THE DIOXIN LISTING
WASTES FROM BRIGHT PIPPINS UNDER THE REINTERPRETED F006 LISTING
WASTEWATER TREATMENT SLUDGE EXEMPTION FOR ANODIZING Of ALUMINUM
WASTEWATER TREATMENT SLUDGES FROM ELECTROPLATING OPERATIONS
WASTEWATER TREATMENT SLUDGES RESULTING FROM METAL CLEANING PROCESS
Definition
TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HA2AR00US WASTE
F-Vastes
•COMPARATIVE DEFINITIONS OF FOOI AND F002
'DILUTION OF F003 WASTES
•F006 SLUDGE FROM ACIO WASTE MIXTURE
'MANUFACTURING PROCESS UNITS
*MULTISOURCE LEACHATE (F039) WASTE CODE AS IT APPLIES TO CONTAMINATION FROM SPILLS
•PROHIBITION ON STORAGE OF RESTRICTED WASTES
•RECLAIMEO SPENT WOOD PRESERVATIVE EXCLUSION IN 261.4(a)(9)
•SOLVENT MIXTURE RULE
•SPENT SOLVENT LISTINGS
•SPENT SOLVENT MIXTURES (F-WASTES)
•SPENT SOLVENTS FROM VARNISH STRIPPING
•WASTEWATER TREATMENT SLUDGE FROM CHEMICAL ETCHING
•WOOD PRESERVING WASTES - ADMINISTRATIVE STAY
ACETONE AND METHANOL CONTAMINATED WASHWATERS
ACTIVATED CARBON CANISTERS SATURATED WITH SPENT SOLVENTS
ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED DURING PAINT APPLICATION
CERTIFICATION/NOTIFICATION FOR MULTIPLE-CONSTITUENT WASTES SUBJECT TO LORi
CHARACTERISTIC HAZARDOUS WASTE OR SOL10 WASTE TREATMENT MAY CREATE A LISTED HAZARDOUS WASTE
CHLOROFLUOROCARBONS (CFCs) AS REFRIGERANTS, RECYCLING OF SPENT
CLEAN SOLVENT FROM RECYCLED SOLVENT-CONTAINING WASTE - STILL BOTTOMS
CLOSURE PLAN FOR THE HAZARDOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT
CYANIDE-SALT CONTAINING WASTES IN METAL HEAT TREATING OPERATIONS
DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOL
DISCARDED WASTEWATER AT A CORROSION CONTROL FACILITY
DRAFT SAMPLING AND ANALYSIS PLAN FOR NM PLATING COMPANY
ORAGOUT FROM F007 - SPENT CYANIDE PLATING BATH SOLUTIONS
DRYCLEANING INDUSTRY WASTES
ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE F006 LISTING
ELECTROLESS ZINC PLATING WASTE NOT IN F006 LISTING
ELECTROPLATING RINSEWATERS
F003 10X RULE AND ASSOCIATED REGULATIONS
F005 LISTING FOR PYRIDINE STILL BOTTOMS
F006 AND F019 ELECTROPLATING LISTINGS
F006 LISTING ANO DEFINITION OF CONVERSION COATING
F006 LISTING APPLIED TO PRINTING INDUSTRY
F006 LISTING FOR PICKLING AND ETCHING WASTES AND DELISTING ISSUES
F006 WASTES. VHS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION FOR
F009 LISTINd AND THE MIXTURE RULE TO ELECTROPLATING RINSEWATERS AND RESINS
F009 LISTING FOR ELECTROPLATING AFTER CYANIDE BATH
F019 LISTING AND THE CONVERSION COATING PROCESS
F019 LISTING APPLICABILITY TO WASTEWATER TREATMENT SLUDGES
F019 LISTING FOR WWT SLUDGES IN ALUMINUM ANODIZING
F024 REVISEO TREATMENT STANDARDS
F027 LISTING-USED AND UNUSED FORMULATIONS IN WOOD PRESERVING
HAZARDOUS WASTE LISTING FOR F006 WASTE
9441.1988!
9441.19881
9444.1986
9444.1987
9441.1986
9444.1985,
9444.1989}
9444.1991(03
9441.1986(97
9441.1987(11
9441.1987(71
9444.1991(06
9453.1986(06
9441.1991(19
9441.1987(18
9444.1988(09
9443.1986(05
9441.1986(57
9444.1984(02
9409.199103
9444.1969(05
9441.1986(54
9444.1986(00
9551.1991(10
9442.1989(05
9441.1989(40
9441.1987(26
9488.1987(01
9444.1984(01
9444.1985(02
9444.1991(05
9433.1990(06
9444.1984(14
9444.1987(07
9444.1987(03
9444.1987(23
9442.1987(03
9444,1987(30
9444.1987(53
9444.1986	09
9444.1987	09
9444.1987 19
9444.1967(55
9433.1907 09
9444.1987(31
9444.1989(06
9444.1987 22
9441.1909(53
9445.1985(03
9554.1990(05
9444.1987
9441.1966
11/02/88
02/22/88
10/21/86
07/13/87
04/09/86
09/03/85
08/21/89
9441.1988(44) 10/27/88
05/01/91
12/30/86
02/28/87
08/30/87
11/01/91
11/30/86
12/01/91
03/30/87
04/30/88
01/30/86
05/30/86
03/30/84
06/01/91
07/21/89
07/15/86
05/02/86
06/05/91
07/05/89
08/02/89
04/17/87
02/09/87
03/05/84
03/04/85
11/26/91
11/27/90
07/30/84
03/06/87
01/27/87
06/30/87
07/28/87
07/21/87
12/15/87
05/02/86
03/26/87
05/22/87
12/28/87
06/08/87
07/28/87
07/30/89
06/24/87
10/30/89
05/31/85
06/25/90
04/09/8?
10/12/86
-------
Page No.
04/06/92
KEYWORD INDEX
\
INK FORMULATION WASTES AS BOTH K086 ANO F001-00S WASTES
LABORATORY WASTE 6ENERATE0 IN RESEARCH USING TCOO STOCK SOLUTIONS
LAND DISPOSAL RESTRICTIONS CLARIFICATIONS
LAND DISPOSAL RESTRICTIONS REGULATION OF CYANIOES
LOR DETERMINATION OF WASTE STREAM DILUTION
METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS
MIXTURE OF F003 AND A SOLIO WASTE AND DELISTING REQUIREMENTS
MIXTURES OF LISTEO AND CHARACTERISTIC WASTES
NARROWING THE SCOPE OF THE F006 LISTING
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
PAINT RESIDUES ON CONVEYOR HOOKS
PAINT WASTES AND OF THE SPENT SOLVENT LISTINGS
PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATOR
PENTACHLOROPHENOL AS A WOO PRESERVATIVE
PROCESS WASTEWATER FROM METAL DECREASING OPERATIONS
RAGS AND SIMILAR MATERIALS ABSORBING VOLITILES ANO F-WASTES, HANDLING
REINTERPRETATION OF THE F006 LISTING
RESIDUALS MATERIALS CONTAMINATED WITH TRACE SOLVENTS
SLUDGE CONTAINING 1,1.1-IRICHLOROETHANE (TCE)
SOIL CONTAMINATEO WITH PESTICIDE
SOIL CONTAMINATED WITH USED AND UNUSED PESTICIDES
SOLVENT LISTINGS AND LAND DISPOSAL RESTRICTIONS
SOLVENT LISTINGS FOR PAINT WASTES/REMOVER AND SPILL RESIDUE
SOLVENT LISTINGS, SCOPE OF
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER
SOLVENT-CONTAMINATED WASTESTREAMS FROM PHARMACEUTICAL MANUFACTURER
SOLVENTS USED AS COOLANTS AND APPLICABILITY OF SOLVENT LISTINGS
SOLVENTS USEO AS REACTANT NOT LISTEO AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCT
SPENT CARBON USEO TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATER
SPENT ION EXCHANGE RESIN
SPENT ION EXCHANGE RESINS AND FILTER AS HAZARDOUS WASTE
STILL BOTTOMS FROM LISTEO SOLVENT RECLAMATION
TETRACHLOROETHYLENE CONTAMINATED WITH POLYCHLORINATEO BIPHENYLS (PCBs)
UNRINSED CONTAINERS WHICH FORMERLY CONTAINED AN UNUSED FORMULATION OF PENTACHLOROPHENOL
WASTE FROM CHEMICAL ETCHING USING CYANIDE
WASTE LISTINGS F006 ANO K062, SCOPE OF
WASTES CONTAINING FOOl-FOOS CONSTITUENTS
WASTES FROM ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL EXCLUDED FROM F006
WASTES GENERATED FROM EXTRACTION PROCESS
WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER
WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATMENT SLUDGE
WASTEWATER TREATMENT SLUDGES FROM ELECTROPLATING OPERATIONS
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE
WATER WALL SPRAY MOTH WASTES ANO THE SOLVENT LISTINGS
WATER/METHANOL MIXTURE WASTESTREAM
ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL
9444.1987(41;
9444.1906 16
9551.1987(01
9554.1991(01
9551.1990 06
9441.1987 46
9441.1987 65
9441.1967(68
9444.1986(21
9441.1986(21
9443.1980103'
9444,1987(17:
9441.1986	47
9444.1988(15
9553.1988(02;
9441.1989 50;
9444.1986(19
9444.1991(04
9551.1987
9441.1987
9444.1987
9444.1987
9444.1987
9444.1986
9441.1988
9443.1988
9444.1987(02
9441.1986(92
9444.1986(05
9444.1985(11
9444.1987(13)
9444.1987(05i
9444.1989(10 1
9444.1986(03
9444.1987(16
9444.1986(32
9441.1988(05)
9444.1987	14
9442.1986 07
9441.1986 52
9444.1984(10
9444.1985(13
9444.1987(39
9444.1987(06
9443.1985(07
9444.1984(09
09/15/87
08/18/86
01/20/87
01/08/91
10/14/90
06/17/87
08/17/87
08/19/87
10/04/86
03/13/86
12/20/80
05/20/87
06/02/86
08/29/88
03/08/88
10/20/89
09/28/86
08/30/91
06/26/87
04/08/87
04/18/87
05/20/87
04/14/87
11/07/86
12/06/88
12/06/88
01/27/87
12/05/86
03/03/86
06/19/85
05/05/87
02/02/87
09/22/89
02/12/86
05/20/87
12/12/86
02/22/88
05/08/87
07/02/86
07/02/86
07/25/84
09/03/85
09/02/87
02/28/87
09/10/85
06/13/84
Iron Foundry Wast#
FOUNDRY SANOS RECYCLED AND RETURNED TO THE FOUNDRY
GRAY IRON FOUNDRY WASTE DISPOSAL
K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON ANO STEEL INDUSTRY
MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY
RECYCLING OF MOLDING AND CASTING SANDS
9441.1987(13)
9486.198l)01|
9444.1987(081
9441.1986(48)
9441.1986(01)
03/04/87
06/18/81
03/16/87
06/10/86
01/06/86
K-Wastas
•API SEPARATOR SLUDGE, EXCLUSION OF WATER FRACTION FROM K051 LISTING
*BAGHOUSE OUST GENERATED FROM REMELTING PRIMARY PRODUCED STEEL
9441.1984(13)
9444.1984(16)
05/30/84
08/30/84
-------
Pag«
04/01
No.
06/92
KEYWORD INDEX
C7
31a)
•N1NINS WASTE EXCLUSION (^INTERPRETATION	9441.1985(35
•MINING WASTE, K064. AND 3004(x)	9571.1966104
•PROOUCT WASHWATERS FROM DINITROTOLUENE - Kill LISTING	9441.1986(20
ASH RESIOUE GENERATED FRON INCINERATION OF K045	9441.1967 12
CLOSURE STANDAROS FOR HAZARDOUS WASTE LAND TREATMENT UNITS	9476.1991(01
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)	9441.1987(98
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)	9441.1987 75
COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE	9441.1986 68
COMMERCIAL FERTILIZERS CONTAINING K061 WASTES	9493.1986(05
CORRECTED LISTING DESCRIPTION FOR K062	9444.1987
DELISTING PETITIONS FOR K-WASTES HAHAGEO IN ON-SITE LAND-BASIO UNITS-MONITORING REQUIREMENTS	9433.1987(21
DISTILLATION BOTTOM TARS AS K022 WASTE	9444.1989(04
EXCLUSIONS FOR K-WASTES DENIED (LACLEOE STEEL)	9441.1989(481
F006 LISTING DOES NOT INCLUDE ZINC PHOSPHATING WASTEWATER TREATMENT SLUDGES	9444.1987(27)
GENERATION AND TREATMENT OF K044 WASTE	9551.1988"
INK FORMULATION WASTES AS BOTH K086 AND F001-005 WASTES	9444.1987(41
K-WASTE FILTER CAKE IN THE MANUFACTURE OF CEMENT	9441.1990 35
K001-LISTED WASTES FROM WOOD PRESERVING PROCESSES	9445.1985 05
K006 WASTES AND ONSITE OISPOSAL UNIT CONTAINING THESE WASTES	9444.1987(37
K035 LISTING AND DELISTING ISSUES:GROUNDWATER CONTAMINATION	9433.1987 27
K051 SLUDGE RE-USED ON-SITE. EXEMPTION	9494.1985 02
K052 LISTING FOR WASTES GENERATED IT PETROLEUM 1N0USTRY	9444.1981 03
K061 HAZARDOUS WASTE LISTING FOR STEEL F0UN0R1ES	9444.1980 06
K061, EMISSION CONTROL DUST/SLUDGE FROM PRODUCTION OF STEEL IN ELECTRIC FURNACES	9444.1983(02
K062 - SPENT PICKLE LIQUOR LISTING	9444.J984 11
K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRY	9444.1987(08
K103/K104 WASTE STREAMS - RELATIONSHIP OF CWA BAT, LAND OISPOSAL RESTRICTIONS, BOAT, AND DELISTING CRITERIA	9433.1987 06
LAND OISPOSAL OF UNTREATED HAZARDOUS WASTE	9551.1990 04
LIME SLUDGE IMPOUNDMENT SLUDGE. DELISTING OF	9484.1986(05
LIME STABILIZEO WASTE PICKLE LIQUOR SLUDGE EXCLUSION	9441.1987 74
METAL, K061 WASTES IN SURFACE IMPOUNDMENT-OELISTING PETITION	9433.1987 18
NEW JERSEY ZINC COMPANY K061 STORAGE PILE	9481.1988(01
NO-MIGRATION PETITION FOR AMOCO REFINERY	9551.1990 13
NO-MIGRATION PETITION FOR ARCO PROOUCTS, WA	9551.1990(08
NO-MIGRATION PETITION FOR MARATHON PETROLEUM, II	9551.1990 09
NO-MIGRATION PETITION FOR SHELL OIL. WA	9551.1990(11
NO-MIGRATION PETITION FOR SINCLAIR OIL. OK	9551.1990
NO-MIGRATION PETITION FOR STAR ENTERPRISE. OE	9551.1990
OIL/WATER EMULSIONS GENERATED BY PETROLEUM REFINERY WW SYSTEHS-K049 WASTE	9441.1984,
PETROLEUM REFINERY WW, MIXTURE ANO DER1VE0-FR0M RULES	9441.1985(29
PICKLE LIQUOR AND SCOPE OF K062 LISTING	9444.1985(17
PROPOSED BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) FOR K061 WASTE	9441.1988(06
RECYCLING OF ELECTRIC ARC FURNACE OUST	9441.1988(27
RESIDUES FROM SECONDARY LEAD SHELTERS THAT RECYCLE K069 WASTES	9496.1991
SHAH INCINERATION ANO TREATMENT OF K048-K052 WASTES IN CEMENT KILNS AND INDUSTRIAL FURNACES	9494.1991
SPENT PICKLE LIQUOR DELISTING PETITION	9433.1991
SPENT PICKLE LIOUOR. DEFINITION AS HAZARDOUS	9441.1987(39
SPENT PICKLELIQUOR flNAL RULE REGARDING SCOPE OF THE K062 LISTING. CORRECTION NOTICE	9444.1986(31
STAINLESS STEEL PRODUCTION RESIDUES	9441.1988(07
SUPERNATANT FORKED IN LIHE STABILIZATION OF WASTE PICKLE LIQUOR AS HAZARDOUS WASTE	9441.1987(83
SUPERNATANT FROM TREATMENT OF SPENT PICKLE LIQUOR (K062)	9444.1987(47
SURFACE I IMPOUNDMENTS HOLDINB ONLY K-WASTES GENERATCO UN6eR A TEMPORARY EXCLUSION	9433.1987 23
THERMAL OXIDIZER ANO HYDRODECHLORINAT1ON PROCESS BY-PRODUCT K-WASTES	9444.1987 44
USE/REUSE EXCLUSION TO RED WATER (K047) FROM WHICH SOOIUM SULFITE IS RECOVERED AND WHICH IS USED AS A FUEL	9441.1987(42
WASTES GENERATED BY COKE AND COAL TAR PLANTS	9442.1987(02
WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATMENT SLUDGE	9444.1984(10
WASTEWATER TREATMENT SLUDGES.FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOL	9444.1964(04
13a)
12)
10
35)
(01
(02
(02
10/30/85
07/30/86
05/30/88
03/03/87
05/02/91
12/24/87
09/04/87
09/11/86
09/11/86
07/30/87
09/26/87
07/13/89
09/12/89
07/06/87
11/04/88
09/15/87
12/21/90
01/18/85
08/19/87
12/11/87
07/30/85
06/06/81
12/02/80
07/11/83
07/27/84
03/16/87
04/02/87
10/03/90
05/23/86
09/02/87
08/07/87
01/25/88
11/08/90
10/24/90
11/06/90
11/07/90
11/08/90
11/07/90
12/07/84
08/23/85
10/03/85
03/09/88
06/15/88
08/05/91
03/29/91
04/26/91
05/20/87
12/11/86
03/10/88
10/23/87
10/23/87
10/05/87
10/16/87
06/09/87
07/24/87
07/25/84
04/26/84
-------
Paae No.
04/06/92
KEYWORD INDEX
< ¦;?
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
WOO TREATED WITH CREOSOTE, DISPOSAL OF
ZINC OXIDE RECLAIMED FROM KILNS
Off-Spiclflcatlon
•METHYL CHLOROFORM
~NATURAL 6AS PIPELINE CONDENSATE AND ENERGY RECOVERY
BURNING OF USED OIL
P-Wastes
CARBON SCRUBBER HASTES IN WHICH PRODUCT MATERIALS ARE CAPTURED
DELISTING PETITION OF NITROGEN TETROXIDE RINSATE
P ANO U-LI5TED WASTES
P-VASTE LISTING FOR CATALYST
SPENT CARBON REGULATION
Sola Active Ingredient
CHLOROANE ANO HEPTACHLOR PESTICIDE WASTE
DISCARDED COMMERCIAL CHEMICAL PRODUCTS
P-WASTE LISTING FOR CATALYST
PESTICIDE STANDARDS FOR FORHALOEHYOE AND PARAFORMALDEHYDE
PESTICIDES CONTAINING A 261.33(e) COMPOUND AS A SOLE ACTIVE INGREDIENT
Steel Foundries
COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE	,
DELISTING PETITION-STEEL FACILITY, REQUIREMENTS FOR CLOSURE PLAN 1
DELISTING TESTING REQUIREMENTS, CYANIDE ANO OTHER WASTES, STEEL INDUSTRY
K061 HAZARDOUS WASTE LISTING FOR STEEL FOUNDRIES
K062 LISTING APPLIES ONLY TO FACILITY WITHIN THE IRON ANO STEEL INOUSTRY
* PRIMARY ANO SECONDARY PRODUCTION OF STEEL IN ELECTRIC ARC FURNACES
SLUDGE WASTE HANDLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY
WASTE-DERIVEO FUELS AT IRON ANO STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIRED
Toluene
•SOLVENT MIXTURE RULE
•SOLVENT MIXTURE RULE APPLIED TO SPILL OF TOLUENE/BENZENE MIXTURE - CERCLA INTERFACE
FILTER CAKE WASTE CONTAINING SOLVENT USED TO S0LUBIL1ZE PRODUCT
PAINT SPRAY BOOTH AIR FILTERS
RESIDUE FROM STREAM-STRIPPING OF PROCESS WASTE CONTAINING TOLUENE
SOIL CONTAMINATED WITH TOLUENE
STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION
STILL BOTTOM WASTE GENERATED BY A POLYSTYRENE PRODUCTION FACILITY
SUBSTITUTION OF EXTRACTION SOLVENTS FOR METHYLENE CHLORIDE
TOLUENE AS A OILUANT OR CARRIER AND THE SCOPE OF THE FOOS LISTING
TOLUENE-LADEN FILTER RESIDUE GENERATIO FROM AN INK PRODUCTION PROCESS
WASTE INK ANO SOLVENT MIXTURES GENERATED FROM PRINTING FACILITIES
U-Wastes
•METHYL CHLOROFORM
ACRYLONITRILE ASH
CONTAINERS USEO TO HOLD LISTED CHEMOTHERAPY DRUGS
DISCARDED COMMERCIAL CHEMICAL PROOUCTS
MIXED SOLVENT WASTES
MIXTURES OF LISTED AND CHARACTERISTIC WASTES
WASTE GENERATEOWBYTAN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHL0R0BEN2INE ANO HEXACHLOROETHANI
9441.1986(28)
9441.1986 10)
9444.1988(02a)
9444.1984(17)
9443.1987(23)
9495.1985(02)
9444.1987
9433.1990
9444.1989
9444.19B1
9441.1987
151
07
07)
02}
371
9444.1900(10)
9444.1988(12
9444.19811021
9444.1909(02)
9444.1901(05}
9441.1986(68)
9433.1986 07
9433.1904(061
9444.1980(061
9444.1987(08
9444.1906(021
9433.1986(17)
9441.1906(00)
9441.1987
9443.190SI
9444.1907
9442.1990
9441.1984
9445.1965(
9444.1987
9432.1988
9441.1908
9444.1987
9444.1985
9443.1984
18)
11
43
01
10
01
3B
01
25
36
09
08
9444.1984(17)
9444.1985(12)
9441.1987 45)
9444.1985(05)
9444.1988(02)
9441.1987(68
9444.1989(07)
9441.1988(04)
04/07/86
02/11/86
01/26/00
08/30/84
10/30/87
10/17/89
05/18/87
12/21/90
08/21/89
06/19/81
05/18/87
05/03/88
05/19/88
06/19/81
03/14/89
09/18/81
09/11/86
03/18/86
12/18/84
12/02/80
03/16/87
01/27/86
09/30/86
01/24/86
03/30/87
11/30/85
10/09/87
05/03/90
05/15/84
04/05/05
09/01/07
02/11/88
06/09/88
08/17/87
06/03/05
11/23/84
08/30/84
05/30/85
06/16/87
05/14/85
01/22/88
08/19/87
08/21/89
01/14/88
-------
Page No.
04706/92
\
\
KEYWORD INOEX
Wastewater Treatment Sludge
•F006 SLUDGE FROM ACID WASTE MIXTURE
•MIXTURE EXCLUSION
•PETROLEUM REFINERY WASTEWATER TREATMENT SLUDGE CLASSIFICATION
DELISTING PETITION - FUJI PHOTO FILM WASTEWATER TREATMENT SLUDGE
METAL FINISHING SLUDGES
PETROLEUM REFINERY SLUDGE REGULATIONS
SURFACE IMPOUNOMENTS/LAND TREATMENT UNITS REGULATION IF ASSOCIATEO WWT SLUDGES ARE LISTEO
WASTEWATER TREATMENT SLUDGES RESULTING FROM METAL CLEANING PROCESS
9441.1967(11
9441.1990(34
9444.1991(01
9433.1991 01
9444.1988	01
9444.1990 05
9460.1985(02
9444.1989	00
62mm
11/01/90
02/01/91
03/07/91
01/11/68
10/17/90
07/17/65
08/21/69
LOCATION
(See SI ting)
LOSS OF INTERIM STATUS
XREF
/ /
(See Interim Status) (Sea alio Permit Process)
LOW LEVEL WASTE
XREF
/ /
(See Mixed Wastes)
MAJOR HANDLERS
XREF
/ /
MAJOR HANOLERS OF HW - DEFINITION
MANIFEST
(Sea Generator) (See also Transporter, OOT, Waste Minimization)
MANUFAC1UR1NG PROCESS UNITS
9522.1983(02) 07/11/83
XREF
/ /
MARKETER
MERCURY
METALS
(See Hazardous Waste Identification)
(See Used Oil)
(See Hazardous Waste Identification)
XREF
XREF
XREF
/ /
/ /
/ /
(See also Hazardous Waste Identification)
METALS PRODUCTION WASTES, APPLICABILITY OF MINING WASTE EXCLUSION - COMBUSTION OF WASTES AS INCINERATION
SLUDGE WASTE HANOLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY
XREF
9441.1965(05}
9433.1986(17)
/ /
02/04/85
09/30/86
-------
1
Pag® Ho.
04/06/92
KEYWORD INDEX
MINERAL PROCESSING
ISm also Mining Wastes)
RON AND STEEL SLAGS IN MINERAL PROCESSING WASTES REPORT
MINERAL PROCESSING FACILITIES. REPORT TO CONGRESS
MINING WASTE EXCLUSION INCLUDING PRIMARY PROCESSING BUT NOT SUBSEQUENT STEPS
MINIMUM SHELL THICKNESS
XREF
944t.t99l.f07
9475.1989 01
9441.1906(81
/ /
05/30/91
02/09/89
I1/03/86
(Sea Tank System)
MINIMUM TECHNOLOGICAL REQUIREMENTS (MTR)
XREF
/ /
(Sea also Compatibility, HSWA, Release, Surface Impoundnent, Land Olsposal, TSOF)
¦EXISTING UNITS ANO MINIMUM TECHNOLOGY STANDARDS
*LOR REQUIREMENTS DURING NATIONAL CAPACITY VARIANCE
ABOVE-GROUND LANO EMPLACEMENT FACILITIES, N.J. LAW
COMBINED NRC-EPA SITING GUIDELINES FOR DISPOSAL OF COMMERCIAL MIXEO LOW-LEVEL RADIOACTIVE ANO HAZARDOUS WASTE
EXISTING UNITS UNDER HSWA-APPLICABILITY OF MTR TO EXPANSIONS
MINIMUM TECHNOLOGICAL REQUIREMENTS WAIVER PETITION SECTION 3004(0)12) (SHELL OIL)
MTR COMPLIANCE DATES FOR SURFACE IMPOUNDMENTS (THERMEX ENERGY)
REPLACEMENT UNIT, DEFINITION. FOR SURFACE IMPOUNDMENT
SURFACE IMPOUNDMENT RETROFITTING REQUIREMENTS
TC RULE HAZARDOUS WASTE DETERMINATION
VERTICAL EXPANSION AT U.S. ECOLOGY'S TRENCH 10, BEATTY, NEVADA FACILITY
«
Double Liner
~RETROFITTING INTERIM STATUS SURFACE IMPOUNDMENTS
STANDAROS AGAINST WHICH A 3004(0)(2) EQUIVALENCY PETITION SHOULD BE CONPARED-OOUBLE LINER
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWEO FOR CLOSURE
UCAPCO APPLICATION FOR A VARIANCE UNDER 3004(c)(2) of RCRA
Leachate Collection/Detection System
LINER/LEACHATE COLLECTION SYSTEM COMPATIBILITY
SECONDARY LEACHATE COLLECTION AND REMOVAL SYSTEMS - FML TOP LINERS
SOLIOTEK LANDFILL/LINER DESIGN
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWEO FOR CLOSURE
UCAPCO APPLICATION FOR A VARIANCE UNDER3004(c)(2) OF RCRA
Liners
* LINER DESIGN CRITERIA
•EXISTING SURFACE IMPOUNDMENTS WITH LINERS
•LEAK NOTIFICATION AT A DOUBLE-LINED SURFACE IMPOUNDMENT
•RETROFITTING FOR PERMITTEO SURFACE IMPOUNDMENTS
•WASTE PILE LINERS - MTR (264.251)
CONSTRUCTION OF A NEW LANDFILL CELL ANO THE OMNIBUS PROVISION
OESIGN AND OPERATING STANDARDS
HSWA MINIMUM TECH REQUIREMENTS FOR LINERS AND LEACHATE COLLECTION SYSTEMS
LINER DESIGN COMMENTS (CWN, EMELLE.AL)
XREF
9487.1906(14
9551.1990(16
948M9B6 04
9480.00-14
9432.1985(04
9522.1966 03
9484.1987(11
9521.1987(01
9484.1987(01
9484.1986(01
9484.1987 02
9441.1991(12
9487.00-9
9528.1988(03)
9487.19861
9523.00-12
9484.00-5a
9480.1987(02)
8(03)
9487.1986(10
9484.1987 03
9487.1985(08
9523.00-12
9523.00-14
9484.00-Sa
9480.1987(02)
94B7.1985(Q4a)
9522.1984(02)
9484.1985(02)
9484.1987 09)
9485.1985(01)
9528.1986(01)
9487.1984(03)
9480.1985(01)
9487.1984(01)
/ /
12/30/86
12/01/90
03/26/86
03/13/89
08/30/85
04/28/88
08/07/87
08/07/87
03/11/87
03/26/86
04/15/87
07/31/91
02/10/88
05/30/88
12/04/86
03/30/87
10/15/88
10/29/87
08/07/86
04/30/87
10/18/85
03/30/87
03/14/86
10/15/88
10/29/87
08/30/85
05/30/84
08/30/85
07/30/87
03/30/85
03/03/86
09/10/84
04/01/85
02/07/04
-------
Page No.
04/06/92
KEYWORD INDEX
SOLIDTEK LANDFILL/LINER 0ES1GN
STANDARDS FOR SECONOARY CONTAINMENT OF HAZARDOUS WASTE TANK SYSTEMS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
VARIANCE FROM 264 LANDFILL LINER I LEACHATE COLLECTION REQUIREMENTS
Retrofit
'CHANGES OURING INTERIM STATUS - CORRECTION
~RETROFITTING FOR PERMITTED SURFACE IMPOUNDMENTS
•RETROFITTING SURFACE IMPOUNDMENTS
ALTERNATE CONCENTRATION LIMIT (ACL) POLICY FOR HSWA PROVISIONS
DECISION DEADLINES FOR RETROFITTING WAIVER REQUESTS
K103/K104 WASTE STREAMS - RELATIONSHIP OF CWA DAT, LAND DISPOSAL RESTRICTIONS. BOAT. AND DELISTING CRITERIA
NEUTRALIZATION SURFACE IMPOUNDMENTS, RETROFITTING VARIANCES
SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWED FOR CLOSURE
MINING WASTE
9407.1985(06
9463.1989(02
9523.00-12
9523.00-14
9523.00-15
9467.1964(02)
9526.1966(05)
9484.1907(09
9476.1966	04
9401.1967	07
9571.1967(01)
9433.1967(06)
9464.1966(04)
9404.00-5#
09/30/65
01/09/69
03/30/67
03/14/86
03/30/88
03/14/84
10/30/68
07/30/87
10/30/86
07/24/87
10/08/87
04/02/87
04/21/66
10/15/68
(See alio Exclusion*)
Exploration or production of cruoe oil, natural gas, or geothermal energy - waste exclusion
'MINING EXCLUSION FOR SHELTER SLAG
'MINING WASTE EXCLUSION REINTERPRETATION
'MINING WASTE, KQ64 and 3004(x)
'ORE AND MINERAL EXTRACTION. BtNEFlClATION AND PROCESSING EXCLUSION APPLICABILITY
•POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSION
APPROPRIATENESS OF THE EP/ECLP SIMULATION OF CO-OISPOSAL SITUATION FOR MINING WASTES
CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTES
DECISION DEADLINES FOR RETROFITTING WAIVER REQUESTS
DROSS FROM ALUMINUM SMELTING USEO IN MANUFACTURE OF CEMENT
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES ANO THE RESIDUALS GENERATED (LOUISIANA REG)
~	METALS PRODUCTION WASTES, APPLICABILITY OF MINING WASTE EXCLUSION - COMBUSTION OF WASTES AS INCINERATION
« •>	MINERAL PROCESSING RESIDUALS FROM COMBUSTION UNITS BURNING HAZARDOUS WASTE FUEL
7	MINING LABORATORY WASTES UNOER 40 CFR 261.4(b)(7) - EXCLUSION OF
MINING WASTE AS NON-HAZARDOUS WASTE
MINING WASTE REGULATED UNDER SUBTITLE 0 RATHER THAN SUBTITLE C
SECONDARY MATERIALS RECYCLED IN PHOSPHORIC ACID RECIRCULATING SYSTEMS
Bevlll Amendment
'NEW WASTES NOT COVERED BY BEVILL EXCLUSION
BERYL PLANT ANO RAFF INATE DISCARD CLASSIFICATION
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
CHL0R10E-ILMEN1TE PROCESS WASTES
IRON ANO STEEL SLAGS IN MINERAL PROCESSING WASTES REPORT
IRON AND STEEL SLAGS, REGULATORY STATUS
MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY
MINING WASTE EXCLUSION INCLUDING PRIMARY PROCESSING BUT NOT SUBSEQUENT STEPS
SHAM INCINERATION AND TREATMENT OF K04B-K05Z WASTES IN CEMENT KILNS AND INDUSTRIAL FURNACES
TREATMENT STANDARDS AND THE SEVILLE EXCLUSION
Boiler Slag
•MINING EXCLUSION FOR SMELTER SLAG
XREF
9441.1964(11
9441.1964(23
9441.1985(35
9571.1986(04
9571.1989(01
9441.1965(09
9571.1965(01
9443.1985(09
9571.1987 01
9441.1989(01
9494.1967 02
9441.1985(05
9441.1984(19
9441.1984(09
9441.1986(72
9441.1986(55
9571.1990(04
9571.1989(02)
9571.1990(01)
9441.1987(76)
9441.1991(05)
9441.1991(07)
9571.1990(04
9441.1966(48)
9441.1986(81)
9494.1991 02
9554.1990(10)
/ /
04/30/84
07/31/84
10/30/65
07/30/86
01/30/69
02/26/65
10/03/85
10/03/85
10/08/87
02/07/89
04/15/87
02/04/85
08/15/64
05/09/64
09/16/86
07/16/86
06/27/90
10/30/89
03/15/90
09/15/87
04/22/91
05/30/91
05/30/90
06/10/66
11/03/86
03/29/91
08/23/90
9441.1984(23) 07/31/84
Coal
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
COAL ASH AS A SOLID WASTE
9441.1907(76)
9571.1990(02)
09/15/87
04/09/90
-------
Pan Mo,
04/06/92
KEYWORD INDEX
PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)
RESIDUAL WATER BERIVEO FROM AN EXEMPT WASTE (COAL ASH) IS EXEMPT
RETORTED OIL SHALE AND COAL FLY ASH
Energy Exploration Vasts
•EXPLORATION OR PRODUCTION OF CRUDE OIL, NATURAL GAS, OR GEOTHERMAL ENERGY - WASTE EXCLUSION
DRILLING FLUIDS ANO PRODUCED WATERS, SUBTITLE C EXCLUSION OF
DRILLING OPERATIONS. EXEMPTION OF CERTAIN WASTE FROH
Fossil Fuels
~FOSSIL FUEL COMBUSTION WASTE EXCLUSION
~MINING EXCLUSION FOR SHELTER SLAG
Large Volume Waste
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
MISCELLANEOUS UNITS
9441.1986(31
9441.1986(49
9571.1990(03
9441.1984(11
9441.1963(02
9441.1980(03
9441.1986(16)
9441.1984(23)
04/21/86
06/16/86
04/06/90
04/30/84
04/19/83
09/04/80
02/28/86
07/31/84
9441.1987(76) 09/15/87
(See Subpart X)
MIXED RADIOACTIVE WASTES
XREF
/ /
(See Mixed Waste)
MIXED WASTE
XREF
/ /
102)
681
10)
01)
~ 'MIXED WASTE AND LAND BAN	9551.1989102
ASPHALT MATERIALS DISPOSAL	9443.1988(03
MIXED WASTE REGULATION	9441.1987
MIXTURES OF LISTED AND CHARACTERISTIC WASTES	9441.19B7
PERCHLOROETHVLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAINING	9441.19B5
—	USED OIL BURNED FOR ENERGY RECOVERY, INTERPRETATION OF SUBPART E	9495.1989
WASTES FROM STORAGE OF PETROLEUM PRODUCTS
Atonic Energy Act (AEA)
BYPRODUCT MATERIAL AND MIXEO WASTE, AEA AND DOE INTERFACE
BYPRODUCT MATERIAL, DEFINITION OF
HIGH-LEVEL. TRANSURANIC, AND LOW-LEVEL RADIOACTIVE MIXEO WASTE
JURISDICTION AND REGULATION OF MIXED WASTE MANAGEMENT INCLUDING INCINERATION ANO LOCATION CRITERIA
By-Product
BRASS DROSS SKIMMINGS, SEPARATION OF METALS ANO OXIDES. BY-PRODUCT	9441.1981
BY-PRODUCT CRUDE OIL TANK BOTTOMS	9441.1986
BYPRODUCT MATERIAL. DEFINITION OF	_	9432.1986
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROH THE PRODUCTION OF CHLOROBENZENE	9441.1988
DROSS FROM ALUMINUM SMELTING USED IN MANUFACTURE OF CEMENT	9441.1909
DROVE RECLAMATION IN BRASS INDUSTRY, BY-PRODUCT DESIGNATION	9441.1981
METAL GALVANIZING PROCESS RESIDUES AS BY-PRODUCTS/SECONDARY MATERIALS	9441.1989
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL ANO HAZARDOUS	9432.1986
Mixed Radioactive Wastes
BULKING ANO CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WITH DIFFERENT HAZARDOUS COOES	9461.1985(01)
BYPROOUCT MATERIAL AND MIXED WASTE. AEA ANO OOE INTERFACE	9441.1986(46)
COMBINED NRC-EPA SITING GUIDELINES FOR DISPOSAL OF COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE 9480.00-14
9444.1980(03)
9441.1986(46)
9432.1986(10
9441.1987(41
9541,1986(14
21)
37)
10
111
011
15)
14)
03/30/89
03/22/88
07/30/87
06/19/87
04/10/85
05/15/89
11/17/80
06/02/86
04/12/16
06/01/87
07/03/86
06/06/85
05/01/86
04/12/86
04/21/88
02/07/89
04/05/89
04/02/89
09/06/86
09/19/85
06/02/86
03/13/89
-------
Page No.
04/06/92
KEYWORD INDEX
CORRECTIVE ACTION/PERMIT 1SSUES-U.S. ARMY ABERDEEN PROVING GROUNDS
HIGH-LEVEL. TRANSURANIC. AND LOU-LEVEL RADIOACTIVE NIXED WASTE
INTERIM STATUS REQUIREMENTS FOR NRC LICENSEES MANAGING RADIOACTIVE MIXED WASTE, CLARIFICATION
JURISDICTION AND REGULATION OF NIXED WASTE MANAGEMENT INCLUOINQ INCINERATION AND LOCATION CRITERIA
LAND OISPOSAL RESTRICTIONS EFFECT ON STORAGE/DISPOSAL OF COMMERCIAL NIXED WASTE
MIXED RADIOACTIVE AND HAZARDOUS WASTE. DISPOSAL OF
MIXED RADIOACTIVE HOSPITAL WASTES AND THE DOMESTIC SEWAGE EXCLUSION
MIXED WASTE (DOE FACILITIES), DEFINITION OF
MIXED WASTE OISPOSAL FROM RADIOACTIVE MATERIALS MANUFACTURING OPERATIONS
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL AND HAZARDOUS
RADIOACTIVE WASTE EXEMPTION IN NORTH AND SOUTH CAROLINA
RECYCLED GASOLINE/WATER ANO FUEL OIL/WATER MIXTURES
REGULATION OF HAZARDOUS COMPONENTS OF RAOIOACTIVE NIXED WASTE
REGULATION OF RADIOACTIVE HIXEO WASTE AT DEPARTMENT OF ENERGY FACILITIES
SCINTILLATION COUNTING COCKTAIL
SCINTILLATION VIALS CONTAINING 0001 WASTES, NANAGEHENT OF
SMALL-VOLUME NIXED WASTE LABORATORY GENERATED NATERIALS ANO LEAD
STATE AUTHORIZATION ANO REGULATION OF RAOIOACTIVE MIXEO WASTES
STATE AUTHORIZATION TO REGULATE HAZARDOUS COMPONENTS OF RAOIOACTIVE MIXEO WASTES
STATE PROGRAM ADVISORY 12 - RCRA AUTHORIZATION TO REGULATE NIXED WASTE
TC APPLICABILITY TO NIXEO WASTE
TREATNENT OF RAOIOACTIVE WASTES AT HAZARDOUS WASTE PERMITTED TSDF
TREATMENT STANDARDS FOR CERTAIN NIXEO RAOIOACTIVE WASTES
Nixed Radloact tve/Radloact1ve Wastes
OIOXIN-CONTAINING LABORATORY WASTE WITH RAOIOACTIVE PROPERTIES
LiqUlO SCINTILLATION COCKTAIL SOLUTION PRODUCT, READY SAFE
NIXEO WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS
NRC-EPA GUIDANCE ON COMMERCIAL NIXED LOW-LEVEL RAOIOACTIVE ANO HAZ WASTE OISPOSAL FACILITIES
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT HATERIAL ANO HAZARDOUS
TREATMENT ANO DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTANINATED OR RADIOACTIVE LEAO
9502.1986(09)
9141.1987	41
9528.1989(13
9541.1986(14
9555.1990(01
9431.1988(02
9441.1986(94
9503.1985(01
9554.1988(04
9432.1986(14
9541.1984 08)
9441.1986(22
9541.1986 19
9528.1987(14
9443.1987(04
9525.1986(04
9551.1988	07
9541.1987(04
9541.1986(20
9541.00-6
9441.1991(02
9525.1990(02
9554.1990(14
9441.1985(261
9443.1980(02
9451.1989(02
9487.00-8
9432.1986(141
9441.1987(52)
05/08/86
06/01/87
10/15/89
07/03/86
09/28/90
01/30/88
12/19/86
05/10/85
06/13/88
09/06/86
09/13/84
03/19/86
10/14/86
11/12/87
03/11/87
08/11/86
06/13/88
06/29/87
10/20/86
07/30/87
02/12/91
10/17/90
12/27/90
07/05/85
01/13/88
06/26/89
08/03/87
09/06/86
06/26/87
NRC
C0NB1NE0 NRC-EPA SITING GUIDELINES FOR OISPOSAL OF COMMERCIAL MIXED LOW-LEVEL	RAOIOACTIVE AND HAZARDOUS WASTE 9480.00-14
NIXEO WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS	9451.1989(02
SCINTILLATION COUNTING COCKTAIL	9443.1987
STATE AUTHORIZATION ANO REGULATION OF RAOIOACTIVE NIXED WASTES	9541.1987(04
isi
(04}
03/13/89
06/26/89
03/11/87
06/29/87
MIXTURE RULE
(See also Dertvcd-From-Rult)
•DILUTION OF F003 WASTES
•GENERATOR STANDARDS APPLICABLE TO TRANSPORTERS
•HAZARDOUS WASTE LISTED SOLELY FOR SUBPART C CHARACTERISTICS
•MIXTURE EXCLUSION
•MIXTURE RULE - DISCHARGE TO WASTEWATER
•SOLVENT DRIPPINGS FOR 0EGREASIN8 OPERATIONS
•SOLVENT DRIPPINGS FROM DEGREASING OPERATIONS
"SOLVENT MIXTURE RULE
•SOLVENT MIXTURE RULE APPLIED TO SPILL OF TOLUENE/BENZENE MIXTURE - CERCLA INTERFACE
1.1.1-TRICHIOROETHANE CONTAINED IN A SANO-METAL-SOLVENT MIXTURE
ACETONE AND METHANOL CONTAMINATED WASHWATERS
ASBESTOS AS A HAZARDOUS WASTE
ASH RESIDUE GENERATED FROM INCINERATION OF K04S
BAN ON USE OF LIQUIDS IN LANDFILLS
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY
XREF
9441.1986(97)
9453.1989(01)
9441.1986(74)
9441.1990(34}
9522.1987(02
9441.1987(19)
9443.1987(08)
9441.1987 18
9443.1985	11)
9443.1989 07)
9444.1989(05
9444.1980(05)
9441.1987(12)
9467.1986(07)
9441.1986	95
/ /
12/30/86
04/30/89
09/30/86
11/01/90
12/30/87
03/30/87
04/30/87
03/30/87
11/30/85
07/10/89
07/21/89
11/10/80
03/03/87
04/27/88
12/23/86
-------
Page No.
04/06/92
KEYW0R0 INDEX

CARBON REGENERATION FACILITY, MIXTURE OF SOLID AND HAZARDOUS WASTES (CALGON)	9441.1986(33)
CLOSURE FLAN FOR THE HAZARDOUS WASTE STORAGE UNITS AT VERTAC'S SHUTDOWN MANUFACTURING PLANT	9408.1907 01)
COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-B46 METHODS, WASTE IDENTIFICATION	9445.1987103a)
DELISTING ACTION - STATUS OF HOLLOMAN AIR FORCE BASE	9433.1987(16)
DELISTING CRITERIA/LEACHATE LEVELS	9433.1986 01
DEPLETED MIXTURES OF ETHYLENE GLYCOL AND WATER FROM HEAT EXCHANGERS	9441.1989(42
DERIVED FROM/MIXTURE RULE APPLICATION TO REFINERY WASTEWATER TREATMENT SYSTEMS	9441.1987(70
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES	9451.1986(01
ELECTROPLATING RINSEWATERS NOT IN F007-009 LISTINGS	9444.1988 07
ENVIRONMENTAL MEDIA CONTAMINATED WITH RCRA-LISTEO HAZARDOUS WASTE	9441.1989(30
EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS	9441.1986(03
F SOLVENT WASTES	9444.1985(03
GENERATION AND TREATMENT OF K044 WASTE	9551.1988 13a)
HAZARDOUS CHARACTERISTIC - BASIS FOR LISTING	9441.1984(32)
HAZARDOUS WASTE LISTING FOR F006 WASTE - F109 WASTE	9441.1986(78)
LEACHATE AND PRECIPITATION RUN-OFF AT LFs, WASTE PILES, AND LT UNITS, HAZARDOUS WASTE FROM MIXTURE OF	9441.1984(37)
LEAKS, SPILLS. AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WATERS, MIXTURE RULE	APPLIEO TO 9441.1986(07)
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER	9441.1986(73)
METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS	9441.1987(46)
MIXING OF METHANOL AS NON-HAZARDOUS WASTE	9471.1983(01)
MIXING RULE DEFINITION	9!!!!!5J 8!f
MIXTURE OF CHARACTERISTIC WASTE AND LISTED WASTE, ASH FROM INCINERATION	9441.1985 32)
MIXTURE OF F003 AND A SOLID WASTE AND DELISTING REQUIREMENTS	9441.1987 65)
MIXTURE OF METHANOL AND SOLID WASTE WHICH DOES NOT EXHIBIT ANY CHARACTERISTICS	9441.1986 23)
MIXTURE RULE CALCULATION - INCLUDING VOLATILIZEO SOLVENT	9441.1987 28
MIXTURE RULE CALCULATION-INCLUDING VOLATILIZED SOLVENT	9441.1987(28)
MIXTURES OF SOL 10 AlfO HAZARDOUS WASTES	9441.1987 06)
MIXTURES OF SOLIO WASTE AND A WASTE LISTEO SOLELY BECAUSE IT EXHIBITS A CHARACTERISTIC	9441.1985 38)
PAINT WASTES AND THE SPENT SOLVENT LISTINGS	9444.1987(17)
PESTICIDE APPLICATOR WASHING RINSEWATER	S!!? "!! 95l
PESTICIDE APPLICATOR WASHING RINSE WATER	9441.1985 42)
PETROLEUM REFINERY WW, MIXTURE AND DERIVE0-FROH RULES	9441.1985 29)
RAILftOAO TIES AS HAZARDOUS WASTES UNOER THE MIXTURE RULE, SMALL QUANTITY GENERATOR	9441.1980 04)
REFINERY WASTEWATER	9444. 980(02)
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE	9433.1986 11)
SECONDARY MATERIALS RECYCLED IN PHOSPHORIC ACID RECIRCULATING SYSTEMS	9571.1990 04
SOLVENT/MIXTURE BLENDS	9444.1968 06)
SPENT FLUIDIZED BED MEDIA AND CHANGES UNOER INTERIM STATUS	9444.1986 28)
SPENT SOLVENT MIXTURE (NALCAST 6015/WATER/WAX)	9444.1985(15)
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANT	, „ , 9441.1986(62
USEO OIL CONTAMINATION THROUGH NORMAL USE OR PURPOSEFUL MIXING WITH HAZAROOUS WASTES -	RECYCLING DEFINED 9441.1984(30)
WASHWATERS 6ENERATE0 FROM WASHING PESTICIDE APPLICATOR TRUCKS	9441.1986 44)
WASTE GENERATED BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHLOROBENZENE AND HEXACHLOROETHANE	9441.1988 04
WASTES CONTAINING F001-F00S CONSTITUENTS	9441.1908 05)
WASTEWATER TREATMENT SYSTEM, SOLVENT RECOVERY STILL BOTTOMS IN	9441.1985(43)
04/23/86
02/09/87
11/17/87
07/31/87
01/07/86
08/04/89
08/28/87
03/17/86
04/07/88
06/19/89
01/07/86
04/01/85
11/04/88
11/07/84
10/12/86
11/14/84
01/23/86
09/25/86
06/17/87
07/12/83
06/09/81
10/07/85
08/17/87
03/21/86
04/30/87
04/30/87
01/27/87
11/20/85
05/20/87
07/16/85
12/13/85
08/23/85
11/17/80
11/13/80
04/24/86
06/27/90
03/31/88
12/05/86
06/24/85
08/19/86
10/22/84
05/30/86
01/14/88
02/22/68
12/17/85
MOBILE TREATMENT UNITS
(Sat also Parmlt Process, Ptrmlt Conditions)
'MOBILE WASTEWATER TREATMENT UNITS
CLOSURE PLANS-MOBILE TREATMENT UNITS
MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTS
HOBILE SOLVENT RECYCLER, GENERATOR DETERMINATION FOR
PROPOSED MECHANISM FOR HANDLING MOBILE TREATMENT UNITS
XREF
9432.1987(05
9476.1988(02
9441.1986(30
9432.1986(13
9525.1982(01
/ /
06/30/87
08/22/88
04/16/86
08/06/86
01/29/82
-------
Page No.
04/06/92
KEYWORD INDEX
MODELS
SUBSURFACE FATE AND TRANSPORT HODEL
MODIFICATIONS
9431.1991(01) 03/26/91
(Sec Permit Process, under Permit Modification)
XREF
MONITOR INO
/ /
(See Groundwater Monitoring)
MORE STRINGENT/BROADER IN SCOPE
XREF
/ /
(See Stat* Authorization)
MUNICIPAL LANDFILL
XREF
/ /
(See also Solid Waste)
LEACHATE FROM A MUNICIPAL LANDFILL, REGULATION OF
Sanitary Landfill
LEACHATE FROM A MUNICIPAL LANDFILL, REGULATION OF
NONHAZARDOUS LIQUID WASTEWATERS ANO SLUDGES IN SANITARY IF UNDER RCRA AND HSWA. DISPOSAL OF
* SPENT SOLVENT LISTINGS & LEACHATE FROM SANITARY LFs THAT RECEIVEO HAZAROOUS WASTE
MUNICIPAL WASTE COMBUSTION
(See also Incineration]
MUNICIPAL WASTE COMBUSflON ASH
MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGE
MUNICIPAL WASTE COMBUSTION, DISPOSAL OF RESIOUAL ASH
MUNICIPAL WASTE INCINERATOR ASH MANAGEMENT
REGULATION OF MUNICIPAL WASTE COMBUSTION ASH
RESIDUES FROM U.S. NAVY SALVAGE FUEL BOILER
NATIONAL VARIANCE
XREF
9441,1983(00}
9441.1963(08
95/4.1985(01
9444.1983(01
XREF
9573.1990(02)
9443.1966(13}
9443.1907 06
9573.1986(01)
9573.1991(01)
9441.1987(16)
/ /
10/21/83
10/21/83
01/22/85
06/10/83
/ /
03/29/90
05/27/86
04/08/87
06/27/86
05/01/91
03/17/87
(See Land Disposal Restrictions)
NATURAL GAS
XREF
/ /
~EXPLORATION OR PRODUCTION OF CRUDE OIL. NATURAL GAS. OR GEOTHERMAL ENERGY
~PRODUCED WATERS FROM NATURAL GAS EXPLORATION-EXCLUSION
WASTE EXCLUSION
9441.1984(111
9441.1984(21)
04/30/84
07/31/84
-------
Page No.
04/06/92
KEYWORD INDEX
NEW UNIT
(Set Construction)
NO-NIGRATION VARIANCE
XREF
/ /
(Set land Disposal Restrictions)
NONCOMPLIANCE
XREF
/ /
(See Oata)
NDNHAZAROOUS LIQUIDS
XREF
/ /
(Sea Liquid Uaste)
NOTIFICATION
J Sat also Burning and Blending, EPA I.D. Number)
LEAK NOTIFICATION AT A OOUBLf-LINEO
SURFACE IMPOUNDMENT
•NOTIFICATION REQUIREMENTS FOR RECYCLABLE MATERIALS
•TANK REPLACEMENT
ADMINISTRATIVE CONTROLS AND STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
BURNING OF USED OIL IN THE MARINE INDUSTRY AND USED OIL 6ENERAT0R NOTIFICATION REQUIREMENTS
DECISION NOT TO REQUIRE NOTIFICATION FROM GENERATORS WHO BURN SPECIFICATION USEO OIL ON-SITE
INTERIM STATUS QUALIFICATION REQUIREMENTS TO HAZARDOUS WASTE FUEL STORAGE FACILITIES. APPLIED
MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OF
PROPOSEO PERMIT-IT-RULE FOR USEO OIL RECYCLERS
RECYCLING ACTIVITIES
NPOES FACILITIES
NRC
OB/OD
(See Clean Water Act, see Wastewater)
(See Mixed Wastes)
XREF
XREF
9404.1905(02
9441.1908(13
9477.1988(03
9494.1986(0S
9495.1986	09
9495.1987	05
9528.1986 10
9494.1986(01
9495.1986(30
9451.1989(01
XREF
XREF
/ /
/ /
08/30/05
04/30/08
07/30/08
04/11/86
04/21/86
03/26/87
11/13/86
02/09/86
11/24/86
05/03/89
/ /
/ /
(See Subpart X under Open Burning/Open Detonation)
OBTAINING INTERIM STATUS
XREF
/ /
(See Interim Status Process)
-------
Page No,
04/06/92
KEYWORD INDEX
\
OFF SPECIFICATION
(Sm List ad Hazardous Waste)
OFF-SITE FACILITIES
XREF
/ /
•ACCEPTANCE OF WASTE IN A PERMITTED FACILITY
EPA 10 NUMBER ANO FACILITY LOCATION
OILY WASTE
(See also Hazardous Waste Identification)
•PETROLEUM REFINERY WASTEWATER TREATMENT SLUDGE CLASSIFICATION
DELISTING TESTING REQUIREMENTS, CYANIDE AND OTHER WASTES, STEEL INOUSTRY
EXCLUSION FROH REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROH SHIPS. DEFINITION
METHODS 1310 ANO 1330: EXTRACTION PROCEOURE ANO EXTRACTION PROCEDURE FOR OILY WASTE
RETORTED OIL SHALE ANO COAL FLY ASH
SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS
TCLP EXTRACTIONS APPLIEO TO LIQUID WASTES, OILS ANO SOLVENT-BASED PRODUCTS
OMNIBUS PROVISION
•THE OMNIBUS PROVISION ANO PERMITS
CONSTRUCTION OF A NEW LANDFILL CELL ANO THE OMNIBUS PROVISION
ECOLOTEC PERMIT REMAND ORDER AND USE OF THE OMNIBUS PROVISION
PROPOSED RULES IMPACT ON PERMIT DEADLINES
9472.1903(02}
9461.1989(03>
XREF
9444.1991(01)
9433.1984 06
9441,1986(031
9432.1986(05)
9443.1987 14
9571.1990(03)
9433.1986 23
9442.1991(14)
9520.1986(01
9528.1986(01
9524.1989(02
9501.1987 03
07/30/83
08/18/89
/ /
02/01/91
12/18/84
01/07/86
02/05/06
08/11/87
04/06/90
12/30/86
10/29/91
02/28/86
03/03/86
03/02/89
12/28/87
ON-SITE WASTE MANAGEMENT
(See also Permit Process, Generator)
DELISTING PETITIONS FOR K-WASTES MANAGED IN ON-SITE LANO-BASED UNITS-MONITORING REQUIREMENTS
DELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIES
K006 WASTE AND ONSITE DISPOSAL UNIT CONTAINING THESE WASTES
OIL/WATER EMULSIONS GENERATED BY PETROLEUM REFINERY WW SYSTEMS-K049 WASTE
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL AND HAZARDOUS
ON-SITE TREATMENT BY GENERATORS UNDER 262.34
PERMIT ISSUES REGAROING ON-SITE TREATMENT BY FLUIOIZED BED INCINERATION
TEMPORARY EXCLUSION APPLIED TO ONLY ONE FACILITY (MONROE AUTO)
TREATMENT OF HAZAROOUS WASTE IN GENERATOR'S ACCUMULATION TANKS
OPEN BURNING/OPEN DETONATION (OB/OO)
XREF
9433.1987(21
9433.1987(22
9432.1987(09
9441.1984(35
9432.1986 14
9453.1987(03
9522.1985(05
9441.1987(30
9453.1987(02
/ /
09/28/87
10/02/87
08/19/87
12/07/84
09/06/86
07/01/87
12/13/85
04/30/87
03/25/87
(See Subpart X, Federal Facilities)
OPERATING LIFE
XREF
/ /
(Sea Permit Conditions)
XREF
/ f
-------
Page No.
04/06/92
V
\
KEYWORD INDEX
OSHA
(Sea also Health and Safety)
STANDARDS FOR AIR PATHWAY FOR METALS AND ORGANIC CHEMICALS
OWNER/OPERATOR
(See also Permit Application)
* OWNERSHIP SPLIT OF ONE FACILITY INTO TWO FACILITIES
•GENERATOR RESPONSIBILITIES: FACILITY OWNER/OPERATOR OR MOBILE RECYCLING UNIT OPERATOR
'MANUFACTURING PROCESS UNITS
ADMINISTRATIVE CONTROLS AND STORAGE STANDAROS FOR MARKETERS OF HAZARDOUS WASTE
CONTAINERS STORING HAZARDOUS WASTE. REQUIREMENTS
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION/PERMIT ISSUES-U.S. ARMY - ABERDEEN PROVING GROUNDS
LINER/LEACHATE COLLECTION SYSTEM COMPATIBILITY
OPERATOR AT DOE OAK RIDGE FACILITY, DETERMINATION OF
OPERATOR AT GOVERNMENT-OWNED CONTRACTOR-OPERATED (GOCO) FACILITIES
OWNER AND OPERATOR RESPONSIBILITIES DURING OPERATING LIFE AND CLOSURE
OWNER/OPERATOR UNDER RCRA AND CERCLA, DEFINITION OF
PERMIT ISSUES REGARDING ON-SITE TREATMENT BY FLUIDIZED BED INCINERATION
PERMITS ISSUED TO BOTH OWNERS AND OPERATORS IF DIFFERENT PEOPLE
XREF
9551.1991(04)
16)
01)
")
05)
01)
XREF
9528.1987
9453.1985
9441.1987
9494.1986
9482.1986
9502.00-2
9502.1986(09
9487.1986(10
9432.1984(01
9472.1987(01
9471.1984(04
9432.1987(12
9522.1985 05
9522.1964(03
/ /
01/30/91
/ /
11/30/87
12/30/84
06/30/87
04/11/86
01/21/86
04/18/86
05/08/86
08/07/86
01/27/84
06/24/67
08/30/84
10/28/87
12/13/85
07/30/84
P-Wastes
(See Listed Hazardous Waste)
PAINT FILTER TEST
XREF
/ /
(See also SW-046)
'LIQUIDS AND FREE LIQUIDS, DEFINITION OF
LIQUID HAZARDOUS WASTES IN LANDFILLS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
Free Liquids
'CALIFORNIA LIST
'LIQUIDS AND FREE LIQUIDS. DEFINITION OF
•PH TESTING OF SOLID/WATER MIXTURE
AQUEOUS SOLUTION, IGNITABILITY DEFINED
BAN ON USE OF LIQUIDS IN LANDFILLS
COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-846 METHODS, WASTE IDENTIFICATION
LIQUID WASTE, DEFINITION OF
PAINT FILTER LIQUIOS TEST USEO TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONS
PCB-CONTAMINATED WASTES, STABILIZATION OF
SOLIDIFICATION OF CALIFORNIA LIST LIQUID WASTES AND THE DILUTION PROHIBITION
WASTE AS LIQUID OR SOLID, DETERMINATION OF
XREF
9432.1985(03)
9487.1985(04)
9523.00-14
9554.1987(03)
9432.1985(03)
9443.1983(03)
9443.1985 02
9407.1966(07)
9445.1987(03a)
9432.1981(01)
9553.1987(15
9487.1966(01
9551.1967(23
9445.1984(06
/ /
05/30/85
08/07/85
03/14/86
07/30/87
05/30/85
02/28/83
02/26/65
04/27/86
11/17/87
06/28/81
12/03/87
02/03/86
11/13/67
07/30/84
PAINT WASTE
(See Hazardous Waste Identification) (See also Listed Hazardous Waste, Characteristic Hazardous Waste)
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
Part B Permit Application
•CONTENTS OF PART B PERMIT APPLICATIONS TRAFFIC REQUIREMENTS
•EXPOSURE INFORMATION REQUIREMENTS
•PART B PERMIT APPLICATION CHECKLISTS
•RCRA PERMITS FOR MOBILE TREATMENT UNITS
•SUMPS IN THE PART B PERMIT APPLICATION
•TOPO MAP REQUIREMENTS FOR CONTAINER STORAGE FACILITIES
•TOXICITY CHARACTERISTIC WASTE PART B PERMIT APPLICATION DEADLINES
CALL-IN OF STORAGE AND TREATMENT APPLICATIONS
COMPLYING WITH RCRA INTERIM STATUS STANDARDS WHILE DEVELOPING A PERMIT APPLICATION
CONSTRUCTION OF A NEW LANDFILL CELL AND THE OMNIBUS PROVISION
FILING PART B PERMIT APPLICATION
GWM DATA IN PART B APPLICATIONS
IMMEDIATE IMPLEMENTATION OF NEW CORRECTIVE ACTION REQUIREMENTS
INTERIM STATUS SURFACE IMPOUNDMENTS & CLEAN CLOSED WASTE PILES, CODIFICATION RULE 12/01/87
LAND TREATMENT PERMIT APPLICATIONS - REFINERY WASTE ANALYSES GUIDANCE
MISCELLANEOUS UNITS SUBPART X. IMPLEMENTATION GUIDANCE
PART B PERMIT APPLICATION REQUIREMENTS FOR SQG TREATMENT FACILITIES
PERMIT REQUIREMENTS, THERMEX ENERGY/RADIAN
POST CLOSURE PERMIT PART B REQUIREMENTS
PROVISIONS IN PART B APPLICATIONS PRIOR TO EFFECTIVE DATE AND FINAL RULE
RCRA CORRECTIVE ACTION PROGRAM	j
REQUIRED SIGNATURES ON PART B PERMIT APPLICATIONS
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
9523.1988(01
9523.1907(03)
9523.1984(04
9523.1986 01
9502.1905(05
9523.1984(11
9501.1990	01
9528.1988(06
9528.1986(09
9528.1986 01
9523.1983 06
9523.1984(07
9502.1985(01
9522.1988(05
9523.1984(02
9489.00-2
9522.1985(06
9521.1987(0!
9523.1985(07
9523.1985(02
9431.1991	03
9523.1985(01
9523.00-18
9523.00-12
9523.00-14
11/30/88
11/30/87
05/30/84
03/30/86
08/31/85
03/30/84
07/31/90
04/19/88
10/27/86
03/03/86
09/30/83
09/10/84
02/06/85
11/30/88
04/03/84
04/22/89
12/20/85
08/07/87
11/18/85
03/30/85
05/01/91
02/25/85
03/14/89
03/30/87
03/14/86
Pre-Constructlon Ban
•CORRECTIVE ACTION FOR NEW FACILITIES
•GROUNDWATER MONITORING t ESTABLISHING BACKGROUND VALUE
PERMITTING AND CORRECTIVE ACTION REQUIREMENTS AFFECTING COMPLIANCE WITH LAND OISPOSAL RESTRICTIONS
9481.1986(10
9481.1986(04
9502.1986(11
10/30/86
07/30/86
06/16/86
>
O
Signatures
LAND OWNER SIGNATURE ON PART A
REQUIRED SIGNATURES ON PART B PERMIT APPLICATIONS
SIGNATORIES TO DEPARTMENT OF DEFENSE PERMIT APPLICATIONS
9523.1983(03
9523.1985 01
9522.1985(01
06/17/83
02/25/85
02/11/85
Withdrawals
REPORTING WITHDRAWALS IN SPHS AS FINAL PERMIT DETERMINATIONS
9521.1984(03) 07/09/84
PERMIT CONDITIONS
Storage, TSDF
.n.^.^TING REGULATOR
•PERSONNEL TRAINING OURING POST-CLOSURE
CONOCO PART B PERMITS
ENFORCEMENT OF STATE AND EPA ISSUED PERMITS
PERMIT CONDITIONS: THE VELSICOL DECISION
STAYING HSWA PERMIT CONDITIONS
AUTHORITY
XREF
9524.1983(01
9523.1985105
9553.1990101
9522.1990
9524.1984
9521.1989(02
/ /
12/31/83
10/30/85
05/11/90
01/26/90
10/11/84
04/19/88
Expansions
INTERIM STATUS OF PROPOSEO LANDFILL CELLS
PART B INFORMATION REGARDING FUTURE POTENTIAL EXPANSIONS
9487.1981(011
9523.1984(08)
03/12/81
09/10/84
-------
Page No.
m
KEYWORD INDEX
PART A PERMIT APPLICATION
($00 Permit Application) (See also Interim Status Process)
PART S PERMIT APPLICATION
(See Permit Application) (See also Interim Status Process)
PARTIAL CLOSURE
PCBs
(See Closure Process)
* INTERIM STATUS FOR RECEIVING SQ6 WASTES
ACCEPTABLE LEVELS OF RESIDUAL CONTAMINANTS IN THE EPA INCINERATOR RESIDUES (REVISION)
MUNICIPAL WASTE COMBUSTION RESIOUES-ASK AND SLUDGE
PCB-CONTAMINATED WASTES. STABILIZATION OF
RCRA TEST METHODS 1 OA ACTIVITIES
SOXTEC EXTRACTION SYSTEM VS. SOXHLET EXTRACTION SYSTEM FOR PREPARATION OF PCB SAMPLES
TETRACHLOROETHYLENE CONTAMINATED WITH POLYCHLORINATED BIPHENYLS (PCBs)
PERMIT APPLICATION
*	*INTERIM STATUS AND SQG
*	213 OF HSWA. REQUIREMENTS - PERMIT ISSUANCE AND CERTIFICATION OF COMPLIANCE
CORRECTIVE ACTION REQUIREMENTS FOR FEOERAL FACILITIES AND IRP ACTIVITIES
CPA AUTHORITY TO CONSIDER PERMIT APPLICANT HISTORY OF COMPLIANCE WITH RCRA
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS. HIGH PRIORITY PERMITTING
_	OPERATOR AT GOVERNMENT-OWNEO CONTRACTOR-OPERATED (GOCO) FACILITIES
TT)	PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
L	REYNOLDS METALS COMPANY INCINERATOR
Incomplete Part B's
INADEQUATE PART B PERMIT APPLICATION
Owner/Operator
'GENERATOR RESPONSIBILITIES; FACILITY OWNER/OPERATOR OR MOBILE RECYCLING UNIT OPERATOR
OWNER AND OPERATOR RESPONSIBILITIES DURING OPERATING LIFE AND CLOSURE
OWNER/OPERATOR UNDER RCRA AND CERCLA, DEFINITION OF
PERMITS ISSUED TO BOTH OWNERS AND OPERATORS IF DIFFERENT PEOPLE
Part A Permit Application
•CHANGES DURING INTERIM STATUS - CORPORATE REORGANIZATION
•EXISTING PORTION OF A LAND OISPOSAL UNIT, DEFINITION (260.10)
•INTERIM STATUS PART A APPLICATION WITHDRAW.
CARBON REGENERATION UNITS - REGULATORY STATUS
CEMENT KILN BURNING HAZARDOUS WASTE FUELS DURING INTERIM STATUS
LANO OWNER SIGNATURE ON PART A
MIXED RAOIOACTIVE AND HAZARDOUS WASTE, DISPOSAL OF
PERMITTING UNITS CREATED FOR FACILITY CLOSURE
REGULATION OF RAOIOACTIVE MIXED WASTE AT DEPARTMENT OF ENERGY FACILITIES
XREF
/ /
XREF
/ /
XREF
/ /
952B.1986(
9488.19851
9443.1986
9467.1988
9441.1960
9443.1988
9444.1989
06)
03)
13
(01)
31)
06)
10)
07/30/86
04/01/85
05/27/86
02/03/88
07/30/68
05/31/88
09/22/89
9521.l986(05a)
9522.1985(03)
9502.1986(14)
9523.199101
9501.1986(01)
9472.1987(01)
9526.1986 11)
9523.1986(04)
05/30/86
07/05/85
08/22/86
03/13/91
09/11/86
06/24/87
12/10/86
10/27/86
9521.1964(01) 05/02/84
9453.1985(01)
9471.1984(04)
9432.1987(-
9S22.19841
12/30/84
08/30/84
10/28/87
07/30/84
9528.1985(04)
9432.1982(01$
9453.199101)
9489.1991(04)
9528.1967 10)
9523.1983 03
9431.1988(02)
9476.1985(03
9528.1987
IS!
10/30/85
08/30/82
06/01/91
08/02/91
09/03/87
06/17/83
01/30/88
09/11/85
11/12/87
-------
Page No.
04/06/92
KEYWORD INDEX
OperaUn^ llf*
y
LITY'S OPERA!1KB LIFE, DETERMINATION OF
Permit Rmulrcmnti
•CONTENTS OF POST B PERMIT APPLICATION: TRAFFIC REQUIREMENTS
•LAND TREATMENT
ALTERNATE CONCENTRATION LIMIT IACLI POLICY FOR HSWA PROVISIONS
APPENDIX VIII CONSTITUENTS IN GROUNDWATER, REQUIREMENTS FOR ANALYSIS OF
COMPACTING HAZARDOUS WASTE INSIDE STEEL DRUMS AS TREATMENT
CONTAINERS STORING HAZARDOUS WASTE. REQUIREMENTS
CORRECTIVE ACTION AT FEDERAL FACILITIES, NATIONAL PRIORITIES
OELAY OF CLOSURE RULE PREAMBLE LANGUAGE, CORRECTION
GENERATOR ACCUMULATION TIME REQUIREMENTS
HAZARDOUS WASTE TREATMENT/STORAGE TANKS, PERMITTING
INTERIM STAT IS FOR RECEIVING SQG WASTE
PERMIT REQUIREMENTS FOR ZERO WASTEWATER TREATMENT SYSTEM
PERMIT REQUIREMENTS RELATING TO ON-SITE TREATMENT AND WASTEWATER TREATMENT UNIT EXEMPTIONS
PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT NINES
PERMITTING AND CORRECTIVE ACTION REQUIREMENTS AFFECTING COMPLIANCE WITH LAND DISPOSAL RESTRICTIONS
POST-CLOSURE PERMIT PART B REQUIREMENTS	r
RCRA FACILITY ASSESSMENTS, IMPLEMENTATION
RECYCLING ACTIVITIES
REGION V FUEL-BLENDING FACILITIES CONCERNS
REPORTING REQUIREMENTS (SECTION 270.30(1)(10)
VOLUNTARY CORRECTIVE ACTION
Permit Standards
•PERMIT MODIFICATION
•SOG 100-1000 Kb/MO GENERATORS. AND THE MANIFEST
« *THE OMNIBUS PROVISION AND PERMITS
•TREATMENT CAPACITY
PERFORMANCE STANDAROS FOR DISPOSAL IN SALT OOMES
REGION X*s RECOMMENDED REVISION OF 40 CFR 270.4(a) AND 270.32(b)(1)
PERMIT PROCESS
3008(H) OF THE SOLID WASTE DISPOSAL ACT, INTERPRETATION OF
•CORRECTIVE ACTION BEYONO FACILITY BOUNDARY - FINANCIAL RESPONSIBILITY REQUIREMENT
•CORRECTIVE ACTION IN PERMITS
•POST-CLOSURE PERMITS FOR SURFACE IMPOUNDMENT
•RETROFITTING FOR PERMITTEO SURFACE IMPOUNDMENTS
~TERMINATION OF PERMITS
•TREATABILITY STUDIES ON HAZAROOUS WASTE SAMPLES, PERMIT REQUIREMENTS
ACLt UNDER THE RCRA AND CERCLA PROGRAMS. USE OF
AWARD OF PERMITS FOR NEW HAZARDOUS WASTE LAND DISPOSAL FACILITIES, PROCESS
BYPRODUCT MATERIAL. DEFINITION OF
CARBON REGENERATION FACILITIES
CONTAINERS FOR SAFE AND ECONOMICAL STORAGE, TRANSPORT. AND DISPOSAL OF HAZAROOUS WASTE. DEVELOPMENT OF
CONTAMINATED GROUND WATER ANO VOLATILES FROM AIR STRIPPING, TREATMENT OF
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION REQUIREMENTS FOR FEDERAL FACILITIES AND IRP ACTIVITIES
DENIAL OF RCRA OPERATING PERMITS
DI0X1N TRIAL BURNS FOR PURPOSES OF CERTIFICATION OR A RCRA PERMIT
DOD'S IRP PROGRAM ANO RCRA CORRECTIVE ACTION
EFFECTS OF THE SHALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES
EPA AUTHORITY TO CONSIDER PERMIT APPLICANT HISTORY OF COMPLIANCE WITH RCRA
9477.1984(07) 12/03/84
9523.19881
9488.19871
9481.19871
9481.1985!
9503.19911
9482.1986
9502.1986
9476.1989
9453.1989
9483.1984
9528.1986
9471.19891 01
01
01
071
01
01
01
04
02
01
01
06
9522.1988
9472.1986
9502.1986
9523.1985
9502.00-4
9451.1989101
9441.1991 17
9524.1988(01
9502.1987(11
9525.1985(01
9475.1985 02
9520.1986(01)
9525.1986(07
9489.1991(05
9522.1987(01
9502.19851
9502.1986
9521.1986i
9522.1986
9484.1987
9525.1986
9441.1986(58
09)
10)
06a)
02a)
09)
05
06)
03
10)
03}
01
86)
9481.1986
9521.1986
9432.1986
9442.1986
9482.1985
9441.1986
9502.00-2
9502.1986(14)
9523.00-11
9488.00-1A
9502.1906(17)
9451.1986(01
9523.1991(01
11/30/88
07/30/87
07/24/87
10/15/85
05/21/91
01/21/86
02/13/86
08/22/89
04/21/89
02/23/84
07/30/86
03/20/89
11/02/88
06/04/86
06/16/86
11/18/85
08/21/86
05/03/89
11/04/91
02/23/88
12/21/87
10/30/85
10/30/85
02/28/86
12/30/86
02/22/91
11/16/87
12/16/85
05/30/86
06/30/86
10/30/86
07/30/87
10/31/86
06/30/86
08/06/86
04/08/86
04/12/86
04/30/86
11/26/85
11/20/86
04/18/86
08/22/86
12/10/06
05/07/86
09/29/B6
03/17/66
03/13/91
-------
Page No.
04/06/92
KEYWORD INDEX
n >
S>>
FACILITY TRANSFER/RECONSTRUCTION DURING INTERIM STATUS
FEDERAL FACILITIES INVENTORY UNDER RCRA 3016
FOUNDRY SANDS RECYCLED AND RETURNED TO THE FOUNDRY
GROUNDWATER CLEANUP STANOARDS/ACLs IN DRAFT HSWA PERMIT (INTERNATIONAL PAPER COMPANY)
HSVA APPLIEO TO FEDERAL FACILITIES (DOE-OAK RIDGE)
INCINERATOR PERMITS TO BURN OIOXIN WASTES. MODIFICATION OF
INSTALLATION RESTORATION PROGRAM (IRP) - 000
INTERIM STATUS REQUIREMENTS FOR NRC LICENSEES MANAGING RADIOACTIVE MIXED WASTES, CLARIFICATION
LAND OISPOSAL UNIT CLOSURE CLARIFICATION OF PROPOSEO AND PROMULGATED RULES
NEGOTIATED PERMITS
OMNIBUS AUTHORITY TO CONTROL EMISSIONS OF METALS, HCL ft PICi FROM INCINERATORS
PERFORMANCE AND PERMITTING STANOAROS IN 3004(b), PROHIBITION OF PLACEMENT OF HAZARDOUS WASTE IN SALT DOMES
PERMIT APPLICATIONS FOR DESTRUCTION OF NERVE AGENTS
PERMIT COMPLIANCE/ENFORCEMENT ISSUES (REG, X)
PERMITTING INCINERATORS
PERMITTING ISSUES (OUPONT EDGEMORE FACILITY) - GUIDANCE
PERMITTING REQUIREMENTS FOR A PCB INCINERATOR
POST CLOSURE PERMITTING REQUIREMENTS (ARMCO STEEL)
PUBLIC HEARING AFTER ISSUANCE OF DRAFT PERMIT - STATES
PUBLIC INVOLVEMENT IN PERMITTING, POLICY FOR EXPANDING
ROM) PERMITS - POLICY GUIDANCE
RECYCLED GASOLINE/WATER ANO FUEL OIL/WATER MIXTURES
RELEASES OF HAZARDOUS WASTE, RCRA APPLICABILITY TO
SECURITY REQUIREMENTS AT FACILITIES
STORAGE PERMIT FOR FACILITIES INVOLVED IN HAZARDOUS WASTE RECYCLING
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT CLOSURE, APPLICABILITY OF 3005(f) OF RCRA TO
> SURFACE IMPOUNDMENT RETROFITTING ANO TIME ALLOWEO FOR CLOSURE
THERMAL RELIEF VENTS ON HAZAROOUS WASTE INCINERATORS, ACCEPTABILITY OF
TREATMENT OF HAZAROOUS WASTE IN A GENERATOR'S ACCUMULATION TANKS ANO CONTAINERS
UIC CORRECTIVE ACTION REQUIREMENTS, IMPLEMENTATION
Appeals
ECOLOTEC PERMIT REMAND ORDER AND USE OF THE OMNIBUS PROVISION
POSTPONEMENT OF A LAND TREATMENT DEMONSTRATION FOR NAVAJO REFINING CO., ARTESIA, NH
RECONSIDERATION OF DELISTING DENIAL BASED ON USE OF VHS, TOTAL CHRONIUH STANDARO, AND MCL
Deadlines
CALL-IN OF STORAGE AND TREATMENT APPLICATIONS PRIM TO 11/08/88 DEADLINE
CALL-IN OF STORAGE AND TREATMENT APPLICATIONS
EXTENSION OF DEADLINE FOR PART A SUBMITTAL ANO INTERIM STATUS APPLICABILITY FOR CEMENT KILNS
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS, HIGH PRIORITY PERMITTING
LAND OISPOSAL FACILITIES NOT ON A PERMITTING OR CLOSURE SCHEDULE
LANO OISPOSAL RESTRICTIONS EFFECT ON PERMITS
MISCELLANEOUS UNITS SUBPART X. IMPLEMENTATION GUIDANCE
PROPOSEO RULES IMPACT ON PERMIT DEADLINES
WASTE PILES ANO POST-CLOSURE PERMITS, APPLICATION OF NOVEMBER 1988 DEADLINE TO
Delegation of Authority
ENFORCEMENT OF STATE ANO EPA ISSUED PERMITS
NEWLY IDENTIFIED WASTE STREAMS AS A RESULT OF NEW TC
PERMITTING ISSUES (OUPONT EDGEMORE FACILITY) - GUIDANCE
SPLITTING FEDERAL RCRA PERMITS WITH THE STATE AUTHORIZATION
STATE PERMIT ISSUED BEFORE RECEIVING RCRA PHASE II AUTHORIZATION
01)
03)
13)
02)
06)
04)
20)
13)
05
01)
Oil
01)
10)
9477.19861
9502.19871
9441.19871
9481.19871
9502.1985'
9488.1985
9502.1986!
9528.1989
9476.19851
9505.19871
9524.19891
9489.1985!
9488.19861
9522.00-3
9488.00-2
9525.1988102
9488.1986(04
9522.1986(03
9521.1984(02
9521.1986(04
9503.50-1A
9441.1986(22)
9502.1987(05
9472.1988(01
9441.1989(11
9523.00-17
9523.00-18
9523.00-15
9523.00-14
9476.1987(01)
9484.00-5a
9488.00-3
9453.1986(08)
9502.00-3
9524.1989(02
9524.1989(03
9433.1986(08)
9521.1988
9528.1988
9528.1987
9501.1986
9501.1987
9522.00-1
9489.00-2
9501.1987(03)
9501.1985(01)
9522.1990
9528.1990(
9525.1988
9521.1990
9542.1982
01)
03)
02)
01)
03)
01/03/86
03/06/87
03/04/87
03/10/87
10/29/85
05/30/85
12/08/86
10/15/89
12/13/85
08/13/87
02/27/89
09/20/85
09/11/86
11/13/87
06/10/86
07/01/88
04/11/86
11/20/86
05/07/84
04/30/86
12/23/85
03/19/86
04/02/87
06/02/88
03/27/89
09/02/88
03/14/89
03/30/88
03/14/86
06/09/87
10/15/88
06/30/86
12/22/86
08/04/86
03/02/89
03/23/89
03/24/86
04/19/88
04/19/88
09/18/87
09/11/86
09/17/87
09/15/87
04/22/83
12/28/87
10/01/85
01/26/90
07/11/90
07/01/88
05/23/90
08/09/82
-------
Page No.
04/06/92
KEYWDRO INOEX
Joint Permitting
PIG-82-5 A()0 RSI 15 JOINT PERMITTING IN PHASE I AUTHORIZED STATES
RCRA PERMIT REAUTHORIZATION ISSUES IN REGION III
RCRA PERMITS WITH HSVA CONDITIONS - JOINTLY ISSUED PERMITS
WASTE MINIMIZATION: PERMIT CERTIFICATION AND JOINT PERMITTING
WASTES NEWLY REGULATED UNDER HSWA, MANAGEMENT OF
On-alte Waste Management
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL AND HAZARDOUS
0NS1TE TREATMENT BY GENERATORS
PERMIT ISSUES REGARDING ON-SITE TREATMENT BY FLUIDIZED BED INCINERATION
TEMPORARY EXCLUSION APPLIED TO ONLY ONE FACILITY (MONROE AUTO)
TREATMENT OF HAZARDOUS WASTE IN GENERATOR'S ACCUMULATION TANKS
Permit Oantal
•APPEAL/RECOURSE PROCESS FOR PERMIT DENIAL
DENIAL OF RCRA OPERATING PERMITS
Permit Modification
•AD0IT10N OF A SURFACE IMPOUNDMENT TO AN EXISTING INTERIM STATUS FACILITY
~CHANGES AT INTERIM STATUS TANK FACILITIES
'CONSTRUCTION DURING INTERIM STATUS WHERE ORIGINAL UNITS ARE CLOSED
•CORRECTIVE ACTION AND PERMITS
•CORRECTIVE ACTION REQUIREMENTS WHILE SEEKING A MAJOR PERMIT MODIFICATION
•INTERIM STATUS VS. PERMIT MODIFICATION FOR NEWLY-REGULATED UNITS
•PERMIT MODIFICATION
•STOCK TRANSFER - EFFECT ON PART A PERMIT APPLICATION
•TERMINATION OF PERMITS
» AMENDED DEFINITION OF SOLID WASTE - PERMIT MODIFICATIONS
INTERIM STATUS EXPANSION TO AOD AN INCINERATOR
MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONS
NEW WASTE STREAMS AT INTERIM STATUS FACILITIES
r-„	NEWLY IDENTIFIED WASTE STREAMS AS A RESULT OF NEW TC
^	NEWLY REGULATED UNITS AT PERMITTED FACILITIES
J-.	CrOUtT PBflfrtC f«IHTC
PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUS
PUBLIC COMMENT PERIODS FOR PERMIT MODIFICATIONS
SCINTILLATION VIALS CONTAINING D001 WASTES, MANAGEMENT OF
SOLVENT MIXTURES. FINAL RULE TO LIST - PERMIT MODIFICATIONS
SPLITTING FEDERAL RCRA PERMITS WITH THE STATE AUTHORIZATION
TREATMENT OF RADIOACTIVE WASTES AT HAZARDOUS WASTE PERMITTED TSOF
PERMIT REQUIREMENTS
(See Permit Conditions)
PERMIT STANDARDS
(See Permit Conditions)
9543.00-1
9541.1985(01)
9502.1987(06)
9560.1985(01
9541.1985(05)
10/03/85
03/06/85
06/30/87
09/11/85
05/06/85
9432.1986(
9453.19871
9522.1985
9441.1987i
9453.1987!
H)
03
05)
30)
02)
09/06/86
07/01/87
12/13/85
04/30/87
03/25/87
9521.1986(04a)
9523.00-11
04/30/86
12/10/86
9528.1985(01
9528.1987(09
9528.1987(03
9525.1988(01
9502.1986	03
9525.1989(01
9525.1985(01
9525.1984(01
9525.1986(06
9525.1986(02
9528.1987	15
9554.1990(08
9S28.1990(01
9528.1990(03
9528.1986(04
9521.1986 02
9528.1986(08
9529.1990(01
9525.1986(04
9525.1986(01
9521.1990(01
9525.1990(02
12/30/85
08/30/87
03/30/87
02/28/88
01/30/86
05/30/89
10/30/85
08/30/84
11/30/86
03/27/86
11/25/87
07/31/90
04/02/90
07/11/90
01/30/86
03/24/86
11/20/86
08/30/90
08/11/86
03/24/86
05/23/90
10/17/90
XREF
/ /
XREF
/ /
-------
Page No,
04/06/92
KEYWORD INDEX
PERMITTING
(Sm Closure Process, Permit Process)
PERSONNEL TRAINING
XREF
/ /
•PERSONNEL TRAINING DURING POST CLOSURE
PESTICIDES
(Sea Agricultural Waste) (See also Hazardous Waste Identification)
PETITIONS
9523.1985(05) 10/30/85
XREF
/ /
V>
(Sm also Exclusions, Delisting. Land Disposal Restrictions)	XREF	/ /
•APPEALING DENIAL OF PETITION TO DELIST A HAZARDOUS WASTE	9433.1907(04)	02/28/07
•DELISTING OF K051 WASTE AT PETROLEUM REFINERY-EFFECT ON INTERIM STATUS	9433.1986(12)	04/30/86
ATSOR HEALTH ASSESSMENTS UNDER RCRA 3019	9523.1986(05)	11/21/86
COMBINATION OF SLUDGES FROM ALL IMPOUNDMENTS TO DETERMINE WASTE VOLUME FOR VHS ANALYSIS	9433.1987 07	04/13/87
0EL1STING ISSUES RELATING TO EPA'S MOBILE INCINERATOR	9433.1986(20}	12/11/86
DELISTING PETITION - FUJI PHOTO FILM WASTEWATER TREATMENT SLUDGE	9433.1991 01)	03/07/91
0ELIST1NG PETITION FOR INCINERATOR ASH	9433.1991(03)	07/10/91
DELISTING PETITION OF NITROGEN TETROXIDE RINSATE	9433.1990107	12/21/90
0EL1STING PETITIONS, PROCEDURES FOR PROCESSING	9433.1907 15	07/28/87
DELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIES	9433.1987 22	10/02/07
DELISTING, INTERIM STATUS. AND SAMPLING ISSUES AT U.S. NAMEPLATE COMPANY	9433.1987(03)	02/25/87
DENIAL OF DELISTING PETITION BASED ON EXISTING GROUNDWATER CONTAMINATION	9433.1987(05)	03/19/87
ELECTROPLATING SLUDGE, EXCLUSION PETITION	9433.1984(05)	12/11/84
EVALUATION OF DELISTING PETITIONS-INFORMATION REQUIRED	9433.1906(04)	02/14/06
EXTENSION OF APPLICABLE EFFECTIVE DATE OF THE LAND DISPOSAL RESTRICTIONS	9551.1908(09)	00/11/00
GROUNDWATER CONTAMINATION AS A BASIS TO OENY A DELISTING PETITION	9433.1987(08)	04/24/07
INTERIM STATUS SURFACE IMPOUNDMENTS ft CLEAN CLOSED WASTE PILES. CODIFICATION RULE 12/01/87	9522.1980(05)	11/30/00
K103/KI04 WASTE STREAMS - RELATIONSHIP OF CWA BAT. LAND DISPOSAL RESTRICTIONS, BOAT, AND DELISTING CRITERIA	9433.1907(06)	04/02/87
METAL. K061 WASTES IN SURFACE IMPOUNDMENT-DELISTING PETITION	9433.1987(18)	08/07/87
NO-HIGRATION PETITION FOR AMOCO REFINERY	9551.1990(13)	11/08/90
NO-MIGRATION PETITION FOR ARCO PRODUCTS, WA	9551.1990(08)	10/24/90
NO-HIGRATION PETITION FOR ATLANTIC REFINING i MARKETING, PA	9551.1991(06)	04/22/91
NO-MIGRATION PETITION FOR CONOCO, NT	9551.1991 09)	05/29/91
NO-HIGRATION PETITION FOR EXXON, TX	9551.1991(03)	01/29/91
NO-MIGRATION PETITION FOR KERR-MCGEE REFINING, OK	9551.1991(05)	02/05/91
NO-MIGRATION PETITION FOR KOCH'S REFINING, TX	9551.1991(01)	01/03/91
NO-MIGRATION PETITION FOR KOCH REFINING. TX	9551.1991(12	12/10/91
NO-MIGRATION PETITION FOR MARATHON PETROLEUM, 1L	9551.1990(09	11/06/90
NO-HIGRATION PETITION FOR ROBINSON, IL	9551.1991 14)	05/01/91
NO-MIGRATION PETITION FOR SHELL OIL. WA	9551.1990 11)	11/07/90
NO-MIGRATION PETITION FOR SINCLAIR OIL. OK	9551.1990 12	11/00/90
NO-HIGRATION PETITION FOR STAR ENTERPRISE, OE	9551.1990(10)	11/07/90
NO-HIGRATION PETITION FOR SUN REFINING, OK	9551.1991 02	01/17/91
NO-HIGRATION PETITION FOR TEXACO. WA	9551.1991 00	05/29/91
PERFORMANCE STANDAROS FOR DISPOSAL IN SALT DOMES	®1E!22i ?5	02/22/91
PETITION TO WITHDRAW K090 AND K091 LISTINGS	9444.1989(111	10/03/09
REINTERPRETATION NARROWING THE SCOPE OF THE F006 LISTING	9444.1986 2	10/04/06
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE	9433.1986(11)	04/24/06
-------
Fag* No. /
04/06/92
\
KEYWORD INDEX
SAMPLING PLAN FOR DELISTING PETITION FOR WASTES IN LANDFILL TRENCHES
SAMPLING REQUIREMENTS FOR ESTIMATING VARIABILITY OF WASTES FOR DELISTING PETITIONS
SPENT PICKLE LIQUOR DELISTING PETITION
TEMPORARY AND INFORMAL DELISTINGS AND HSWA EFFECTS ON BOTH
WASTEWATER TREATMENT SLUDGES CONTAINING METHANOL
PETROLEUM REFINERY WASTE
9433.1906(21)
9433.1986(22
9433.1991(02
9433.1906(14
9441.1989(52
12/13/66
12/18/86
04/26/91
05/27/86
10/06/89
PETROLEUM REFINING WASTES AND EXEMPTIONS FOR WWTUs
PETROLEUM REFINERY WASTES
9483.1990(03) 09/20/90
c
(Sea also Exclusions, Delisting)	XREF
•BURNING/BLENDING OF UNUSEO COMMERCIAL CHEMICAL PRODUCT (XYLENE) WITH USED OIL	9442.1985(01
•OFF-SPECIFICATION USED OIL FUEL	9454.1986 02
•PETROLEUM REFINERY WASTEWATER TREATMENT SLUDGE CLASSIFICATION	9444.1991 01
•RECYCLED USED OIL-TECHNICAL CRITERIA FOR LISTING, COURT DECISION	9433.1988(02
•USED OIL AS OUST SUPPRESSANT	9493.1985(06
•USED OIL, DEFINITION OF 4	9431.1988 01
ATOMIZER MULTI-OIL FUELED HEATERS, INSPECTION AND CERTIFICATION CRITERIA FOR	9495.1980(02
AUTOMOTIVE FLUIDS. REGULATION OF !	9441.1987(14
BOILERS USED IN GREENHOUSE OPERATIONS ARE IN0USTR1AL BOILERS	9432.1986 03
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY	9441.1986 95
DECISION NOT TO REQUIRE NOTIFICATION FROM GENERATORS WHO BURN SPECIFICATION USED OIL ON-SITE	9495.1987(05
DERIVED FROM/MIXTURE RULE APPLICATION TO REFINERY WASTEWATER TREATMENT SYSTEMS	9441.1987 70
DRAINAGE WATER BENEATH LAND TREATMENT UNITS AT OIL REFINERIES	9486.1900 01
DRAINAGE WATER BENEATH LAND TREATMENT UNITS - NO MIGRATION PETITIONS	9551.1988 15
EXPORTING PETROLEUM WASTE TO SOUTH AMERICA	9455.1989(01
HSWA PROHIBITION ON THE USE OF HAZARDOUS WASTE AS A DUST SUPPRESSANT	9493.00-lA
LAND TREATMENT PERMIT APPLICATIONS - REFINERY WASTE ANALYSES GUIDANCE	9523.1984(02
MIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS	9451.1989(02
NO-MIGRATION PETITION FOR AMOCO REFINERY	9551.1990(13
NO-MIGRATION PETITION FOR EXXON. TX	9551.1991(03
NO-MIGRATION PETITION FOR KOCH'S REFINING. TX	9551.1991(01
NO-MIGRATION PETITION FOR MARATHON PETROLEUM, IL	9551.1990 09
NO-MIGRATION PETITION FOR ROBINSON, IL	9551.1991 14
NO-MIGRATION PETITION FOR SHELL OIL, WA	9551.1990(11
NO-MIGRATION PETITION FOR SUN REFINING, OK	9551.1991 02
OIL ANO GAS EXPLORATION EXCLUSION	9441.1987(04
OIL/WATER EMULSIONS GENERATED BY PETROLEUM REFINERY WW SYSTEMS-K049 WASTE	9441.1984(35
PETROLEUM FACILITIES INCLUDED IN THE K051 LISTING FOR API SEPARATOR SLUOGE	9444.1987(20
PETROLEUM REFINERY SLUOGE REGULATIONS	9444.1990(05
PETROLEUM REFINERY WW, MIXTURE AND OERIVED-FRON RULES	9441.1985 29
srciHrov ittCTfiMTFB	9444.1960(02
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE	9493.1991(01
SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS	9441.1985(08
SHELL OIL FACILITY - TC COMPLIANCE 		9431.1991 02
UNDERGROUND INJECTION WELLS USED IN HYDROCARBON RECOVERY	9521.1991 02
USED OIL BURNED FOR ENERGY RECOVERY. INTERPRETATION OF SUBPART E	9495.1989(01
USED OIL CONTAMINATION THROUGH NORMAL USE OR MIXING WITH HAZARDOUS WASTES, RECYCLIN6 DEFINED	9441.1984(30
USED OIL INTRODUCED INTO REFINERY PROCESS UNDER HAZARDOUS WASTE DERIVED REFINERY FUEL PROOUCTS EXEMPTION	9441.1986(11
WASTE AS FUEL RULES AT DOD FACILITIES. IMPLEMENTATION	9494.1986(02
/ /
12/30/85
02/28/86
02/01/91
11/30/88
12/30/85
01/30/88
09/22/80
03/06/87
01/09/86
12/23/86
03/26/87
08/28/87
01/02/88
01/21/88
06/27/89
05/31/86
04/03/84
06/26/09
11/08/90
01/29/91
01/03/91
11/06/90
05/01/91
11/07/90
01/17/91
01/13/87
12/07/84
05/26/87
10/17/90
08/23/85
11/13/80
01/08/91
02/22/85
05/09/91
08/30/91
05/15/89
10/22/84
02/11/86
03/19/86
-------
Pan No,
04/06/92
KEYWORD INDEX
PHOSPHATE WASTES
(Sm Hazardous Waste Identification)
PICKLE LIQUOR
XREF
I /
(See Electroplating)
XREF
POHCs
/ /
(See Incineration)
POST-CLOSURE
XREF
/ /
V
(See also Cloture. Cost Estimates, Financial Responsibility, Groundwater Monitoring, Post-Closure Permits)
"AOJUSTMENT OF POST-CLOSURE TRUST FUNDS USEO FOR FINANCIAL ASSURANCE
•CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT AND WASTE PILE
•CORRECTIVE ACTION IN PERMITS
*GROUNDWATER MONITORING - COMPLIANCE PERIOD/POST-CLOSURE CARE PERIOD
'GROUNDWATER MONITORING-ASSESSMENT MONITORING/CORRECTIVE ACTION AT CLOSEO INTERIM STATUS FACILITIES
•POST CLOSURE PERMITS FOR SURFACE IMPOUNDMENT
3008(h) ORDERS OR POST-CLOSURE PERMITS AT CLOSING FACILITIES, USE OF
CLOSURE I POST-CLOSURE REQUIREMENTS REGARDING HAZARDOUS WASTE TREATMENT, STORAGE AND 01SP0SAL FACILITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES
CORRECTIVE ACTION REQUIREMENTS FOR FEDERAL FACILITIES AND IRP ACTIVITIES
DENIAL OF RCRA OPERATING PERMITS
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS, HIGH PRIORITY PERMITTING
INSTALLATION RESTORATION PROGRAM (IRP) - 000
INTEGRITY ASSESSMENT FOR TANKS AND POST-CLOSURE
PERMITTING UNITS CREATEO FOR FACILITY CLOSURE
POST CLOSURE PERMIT REQUIREMENTS (ARMCO STEEL)
POST CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS
POST-CLOSURE PART B PERMIT REQUIREMENTS
POST-CLOSURE PERMIT PART S REQUIREMENTS
POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITS
POST-CLOSURE REQUIREMENTS FOR SURFACE IMPOUNDMENTS LOCATED IN A 100 YEAR FLOOD PLAIN
RCRA PROGRAM DIRECTIONS - PRIORITY TO ENVIRONMENTALLY SIGNIFICANT FACILITIES
RELEASES OF HAZARDOUS WASTE, RCRA APPLICABILITY TO
SURFACE IMPOUNDMENT CLOSURE. APPLICABILITY OF 3005(1) OF RCRA TO
XREF
9477.1906(05
9522.1988(01.
9521.1966(06a)
9401.1988(03)
9481.1988 02)
952Z.1986(02a)
9502.00-7
9476.1983(02
9476.1966 01
9502.1986(04
9502.1986	06
9502.1986(14
9523.00-11
9501.1986(01
9502.1986(20
9483.1989(04
9476.1985(03
9522,1986(03)
9521.1985 01
9523.1985 06
9523.1985(07
9476.1985(04
9484.1984(02
9501.1987	02
9502.1987 05
9476.1987(01
/ /
11/30/88
02/28/88
06/30/86
04/30/88
04/30/88
10/30/86
03/08/88
01/11/83
05/08/86
02/13/86
04/15/86
08/22/86
12/10/86
09/11/86
12/08/86
10/30/89
09/11/85
11/20/86
09/25/85
11/18/85
11/18/85
09/25/85
12/31/84
12/14/87
04/02/87
06/09/87
POTW
(See Wastewater)
PRE-CONSTRUCTION BAN
XREF
/ /
(See Permit Application)
XREF
/ /
-------
Page No,
04/06/92
KEYWORD INDEX
PRECIOUS METALS
(See Recycle)
PROCEDURE
(Sea Test Methods)
PROCESS WASTES
(Set Hazardous Watte Identification)
PROTECTIVE FILERS
(See Interim Status Process)
PUBLIC PARTICIPATION
(See also Closure. Post-Closure)
'CLOSURE PUN PUBLIC COMMENT PERIOD FOR INTERIM STATUS FACILITIES
FIELD ASSESSMENT AND PUBLIC INVOLVEMENT PLAN FOR THE OCCIDENTAL INCINERATOR
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS, HIGH PRIORITY PERMITTING
PUBLIC COMMENT PERIODS FOR PERMIT MODIFICATIONS
PUBLIC PARTICIPATION PROGRAM REQUIREMENTS FOR FY 1986
~ RCRA PERMITS WITH HSWA CONDITIONS - JOINTLY ISSUED PERMITS
QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
(See also SW-B46)
-r-	ANALYTICAL HETHQuS/EP TOXICITY TEST/REFERENCE STDS.
QC REVIEW OF PERMIT DATA
©P	RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)
RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES NOTES)
RCRA METHOOS ANO QUALITY ASSURANCE ACTIVITIES NOTES)
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMNEN S
SW 846 METHODS MANUAL
RAGS AND WIPERS
(See Solvents)
RCRA FACILITY ASSESSMENT (RFA)
(See Corrective Action)
XREF
/ /
XREF
/ /
XREF
/ /
XREF
/ /
XREF
94?6.I98?i
9505.1986!
9501.19861
9525.19901
9505.19851
9502.198?!
0?)
01)
01)
01)
01
06}
/ /
11/30/8?
09/18/86
09/11/86
08/30/90
11/13/85
06/30/8?
XREF
9445.1984
9442.1990
9445.1985
9445.1984
9445.1984(
9523.00-12
9445,1987(02)
02)
04}
04)
01)
05)
/ /
04/23/84
11/01/90
06/30/85
04/23/84
12/20/84
03/30/8?
09/16/8?
XREF
/ /
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
RCRA/CERCIA INTERFACE
ACl« UNDER THE RCRA AND CERCLA PROGRAMS, USE OF
DELISTING, INTERIM STATUS, AND SAMPLING ISSUES AT U.S. NAMEPLATE COMPANY
FEDERAL FACILITIES INVENTORY UNDER RCRA 3016
FEDERAL POLICY REGARDING DIOXIN DISPOSAL
GENERATOR LIABILITY FOR DELISTED WASTE RELEASES
LAND DISPOSAL RESTRICTIONS CLARIFICATIONS
PIPELINE TRANSPORTATION OF HAZARDOUS WASTE
RCRA PERMIT REAUTHORIZATION ISSUES IN REGION III
CERCLA (Superfund)
CORRECTIVE ACTION PLAN (CAP). CONTENTS AND USE OF
HAZARDOUS WASTE MANAGEMENT CAPACITY AND RCRA CONSISTENCY ISSUES
HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS, CERCLA AND RCRA LIABILITY OF MUNICIPAL SPONSORS OF
LIABILITY AND RESPONSIBILITY FOR TRANSPORTATION AND DISPOSAL OF SMALL QUANTITIES OF HAZARDOUS WASTE
OWNER/OPERATOR UNDER RCRA AND CERCLA, DEFINITION OF
PLACEMENT OF RCRA FACILITIES ON THE CERCLA NATIONAL PRIORITIES LIST, POLICY FOR
9481.1966(06
9433.1987
9502.1987
9444.1987
9433.1985
9551.1987
9432.1986
9541.1985
9502.1987
9572.1988
9441.1986
9451.1986
9432.1987
9504.1986
(03
03
26
04
01
08
01
08/06/86
02/25/87
03/06/87
07/02/87
10/23/85
01/20/87
04/30/86
03/06/85
03/13/87
12/23/88
01/28/86
03/24/86
10/28/87
06/12/86
RCRA
INTERIM STATUS SURFACE IMPOUNDMENTS & CLEAN CLOSED WASTE PILES, CODIFICATION RULE 12/01/87
OWNER/OPERATOR UNDER RCRA AND CERCLA. DEFINITION OF
RECYCLING ACTIVITIES
UCAPCO APPLICATION FOR A VARIANCE UNDER 3004(c)(2) OF RCRA
UIC CORRECTIVE ACTION REQUIREMENTS, IMPLEMENTATION
9522.1988(05
9432.1987(12
9451.1989(01
9480.1987(02
9502.00-3
11/30/88
10/28/87
05/03/89
10/29/87
08/04/86
Tax
SPENT SOLVENT RECOVERY. WASTE MANAGEMENT TAX
* Treatability Study
•TREATABILITY STUDIES SAMPLE EXEMPTION
DESIGNATED FACILITY UNDER THE TREATABILITY STUDY EXCLUSION
RD&D PERMIT
9441.1986(41) 05/20/86
9441.1989(56)
9432.1991(01)
11/30/89
09/27/91
•5 >
—O
CHEMICAL AGENT/MUNITIONS SYSTEM (CADMS) IS NOT TOTALLY ENCLOSED AND SUGGESTED RD&D PERMIT
DESTRUCTION OF DIOXIN CONTAMINATED SOIL USING MOBILE INCINERATION
RD&D PERMIT FOR A SLUOGE DRYING PROCESS IN A WASTE WATER SYSTEM
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR WET-AIR OXIDATION UNITfVERTECH)
9432.1985(07)
9433.1986(10)
9503.51-1A
9432.1986(06)
11/19/85
04/24/86
12/24/85
02/06/86
REACTIVE WASTES
(See Characteristic Hazardous Waste)
RECLAMATION
XREF
/ /
(See also Solid Waste. Recycle, Solvents, Used OH)
"CLOSEO LOOP RECYCLING
•CORRECTIVE ACTION REQUIREMENTS AT FACILITIES HANDLING SCRAP METAL RECLAMATION
'EXPORTING HAZARDOUS WASTE
'NOTIFICATION REQUIREMENTS FOR RECYCLABLE MATERIALS
•SLUDGES WHEN RECLAIMED. REGULATION OF
•SOLID AND HAZARDOUS WASTE, DEFINED FOR SPENT SULFURIC ACID
XREF
9471.1988(06
9502.1985(04
9456.1987(01
9441.1988(13
9441.1986(59
9441.1986(17
/ /
12/30/88
06/30/85
08/30/87
04/30/88
06/30/86
02/28/86
-------
Paat No.
04/06/92
\
KEYWORD INDEX
U">
o
~SPENT LEAD ACID BATTERIES
•SOS QUANTITY DETERMINATION, MULTIPLE COUNTING EXEMPTION
BATTERY RECONDITIONING
BRIQUET!ING OF FLUE DUST (K061) FOR STEEL PRODUCTION
BY-PRODUCT CRUDE OIL TANK BOTTOMS
CHARACTERISTIC SLUOGES RECLAIMED OR PROCESSED PRIOR TO USE AS AN INGREDIENT IN FERTILIZER
CHLOROFLUOROCARSONS (CFCi) AS REFRIGERANTS, RECYCLING OF SPENT
COMMERCIAL CHEMICAL PRODUCTS, RECYCLING A MIXTURE OF
COUNTING DRY CLEANING INDUSTRY WASTE ONLY AFTER REMOVAL FROM THE PROCESS - SQG RULE
DISPOSAL OR RECLAMATION OF RAGS
OROVE RECLAMATION IN BRASS INDUSTRY, BY-PRODUCT DESIGNATION
ETCHANTS USED TO MANUFACTURE COPPER SALTS
FLUE DUST AND NETAL HYDROXIDE SLUDGE RECYCLING/RECLAMATION
HANDLING OF RAGS AND SIMILAR MATERIALS ABSORBING
MERCURY SUITABLE FOR DIRECT USE (99% PURE) NOT SOLID WASTE
MERCURY THERHOHETERS, RECLAIMED OFF-SPEC AND BROKEN
MERCURY, REFINING/REUSE OF SCRAP
NETAL GALVANIZING PROCESS RESIDUES AS BY-PRODUCTS/SECONDARY MATERIALS
MOBILE RECYCLING UNIT FOR REPROSSESING WASTE SOLVENTS
PESTICIDE RINSEATE TREATMENT/RECYCLING SYSTEM
PHOTOGRAPHIC FIXER RECYCLING
PICKLE LIQUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE
RECLAIMED METHANOL IS A PROOUCT RATHER THAN A WASTE
RECLAIMING PRECIOUS METALS FORM DISCARDED AUTOMOTIVE AND ELECTRONIC DEVICES
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
RECYCLEO PRECIOUS METALS, BATTERIES FROM DEFENSE OEPT. SUPPLIES
RECYCLING NICKEL. COPPER AND CHROMIUM-CONTAINING ELECTROPLATING SLUDGES
RECYCLING OF HOLDING AND CASTING SANDS
REPROCESSING OF BATTERIES
RESIDUE FROM SPENT SOLVENT RECLAMATION CONSIDERED HAZARDOUS
SECONDARY LEAD SMELTER VARIANCES
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY, CHEMICAL RECOVERY CARTRIDGES FOR
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS
SPENT LEAO-ACID BATTERIES MANAGEMENT
SPENT PICKLE LIQUOR USED/REUSED IS NOT SOLID WASTE
SPENT PICKLE LIQUOR, DEFINITION AS HAZAROOUS
SPENT-LEAD ACID BATTERIES BEING RECLAIMED
STILL BOTTOM WASTE GENERATED OURING THE PRODUCTION OF POLYSTYRENE
THERMAL OXIDIZER AND HYOROOECHLORINATION PROCESS BY-PRODUCT K-WASTES
ZINC OXIDE RECLAIMED FROM KILNS
9441
9441
9441
9441
9441
9497.1989(01)
9441.1966 64)
9441.1906(56)
9441.1987 58
9441.1966(371
9493.1985	03)
9441.1989|40l
9441.1966(34)
9441.1986(67)
9444.1909(13)
1989(15
1986(82)
1989 10
1969(50
1966(43)
9441.1986	27)
9441.1986	06
9441.1989(14)
9441.1986(30)
9471.1988(04)
9496.1990(01)
9432.1987	13
9441.1985(33)
9432.1989(03)
9441.1985(39)
9441.1986(85)
9441.1988(09)
9441.1966(01)
9497.1987 02)
9441.1984 03
9444.1988(14)
9443.1987(01)
9441.1966(89)
9497.1989(02)
1986(61)
1987(39)
9497.1987(03)
9441.1988(40
9444.1987(44)
9444.1988(02a)
9441
9441
01/31/89
08/30/86
07/28/86
07/31/87
05/01/86
11/25/85
08/02/89
04/28/86
09/08/86
10/20/89
04/05/89
11/08/86
03/27/89
10/20/89
05/30/86
04/02/86
01/21/86
04/02/89
04/16/86
10/27/88
07/16/90
11/10/87
10/23/85
06/06/89
11/25/85
11/19/86
04/06/88
01/06/86
02/19/87
02/16/84
08/26/88
01/06/87
12/02/86
10/19/89
08/16/86
05/20/87
04/17/87
09/01/88
10/16/87
01/26/88
Recovery
*HAZARDOUS WASTE FUEL IN INCINERATORS
•OFF-SPECIFICATION CIRCUIT PRINTING BOARDS - REGULATORY STATUS
•RECOVERED MATERIALS, FEOERAL PROCUREMENT OF
COPPER-BEARING SECONDARY MATERIALS AS FEEDSTOCK
EXEMPTION FOR COMMERCIAL CHEMICAL PRODUCTS BURNED FOR ENERGY RECOVERY
RECLAMATION OF SPENT ALKALINE ETCHANT-REQUEST FOR VARIANCE UNDER MOO. CLOSEO-LOOP PROVISION
RECOVERED LEAD ANO LEAD ALLOYS FROM BATTERIES
RECYCLING OF ZINC OXIDE BAGHOUSE DUST
RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES
SILVER RECOVERY IN THE PHOTOGRAPHIC 1N0USTRY	, 			
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER
SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMED XYLENE
SPENT SOLVENT RECOVERY, WASTE MANAGEMENT TAX
STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION
TC RULE - IMPLEMENTATION
9441.1986(87)
9441.1991(14)
9493.1986 02
9441.1988(08)
9441.1988(33)
9433.1985(06)
9455.1991(03)
9443.1987(25)
9487.1986	08)
9441.1987	02
9441.1988(49)
9441.1987 24
9441.1986(41
9444.1967(38
9441.1990(29)
11/30/86
08/01/91
03/30/86
03/22/88
07/27/88
10/29/85
12/10/91
11/04/87
05/27/86
01/06/87
12/06/88
04/15/87
05/20/86
09/01/87
10/01/90
-------
04/06/91
\
KEYWORD INDEX
USED OIL. BURNINS OF OFF-SPECIFICATION FUEL - DUMPING
USED REFRIGERANTS UNDER 40 CFR 261.2
Unused Materials
OFF-SPECIFICATION JET FUELS. RECYCLING OF UNUSED
RETURNED PHARMACEUTICAL PRODUCTS
RECOVERY
RECYCLE
(See Reclamation)
9441.1986(40)
9441.1990(28)
9441.1909(39
9455.1991(02
XREF
OF/31/86
10/18/90
07/31/09
05/16/91
/ /

(See also Reclamation, Solid Waste)
'EXPORTING HAZARDOUS WASTE
~RECOVEREO MATERIALS, FEDERAL PROCUREMENT OF
•RECYCLED USED OIL-TtCHNICAL CRITERIA FOR LISTING, COURT DECISION
~SHAH RECYCLING POLICY APPLIED TO CERTIFIED BIFt
~SHALL QUANTITY DETERMINATION FOR SOLVENT RECLAIMER
~STORAGE PRIOR TO RECYCLING
~USED OIL AS OUST SUPPRESSANT
AUTOMOTIVE FLUIDS, REGULATION OF
BATTERY RECONDITIONING
BATTERY RECYCLING AND EXPORT
BLAST SLAG TESTING PROCEDURES
BRASS DROSS SKIMMINGS, SEPARATION OF METALS AND OXIOES, BY-PRODUCT
BY-PRODUCT CRUDE OIL TANK BOTTOMS
CHARACTERISTIC SLUDGES RECLAIMED OR PROCESSED PRIOR TO USE AS AN INGREDIENT IN FERTILIZER
CHLOROFLUOROCARBON RECYCLING
CLEAN SOLVENT FROM RECYCLED SOLVENT-CONTAINING WASTE - STILL BOTTOMS
CLOSURE COST ESTIMATES BASED ON THIRD PARTY COSTS
COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)
COMMERCIAL CHEMICAL PRODUCTS USED IN AIR BAGS - EFFECT ON RECYCLE OF FERROUS SCRAP FROM AUTOMOBILES
COMMERCIAL CHEMICAL PROOUCTS, RECYCLING A MIXTURE OF
COMMERCIAL FERTILIZERS VERSUS SOIL AMENDMENTS
ETCHANTS USED TO MANUFACTURE COPPER SALTS
EXEMPTION FOR COMMERCIAL FERTILIZERS ONCE THE FERTILIZER IS PRODUCED
EXPORT REQUIREMENTS FOR SPENT BATTERIES SENT TO FOREIGN COUNTRIES FOR RECYCLING
FLUE DUST AND METAL HYDROXIDE SLUDGE RECYCLING/RECLAMATION
FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)
FOUNDRY SANDS RECYCLED ANO RETURNED TO THE FOUNDRY
GENERATOR RECYCLING HAZARDOUS WASTE ON-SITE
HAZARDOUS WASTE FUEL CADENCE PRODUCT 312. REGULATION OF
HAZARDOUS WASTE RECYCLING
HAZARDOUS WASTES THAT ARE RECYCLED. HANDLING
INCINERATOR RESIDUES/RECYCLING DEFINED/ACCUMULATION
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES ANO THE RESIDUALS GENERATED (LOUISIANA REG)
INDUSTRIAL PLATING OPERATIONS, STATUS OF VARIOUS WASTES FROM
LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENT
MIXTURES OF SPENT SOLVENTS - F001-F005. REGULATORY STATUS OF
MIXTURES OF WASTES AND LEGITIMATE BURNING FOR ENERGY RECOVERY
MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTS
MOBILE SOLVENT RECYCLER. GENERATOR DETERMINATION FOR
NICKEL-CADMIUM BATTERIES RECYCLING
OFF-SPECIFICATION JET FUELS, RECYCLING OF UNUSED
XREF
9456.1987(01)
9493.1986	02
9433.1988 02
9408.1991(051
9441.1987	10
9475.1907 01
9493.1985 06
9441.1987(14)
9441.1986(56)
9497.1987(01)
9442.1989(09)
9441.1985	21
9441.1986(37)
9493.1985(03)
9441.1988(32)
9441.1987(26)
9477.1984(01)
9441.1987(98)
9441.1985(02)
9441.1986(34)
9493.1986(04)
9441.1986	82
9493.1986(03)
9455.1987(01)
9441,1989(101
9441.1988(40)
9441.1987	13
9453.1987(04
9494.1986(04)
9461.1980(01)
9441.1986(76)
9551.1989(06)
9494.1987(02)
9441.1988(50
9442.1986(04)
9441.1984(06)
9494.1987(03)
9441.1986(30)
9432.1986(13)
9497.1991(02)
9441.1989(39)
/ /
08/30/87
03/30/86
11/30/88
10/01/91
02/28/87
04/30/87
12/30/85
03/06/87
07/28/86
02/12/87
11/03/89
06/06/85
05/01/86
11/25/85
07/21/88
04/17/87
01/12/84
12/24/87
01/16/85
04/28/86
09/03/87
11/08/86
08/21/86
06/19/87
03/27/89
11/21/88
03/04/87
07/14/87
04/11/86
08/31/88
10/08/86
05/03/89
04/15/87
12/07/88
05/06/86
04/10/84
08/31/87
04/16/86
08/06/86
05/30/91
07/31/89
-------
Page Jlo.
04/06/92
KEYWORD INDEX
THREE AND FOUR-SIDEO. FLOWED STRUCTURES, REGULATORY CLASSIFICATION OF
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLIR
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
UCAPCO APPLICATION FOR A VARIANCE UNDER3004(c)(2) OF RCRA
F-Wastes
•MIXEO WASTE AND LAND BAN
REGULATED WASTES
(Sea Hazardous Waste Identification, Solid Waste)
REGULATION
MARINE DEBRIS IN WATERS. DISPOSAL OF
PERMIT COMPLIANCE/ENFORCEMENT ISSUES (REG. X)
PETROLEUM REFINERY SLUDGE REGULATIONS
PROPOSED RULES IMPACT ON PERMIT DEADLINES
SEDIMENT SAMPLE OlSPOSAL
TEMPORARY AND INFORMAL DELISTINGS AND HSWA EFFECTS ON BOTH
YAKIMA INDIAN NATION INVOLVEMENT IN RCRA ON TRIBAL AND CEDED LANDS
RELEASE
(See Corrective Action, Secondary Containment)
REMEDIATION
(See Corrective Action)
REPORTING INFORMATION
>3
(See also Generator, Notification)
MINERAL PROCESSING FACILITIES, REPORT TO CONGRESS
RD&D PERMITS - POLICY GUIDANCE
REPORTING REQUIREMENTS (SECTION 270.30(1)(10)
STATE/REGIONAL BIENNIAL REPORTS
RESIDUE
(See Derived-Fran Rule)
RETROFIT
(See Minimum Technology Requirements, Surface Impouniftnents)
#432.1987
9432.1986
9432.1987
9432.1986(
9480.1987
02)
07
01
15
02
04/02/87
02/11/86
03/17/87
12/22/86
10/29/87
9551.1989(02) 03/30/89
XREF
/ /
9432.1987(12a)
9522.00-3
9444.1990(05)
9501.1987103
9441.1989	12
9433.1986 14
9431.1990	01
11/04/87
11/13/87
10/17/90
12/28/87
03/31/85
05/27/86
11/05/90
XREF
/ /
XREF
/ /
XREF
9475.1989(01)
9503.50-1A
9524.1988(01
9454.1986
ISi
/ /
02/09/89
12/23/85
02/23/88
08/13/86
XREF
/ /
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
ZINC OXIDE OUST RECLAIMED OR USED AS FERTILIZER
Uae Constituting Disposal
000 FOLIC? FOR OEHILITIZATION OF MILITARY MUNITIONS
REFINERY WASTE
9441.1987(61)
9444.1985(18)
08/12/87
10/03/85
(Sec Petroleum Refinery Waste)
REGENERATION
XREF
/ /
(See Recycle)
REGULATED UNIT
XREF
/ /
VJpS
J See also Correctve Action. Groundwater Monitoring)
1NANCIAL ASSURANCE FOR CORRECTIVE ACTION
GROUNDWATER MONITORING AT REGULATED UNITS NEAR SVMUs THAT HAVE IMPACTED GROUND WATER
Definition
~BOAT FOR WASTEWATER
•ELECTROPLATING AND ELECTROLESS PLATING LISTINGS
•HOUSEHOLD HAZARDOUS WASTE
•LAND DISPOSAL RESTRICTIONS DEFINITIONS
•REMOVAL OF TC WASTE FROM A SURFACE IMPOUNDMENT
•SKINNER LIST
•SOLID AND HAZARDOUS WASTE. DEFINED FOR SPENT SULFURIC ACID
•TANK WASTEWATER TREATMENT UNIT DEFINITIONS
•USED OIL. DEFINITION OF
•WASTEWATER TREATMENT UNIT DEFINITION
AqUEOUS AS USED IN THE CORROSIVITV CHARACTERISTIC
BATCH, DEFINITION OF
BOILERS USED IN GREENHOUSE OPERATIONS ARE INOUSTRIAL BOILERS
BULKING OR CONTAINERIZING COMPATIBLE HAZARDOUS WASTES FOR TRANSPORTATION
DEACTIVATION (POPPING) FURNACES AS INCINERATORS
EMPTY CONTAINERS REGULATORY STATUS
EVAPORATOR USED TO REMOVE WATER FROM HAZARDOUS WASTE
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
HEAT RECOVERY UNIT AS A BOILER OR AN INCINERATOR
HOLDING, TEMPORARY. PERIOD, STORAGE, AND DISPOSAL (DEFINITIONS)
IN-EXISTENCE AND UNDER CONSTRUCTION-DEFINITIONS
INTEGRAL DESIGN STANDARD IN BOILER DEFINITION (LUBRIZOL)
LIQUID, FREE LIQUID, RELEASA6LE LIQUID DEFINITIONS
MARINE DEBRIS IN WATERS. DISPOSAL OF
OPERATED TO CONTAIN, DEFINITION
PIPELINE TRANSPORTATION OF HAZAROOUS WASTE
SECONDARY CONTAINMENT SYSTEMS CERTIFICATION
SLUDGE DEHYDRATION EQUIPMENT AS A WASTEWATER TREATMENT UNIT
SLUDGE DEHYDRATION EQUIPMENT THAT IS PART OF A WASTEWATER TREATMENT FACILITY
SLUOGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON VWTU EXEMPTION
SOLID WASTE MANAGEMENT UNIT DEFINED FOR CORRECTIVE ACTION UNDER 3004(u)
SOLIO WASTE MANAGEMENT UNIT FOR THE PURPOSE OF CORRECTIVE ACTION UNOER 3004(u), DEFINITION OF
STILL BOTTOM WASTE GENERATED BY A POLYSTYRENE PRODUCTION FACILITY
SULFUR RECOVERY FURNACES ARE INDUSTRIAL FURNACES SUBJECT TO THE WASTE-AS-FUEL RULES
XREF
9502.1986
9481.1987
9432.1986(16)
9432.1989 01)
9441.1988(30
9551.1986(23)
9443.1991(02)
9445.1985(06)
9441.1986(17
9432.1988(03)
9431.1988	01)
9432.1988(05)
9443.1907 19
9432.1989	05
9432.1986 03)
9432.1990	02)
9432.1987(07)
9432.1990(03)
9432.1987(03
9432.1986(05
9432.1985(08
9432.1986(12
9432.1989(02
9432.1985 10
9432.1989(04
9432.1987(12a)
9483.1989(06)
9432.1986(08)
9483.1988(10
9432.1987(08)
9522.1988(02)
9432.1986(01)
9502.1987(07)
9502.00-6
9432.1988(01
9432.1986
!8«l
/ /
08/22/86
06/17/87
12/30/86
08/30/89
06/30/88
12/30/86
11/01/91
08/30/85
02/28/86
03/30/88
01/30/88
10/30/88
09/14/87
12/05/89
01/09/86
03/01/90
07/17/87
09/13/90
05/01/87
02/OS/86
11/20/85
07/28/86
05/16/89
12/30/85
07/20/89
11/04/87
I1/30/89
04/30/86
12/12/88
08/03/87
03/07/88
01/06/86
07/24/87
07/02/89
02/11/88
01/21/86
-------
Page No.
04/06/92
\
KEYWORD INDEX
REUSE
UFA
RISK
($•• Recycle)
(See RCRA Facility Assessment)
XREF
XREF
/ /
/ /
(See Risk Assessment)
RISK ANALYSIS
XRIF
/ /
(See Risk Assessment)
RISK ASSESSMENT
XREF
/ /
(CAP), CONTENTS AND USE OF
WAT I ON IN LISTING DECISIONS
«>*>
—c,
HEALTH BASED VALUES FOR PAH'S IN COKE BY-PRODUCT WASTES
NO-MIGRATION PETITION FOR EXXON, TX
Exposure Information
ATSDR HEALTH ASSESSMENTS UNDER RCRA 3019
EXPOSURE INFORMATION REPORT REVIEW IN CONJUNCTION WITH ATSDR
~ Health Assessments
CORRECTIVE ACTION PLAN . ,
HEALTH ASSESSMENT INFORMATIt
HEALTH BASED LEVEL FOR CYANIDE
HEALTH BASED VALUES FOR CHEMICAL LIST
HEALTH BASEO VALUES FOR PAH'S IN COKE BY-PRODUCT WASTES
HEALTH STATUS OF PAH's IN COKE BY-PRODUCT WASTES
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
"Uk HAZARDOUS WASTE TREATMENT TECHNOLOGIES, APPLICATION OF
Risk Analysts
RISK-BASED HETHOOOLOGIES ON LANO 01SP0SAL RESTRICTIONS
SMALL QUANTITY GENERATOR WASTE STREAMS - TANK RISK ANALYSIS
9551.1969(04
9551.1991(03
9523.1986(05)
9523.1966(02)
9502.1987(04)
9442.1986(04a)
9442.1988(02)
9445.1989(02)
9551.1989(04)
9441.1989(28)
9523.00-12
9551.1986(07)
9441.1986(25)
07/06/89
01/29/91
11/21/86
07/31/86
03/13/87
05/09/86
03/30/88
07/18/89
07/06/89
06/12/89
03/30/87
9486.1985(01) 03/27/85
06/19/86
03/26/86
RUN-OFF
LEACHATE AND PRECIPITATION RUN-OFF AT LFi, WASTE PILES. AND IT UNITS. HAZARDOUS WASTE FROM MIXTURE OF
PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
9441.1984(37
9441.1986(31
9441.1986(28
11/14/84
04/21/86
04/07/86
-------
Page No.
04/06/92
KEYWORD INDEX
SAMPLE ANALYSIS
(See Analytic Method)
SAMPLING
(See Analytic Method)
SAMPLING PLAN
(See Analytic Method)
SANITARY LANDFILL
(See Municipal Landfill)
SCRAP HETAL
iSee alto Solid Waste)
ATTERIES, SCRAP METAL. AND PRECIOUS METALS
MOVE RECLAMATION IN BRASS INDUSTRY, BY-PRODUCT DESIGNATION
HAZARDOUS WASTES THAT ARE RECYCLED. HANDLING
RECLAIMING PRECIOUS METALS FROM DISCARDED AUTOMOTIVE ANO ELECTRONIC DEVICES
SCRAP METAL REMOVED FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED
TC RULE DELAY OF IMPOSITION ON OIL FILTERS
* TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING. REGULATION OF
Dental Amalgam
SCRAP AMALGAM FILLINGS FROM DENTISTS. DISPOSAL OF
V* SCRUBBER
SCRAP DENTAL AMALGAM
(See also Sludge)
Baghouse Dust
MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY
SECONDARY CONTAINMENT
(See also Tank System, Minimum Technology Requirements)
'CHANGES OF INTERIM STATUS TANK FACILITIES
'CHANGES TO INTERIM STATUS TANK FACILITIES
•CONTINGENT CLOSURE AND POST CLOSURE PLANS FOR TANKS
'GENERATOR ACCUMULATION AND SECONDARY CONTAINMENT
'HAZARDOUS VASTE TANK REGULATIONS
'HAZARDOUS WASTE TANKS
•HAZARDOUS WASTE TANKS - INSTALLATION/CERTIFICATION OF SECONDARY CONTAINMENT
•INSPECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKS
•SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANKS
HREF
/ /
XREF
/ /
XREF
/ /
XREF
/ /
XREF
9441.1985(44
9441.1989(15
9441.1906 76
9432.1989 03
9441.1986(79
9441.1991(15
9441.1986 14
/ /
12/16/85
04/05/89
10/08/86
06/06/89
10/20/86
09/25/91
02/25/86
9441.1989(22)
9441.1989(43)
05/17/69
08/17/89
XREF
9441.1986(48)
/ /
06/10/86
XREF
9528.1987(09
9483.1988 16
9483.1987 08
9483.1986(10)
9483.1986 05
9483.1987(07
9483.1988(13
9483.1987(06
9483.1988(06
t /
08/30/87
09/30/88
05/30/87
11/30/86
08/30/86
05/30/87
06/30/88
05/30/87
04/30/88
-------
Page No.
04/0
06/92
KEYWORD INDEX
•SECONDARY CONTAINMENT FOR TANKS
•SECONDARY CONTAINMENT VARIANCES FOR TANKS
•TANK INTEGRITY ASSESSMENTS
CONCRETE LINERS FOR HAZARDOUS WASTE TANK SYSTEMS
INTEGRITY ASSESSMENT FOR TANKS AND POST-CLOSURE
LOADING/UNLOADING AREA IN THE DEFINITION OF TANK SYSTEM
OPERATED TO CONTAIN, DEFINITION
PUMP EXEMPTION FROM SECONDARY CONTAINMENT
SECONDARY CONTAINMENT FOR EXISTING HAZARDOUS WASTE TANK SYSTEMS
SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANKS
SECONDARY CONTAINMENT REQUIREMENTS FOR ABOVE GROUND WELDED FLANGES AND SEALLESS VALVES
SECONDARY CONTAINMENT SYSTEMS CERTIFICATION
SECONDARY CONTAINMENT SYSTEMS FOR HAZARDOUS WASTE TANKS
STANDARDS FOR SECONOARY CONTAINMENT OF HAZARDOUS WASTE TANK SYSTEMS
TANK SYSTEM DESIGN-SECONDARY CONTAINMENT
TEMPORARY PERIOD AND HOLDING DEFINED
Leak Dated I on
•HAZARDOUS WASTE TANKS
•LEAK DETECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKS
•LEAK NOTIFICATION AT A OOUBLC-LINEO SURFACE IMPOUNDMENT
•LEAK TESTING FOR EXISTING HAZARDOUS WASTE TANKS
CONTAINMENT AND DETECTION OF RELEASE FROM HAZARDOUS STORAGE TANK SYSTEMS
SECONDARY CONTAINMENT FOR PIPING SYSTEMS
Leakagi
CT
RELEASES FROM 90-DAY ACCUMULATION TANKS
LEAKS, SPILLS. AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WATERS, MIXTURE RULE APPLIED TO
Release
~ 3008(h) OF THE SOLID WASTE DISPOSAL ACT, INTERPRETATION OF
CONTAMINATED GROUND WATER AND VOLATILES FROM AIR STRIPPING, TREATMENT OF
CORRECTIVE ACTION AT FEOERAL FACILITIES
CORRECTIVE ACTION AT FEDERAL FACILITIES
ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTS
FIOERAL FACILITIES INVENTORY UNDER RCRA 3016
FIRE TRAINING PITS. REGULATORY REQUIREMENTS FOR
GROUNDWATER CLEANUP STANDARDS/ACLs IN DRAFT PERMIT (INTERNATIONAL PAPER COMPANY)
HSWA APPLIED TO FEOERAL FACILITIES (DOE-OAK RIOGE)
PIPELINE TRANSPORTATION DF HAZAROOUS WASTE
RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
RELEASES OF HAZAROOUS WASTE. RCRA APPLICABILITY TO 			
SOLID WASTE MANAGEMENT UNIT FOR THE PURPOSE OF CORRECTIVE ACTION UNDER 3004(d), DEFINITION OF
SOLID WASTE MANAGEMENT UNITS, INFORMATION ON
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
WASTE PILES AND POST-CLOSURE PERMITS, APPLICATION OF NOVEMBER 1988 DEADLINE TO
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
9403.1967(13
9483.1966(08
9483.1987(15
9483.1988(04
9483.1989(04
9483.1989(08
9483.1989 06
9483.1988(11
9483.1989(03
9483.1987(16
9483.1987 17
9483.1988(18
9483.1989 07
9483.1989(02
9483.1987 05
9522.1986(01
9483.1986(07)
9483.1986(03)
9484.1985(02)
9483.1986(13)
9483.1988(10)
9483.1987(10)
9453.1986(05
9441.1986(07
9502.1985(09)
9441.1966(B6|
9502.00-2
9502.1986(06)
9444.1986(07)
9502.1987(03)
9489.1987(02)
9481.1987(02
9502.1985(06)
9432.1986(08
9502.1986(02
9502.1987(05)
9502.00-6
9502.1986101a)
9523.00-14
9501.1985(01)
9441.1986)
07/30/87
10/30/86
08/30/87
03/16/88
10/30/89
03/17/88
11/30/89
06/09/88
03/14/89
09/11/8?
09/23/87
12/12/88
11/30/89
01/09/89
05/29/87
12/20/85
10/30/86
08/30/86
08/30/85
12/30/86
06/03/88
07/09/87
08/30/86
01/23/86
12/16/85
11/20/86
04/18/86
04/15/86
04/07/86
03/06/87
07/22/87
03/10/87
10/29/85
04/30/86
01/31/86
04/02/87
07/02/87
01/23/86
03/14/86
10/01/85
04/07/86
Sumps
•APPLICABILITY OF SUBTITLE I
•SUMPS IN THE PART B PERMIT APPLICATION	_	,
CARBON REGENERATION FACILITY, MIXTURE OF SOLID AND HAZARDOUS WASTES (CALGON)
TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING. REGULATION OF
WOOO TREATMENT CYLINDER CREOSOTE SUMPS
9483.1988
9502.1985'
9441.19861
9441.1986!
9441.19861
05)
05)
33)
M|
69
03/30/88
08/31/85
04/23/86
02/25/86
09/12/86
-------
Page No.
04/06/92
KETO0R0 INDEX
SECONDARY MATERIALS
(Sn Solid Waits)
SECONDARY TREATMENT
XREF
/ /
(Sat Treatment)
XREF
SECURITY
/ /
SECURITY REQUIREMENTS AT FACILITIES
SEWAGE SLUDGE
9472.1988(01) 06/02/08
(Sn Wastewater)
SIC CODES
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE
SIC CODE FOR A STEEL MANUFACTURER/PROCESSOR, PICKLE LIQUOR SLUDGE
POINT OF WASTE GENERATION
XREF
9493.1991(01
9441.1985(18
SIGNATURES
/ /
01/08/91
OS/21/85
»
SITING
(Sat Permit Application)
XREF
/ /
(See alto Public Participation)
U*	Capacity
-3	'TREATMENT CAPACITY
CAPACITY VARIANCES AND UNDERGROUND INJECTION
EXTENSION OF APPLICABLE EFFECTIVE OATE OF THE LAND DISPOSAL RESTRICTIONS
HAZARDOUS WASTE MANAGEMENT CAPACITY AND RCRA CONSISTENCY ISSUES
NATIONAL CAPACITY VARIANCE FOR INORGANIC SOLIDS DEBRIS
NEW HAZARDOUS WASTE FACILITY SITING PREVENTIONS
Locatton
CHARACTERISTIC HAZARDOUS WASTES GENERATED AT PRIMARY METAL SMELTING AND REFINING SITES
COMBINED NRC-EPA SITING GUIDELINES FOR OISPOSAL OF COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE
JURISDICTION AND REGULATION OF MIXED WASTE MANAGEMENT INCLUDING INCINERATION AND LOCATION CRITERIA
LOCATION STANDARDS FOR HAZARDOUS WASTE MANAGEMENT FACILITIES
PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT MINES
PROPOSED RULES IMPACT ON PERMIT DEADLINES
TIME OF TRAVEL METHOD FOR THE GUIDANCE CRITERIA FOR IDENTIFYING AREAS OF VULNERABLE HYOROGEOIOGY
VULNERABILITY GUIDANCE
VULNERABLE HYDROGEOLOOY GUIDANCE CRITERIA
XREF
9525.1986(07
9489.1990(01
9551.1988 09
9572.1988(03
9551.1990(07
9523.1987(02
9443.1986(16)
9480.00-14
9541.1986(14
9472.1991 01
9472.1986(04
9501.1987(03
9472.1986(06
9481.1987(01
9481.1987(03
/ /
12/30/86
08/30/90
08/11/88
12/23/88
10/14/90
09/14/87
07/09/86
03/13/89
07/03/86
10/01/91
06/04/86
12/28/87
07/08/86
02/25/87
06/03/87
-------
' '
Page No.
04/06/92
KEYWORD INDEX
\
SKINNER LIST
SLUDGE
(See Appendix IX) (St« also Groundwater Monitoring, Delisting)
XREF
/ /
i >>
(See alto Wastewater)
Pollution control sluoge from treatment of minims waste - exclusion
•SLUDGES when reclaimed, regulation of
ACID PLANT SLOWDOWN SLWRY/SLUOGE FROM PRIMARY COPPER PRODUCTION
CARBON REGENERATION FACILITIES
CERTIFICATION/NOTIFICATION FOR MULTIPLE-CONSTITUENT WASTES SUBJECT TO LOftt
ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE FOOfi LISTING
EXPORT OF HAZARDOUS WASTES UTILIZED FOR PRECIOUS METALS RECLAMATION
F006 LISTING APPLIEO TO PRINTING INDUSTRY
F019 LISTING AND THE CONVERSION COATING PROCESS
FLUE DUST AND METAL HVDROXIOI SLUOGE RECYCLING/RECLAMATION
INDUSTRIAL PLATING OPERATIONS. STATUS OF VARIOUS WASTES FROM
LOR DETERMINATION OF WASTE STREAM DILUTION
PETROLEUM REFINERY WW. MIXTURE AND OERIVED-FROM RULES
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
RECYCLING NICKEL. COPPER AND CHROMIUM-CONTAINING ELECTROPLATING SLUDGES
RECYCLING OF ELECTROPLATING SLUDGES (F0061 FOR CEMENT/AGGREGATE MANUFACTURE
SCRUBBER BRINE/SLUDGE PRODUCEO IN INCINERATION OF A LISTED HAZARDOUS WASTE
SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS
SLUDGE WASTE HANDLING IF TEMP. EXCLUSION IS WITHDRAWN / fUTURE METALS RECOVERY-STEEL FACILITY
SLUDGES GENERATED FROM THE FIRST CLEANING STAGES OF PHOSPHATING PROCESS
SLUDGES WITHIN SURFACE IMPOUNDMENTS. NEWLY REGULATED OUE TO TC RULE
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLE*
WASTE-DERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION RIQUIREO
WASTEWATER TREATMENT SLUDGE EXEMPTION FOR ANODIZING OF ALUMINUM
WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOL
ZINC OXIDE OUST RECLAIMED OR USED AS FERTILIZER
ZINC PLATING, WASTEWATER TREATMENT SLUDGES GENERATED FROM
Baghouse Dust
'BAGHOUSE DUST GENERATED FROM REMELTING PRIMARY PRODUCED STEEL
BAGHOUSE FLUE DUST AND ZINC OXIDE SLUDGE USEO IN 2INC CHEMICALS PRODUCTION
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
RECYCLING OF ZINC OXIDE BAGHDUSE DUST
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
Emission Control Wastes
COAL/FOSSIL FUEL COMBUSTION WASTES EXCLUDED FROM SUBTITLE C PENDING FURTHER STUDY
EMISSION CONTROL BUST/SLUDGE FROM ELECTRIC ARC FURNACE AT FOUNDRY NOT A K061 WASTE
EXEMPTION FOR COMMERCIAL FERTILIZERS ONCE THE FERTILIZER IS PRODUCED
K061, EMISSION CONTROL DUST/SLUDGE FROM PRODUCTION OF STEEL IN ELECTRIC FURNACES
RESIOUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES
STAINLESS STEEL PRODUCTION RESIOUES
XREF
9441.1905(091
9441.1986(59)
9441.1989(32)
9441.1986(26)
9551.199110
9444.1967(03)
9455.1991(01)
9444.1987(19)
9444.1987(22
9441.1989(10)
9441.1988(50)
9151.1990(06)
9441.1985 29
9441.1985 39
9441.1988(09)
9441.1969(19)
9441.1964(05)
9441.1965(06}
9433.1966(17
9444.1986(11)
9464.1991(01)
9523.00-12
9432.1966(07)
9441.1966(06)
9441.1986(29)
9444.1984(04)
9441.1987(61)
9441.1984(29)
9444.1984(16
9441.1985(06
9493.1991(04
9493.1991(05
9443.1987(25
9432.1987(01
9441.1984(20
9441.1964 06
9493.1966(03
9444.1993(02
9496.1991(01
9441.1986
02/28/65
06/30/86
07/06/89
04/02/66
06/05/91
01/27/87
02/05/91
05/22/67
06/24/67
03/27/89
12/07/68
10/14/90
08/23/85
11/25/85
04/06/88
04/26/89
02/19/84
02/22/65
09/30/86
05/22/86
03/08/91
03/30/87
02/11/66
01/24/86
04/09/86
04/26/84
08/12/87
09/24/84
08/30/84
02/13/85
10/11/91
10/11/91
11/04/87
03/17/87
08/16/84
05/03/84
08/21/86
07/11/83
06/05/91
03/10/66
Scrubber
MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY
9441.1966(46) 06/10/06
-------
I
Pagt
04/0
Ho.
06/92
KEYWORD 1N0EX
PERMIT-EXEMPT STATUS OF SLU08E MYERS ADDED TO WASTEWATER TREATMENT UNITS
RDKD PERMIT FOR A SLUDGE DRYING PROCESS IN A WASTE WATER SYSTEM
SLUDGE OEHYORATIQN EQUIPMENT
SLUDGE DEHYDRATION EQUIPMENT AS A WASTEWATER TREATMENT UNIT
SLUDGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WVTU EXEMPTION
9S03.52-1A
9503.51-1A
9527.1967(02
9432.1987(08
9432.1986(01
01/02/86
12/24/85
08/03/87
08/03/87
01/06/86
SLUDGE DRYERS
(Sea Sludge)
SMALL QUANTITY GENERATOR
XREF
/ /
(See Generators)
SMELTING WASTE
XREF
/ /
(See Hazardous Waste Identification)
SOIL
XREF
/ /
(See Hazardous Waste Identification)
SOLE ACTIVE INGREDIENT
XREF
/ /
* (See Listed Hazardous Waste)
SOLID WASTE
XREF
/ /
JP
JSm also Recycle) (See also Hazardous Waste Identification)
CTIVATED CARBON CANISTER SATURATED WITH SPENT SOLVENTS
ANTARCTICA WASTE DISPOSAL PRACTICES
BAGHOUSE DUSTS USED AS, OR TO PRODUCE, AGGREGATE
BERYLLIUM WASTE DUST
CARBON REGENERATION FACILITY. MIXTURE OF SOLID AND HAZARDOUS WASTES (CALGON)
CHARACTERISTIC SLUDGES RECLAIMED OR PROCESSED PRIOR TO USE AS AN INGREDIENT IN FERTILIZER
COMMERCIAL CHEMICAL PRODUCTS, RECYCLING A MIXTURE OF
COPPER PLATING SOLUTION
COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZER
DEIONIZATION ACID REUSED, NOT A WASTE
DOD^HUNiIIOnITbECOh! SOLlPwASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO OISPOSE OR DESTROY THEM
EXPORTATION OF MUNICIPAL WASTE TO CENTRAL AMERICA
FILTER PRESS PROPOSED AS PART OF CORRECTIVE ACTION - NOT EXCLUOEO FROM PERMITTING
GROUNDWATER CONTAMINATED WITH HAZARDOUS WASTE LEACHATE
*Ln^bA^l?ElFTO SURFACE WATERS. MIXTURE RULE APPLIED TO
LETTER TO STAtE ENVIRONMENTAL COMMISSIONERS:SUBTITLE D STATE SOLID WASTE MANAGEMENT PLANS
MERCURY SUITABLE FOR DIRECT USE (99% PURE) NOT SOLID WASTE
MERCURY THERMOMETERS, RECLAIMED OFF-SPEC AND BROKEN
MERCURY, REFINING/REUSE OF SCRAP
XREF
9441.1986(54
9442.1989 04
9493.1991(03
9434.1989(01
9441.1986(33
9493.1985	03
9441.1986(34
9443.1986	04
9493.1986 01
9441.1986(39
9443.1987(30
9441.1985(31
9573.1990(01
9433.1987(10
9441.1986(83
9494.1986(04
9441.1986(07
9572.00-02
9441.1986(43
9441.1986 27
9441.1986(06
/ /
07/15/86
04/26/89
06/21/91
03/13/89
04/23/86
11/25/85
04/28/86
01/22/86
01/22/86
05/12/86
11/30/87
10/31/85
02/16/90
06/12/87
11/13/86
04/11/86
01/23/86
02/22/88
05/30/86
04/02/86
01/21/86
-------
\
KEYWORD INDEX
MICRO-CLEAR REGULATORY STATUS
MIXTURE OF F003 AND A SOLID WASTE AND DELISTING REQUIREMENTS
MIXTURES OF SOLID WASTE AND A WASTE LISTEO SOLELY BECAUSE IT EXHIBITS A CHARACTERISTIC
MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGE
OFF-SPECIFICATION JET FUEL BURNED AS KEROSENE FUEL
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
RECLAIMED METHANOL IS A PRODUCT RATHER THAN A WASTE
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES
RECYCLED GASOLINE/WATER AND FUEL OIL/WATER MIXTURES
REFRACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY. CHEMICAL RECOVERY CARTRIDGES FOR
SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMED XYLENE
SPENT PICKLE LIQUOR, REUSE OF
SPENT SULFURIC MID PICKLE LIQUOR USED TO PRODUCE FERTILIZER
WOOD TREATMENT CYLINDER CREOSOTE SUMPS
Batteries
•BATTERY REGENERATION
•EXPORTING HAZARDOUS WASTE
•SPENT LEAD ACID BATTERIES	j
AIDS TO NAVIGATION (ATON1 BATTERIES AND RCRA REQUIREMENTS
ATON BATTERIES. GENERATOR DEFINITION FOR
BATTERIES. SCRAP METAL. AND PRECIOUS METALS
BATTERIES, WASTE ELECTROLYTE FROM RECHARGEABLE NICKEL-CADMIUM
BATTERY RECONDITIONING
BATTERY RECYCLING AND EXPORT
GENERATION OF AIDS TO NAVIGATION (ATON BATTERIES)
HOUSEHOLD WASTES - OISPOSAL OF CARBON-ZINC BATTERIES
LITHIUM BATTERIES
MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONS
NICKEL-CADMIUM BATTERIES RECYCLING
NICKLE/CADMIUH BATTERIES, REGULATORY STATUS
REACTIVE CHARACTERISTICS OF DISCHARGED LI/S02 BATTERIES
RECYCLED PRECIOUS METALS. BATTERIES FROM &EFENSE DEPT. SUPPLIES
RECYCLING OF LEAD-ACID BATTERIES
REGENERATION OF USED BATTERIES EXEMPTED FROM REGULATION
REPROCESSING OF BATTERIES
REUSE/RECYCLE REGULATIONS IMPACT ON SPENT LEAD-ACID BATTERY RECYCLING
SCRAP METAL REMOVED FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED
SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS
SPENT LEAO ACID BATTERIES BEING RECLAIMED
SPENT LEAD-ACID BATTERIES MANAGEMENT
WASTE BATTERIES ANO CELLS
By-Product
BRASS DROSS SKIMMINGS, SEPARATION OF METALS AND OXIDES, BY-PRODUCT
BY-PRODUCT CRUDE OIL TANK BOTTOMS
BYPRODUCT MATERIAL, DEFINITION OF
COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE
COPPER-BEARING SECONDARY MATERIALS AS FEEDSTOCK
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE
OROSS FROM ALUMINUM SMELTING USED IN MANUFACTURE OF CEMENT
OROVE RECLAMATION IN BRASS INDUSTRY. BY-PROOUCT DESIGNATION 	
METAL GALVANIZING PROCESS RESIDUES AS BY-PRODUCTS/StCOJWARY MATERIALS
ON-SITE INCINERATION OF A WASTE THAT IS BOTH A BY-PRODUCT MATERIAL AND HAZARDOUS
SOLDER OROSS FROM SKIMMING MOLTEN SOLDER BATHS - REGULATORY STATUS
SOLDER SKIMMINGS REGULATORY INTERPRETATION
9444.19901
9441.1987(
9441.19851
9443.19061
9441.19861
9441.19861
9441.1985
9441.19851
9441.19861
9444.1988
9443.19871
9441.19871
9441.1987
9493.19811
9502.19861
02)
65
38
13
19
21
33
39
22
05
01
24
17
02
15
03/22/90
08/17/87
11/20/85
05/27/86
03/08/86
03/13/86
10/23/85
11/25/85
03/19/86
03/11/88
01/06/87
04/15/87
03/31/87
11/14/85
09/12/86
9441.1985(308)
9456.1987(01)
9497.1989(01
9451.1907 03
9453.1988 03
9441.1985(44
9441.1985113
9441.1986(56
9497.1987(01
9461.1987(03
9441.1984(07)
9443.1987(02
9443.1986(18
9497.1991 02
9441.1990(13
9443.1987(05
9441.1986(85
9497.1989(03
9441.1906(51
9497.1987(02
9497.1986(01
9441.1906(79
9487.1986(13
9497.1987(03
9497.1989(02
9443.1983(05
09/30/85
08/30/87
01/31/89
07/30/87
02/25/88
12/18/85
05/15/85
07/28/86
02/12/87
07/30/87
04/19/84
01/14/87
09/04/86
05/30/91
05/23/90
03/18/87
11/19/86
11/17/89
07/02/86
02/19/87
02/06/86
10/20/86
12/31/86
04/17/87
10/19/89
07/27/83
9441.1985(21
9441.1986(37
9432.1986(10
9441.1986(68!
9441.1988(08
9441.1988	11
9441.1989	01
9441.1989(15
9441.1989(14
9432.1986(14
9441.1991(03
9441.1991(10
06/06/85
05/01/86
04/12/86
09/11/86
03/22/88
04/21/88
02/07/89
04/05/89
04/02/09
09/06/86
03/19/91
06/21/91
-------
\ J
Page No.
04/06/92
KEYWORD INDt*
THERMAL OXIDATION UNIT/FUME INCINERATOR AND CYANURIC CHLORIDE WASTE
THERMAL OXIDIZER AND HYDRODECHLORINATION PROCESS BY-PRODUCT K-WASTES
Definition
~BOAT FOR WASTEWATER
'ELECTROPLATING AND ELECTROLESS PLATING LISTINGS
*HOUSEHOLD HAZARDOUS WASTE
'SKINNER LIST
'SLUDGES WHEN RECLAIMED. REGULATION OF
'SOLID AND HAZAROOUS WASTE, DEFINED FOR SPENT SULFURIC ACID
'TANK WASTEWATER TREATMENT UNIT DEFINITIONS
'USED OIL. DEFINITION OF
'WASTEWATER TREATMENT UNIT DEFINITION
AQUEOUS AS USED IN THE CORROSIVITY CHARACTERISTIC
BAGHOUSE FLUE OUST AND ZINC OXIDE SLUDGE USED IN ZINC CHEMICALS PRODUCTION
BATCH. DEFINITION OF
BOILERS USED IN GREENHOUSE OPERATIONS ARE INDUSTRIAL BOILERS	I
COLORED GLAZE SOLIOS COLLECTED IN POTTERY MANUFACTURING OPERATIONS
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
HEAT RECOVERY UNIT AS A BOILER OR AN INCINERATOR
HOLDING, TEMPORARY, PERIOD, STORAGE, AND DISPOSAL (DEFINITIONS)
IGNITABLE SOLID DEFINITION APPLIED TO TITANIUM SWARF
INTEGRAL DESIGN STANDARD IN BOILER DEFINITION (LUBRIZOL)
LEAD SHERDING FOR RAOIOACTIVE WASTE IS A RCRA SOLIO WASTE
MARINE DEBRIS IN WATERS, OISPOSAL OF
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS
PIPELINE TRANSPORTATION OF HAZARDOUS WASTE
RECYCLING EXCLUSION OF WASTES
SLUDGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WWTU EXEMPTION
SOLIO WASTE MANAGEMENT UNIT FOR THE PURPOSE OF CORRECTIVE ACTION UNDER 3004(u), DEFINITION OF
SPENT SULFURIC ACID ACCUMULATED SPECULATIVELY
STILL BOTTOM WASTE GENERATED BY A POLYSTYRENE PRODUCTION FACILITY
THREE AND FOUR-SIDED. FLOORED STRUCTURES, REGULATORY CLASSIFICATION OF
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
TOTALLY ENCLOSED TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSE SYSTEM
UCAPCO APPLICATION FOR A VARIANCE UNDER3004(c)(2) OF RCRA
WOOD TREATMENT CYLINDER CREOSOTE SUMPS
ZINC OXIDE DUST RECLAIMEO OR USEO AS FERTILIZER
Discarded Materials
ACCUMULATION OF SECONDARY MATERIAL - ABANDONED VS. DISPOSED OF
FORMALDEHYDE-BASED TOILET DEODORANTS
IRON AND STEEL SLAGS IN MINERAL PROCESSING WASTES REPORT
IRON AND STEEL SLAGS. REGULATORY STATUS
SOIL CONTAMINATED WlfH CHLORDANE AS A RESULT OF PESTICIDE APPLICATION
SPENT CARBON REGULATION
THERMAL OXIDIZER AND HYDRODECHLORINATION PROCESS BY-PRODUCT K-WASTES
Household Wastes
'HOUSEHOLD HAZARDOUS WASTE
'MEDICAL WASTE - HOUSEHOLD MEDICAL WASTE
'WASTE DERIVED FROM TREATING EXEMPT OR EXCLUDED WASTES
CALIFORNIA LIST HOC LAND BAN REGULATIONS
CHEMICAL WEAPON AGENT REALEASE
9400.1906(06)
9444.1967(44)
9432.1986(16)
9432.1909 01
9441.1908 30
9445.1905	06
9441.1906	59
9441.1966(17
9432.1988(03 i
9431.1986	01
9432.1988	05
9443.1967(19
9441.1985(06
9432.1989	05
9432.1986(03
9441.1988(17
9432.1906(05
9432.1905(08
9432.1906(12
9443.1983(01
9432.1985(10
9444.1991(02
9432.1987	12a)
9493.1991(04)
9493.1991(051
9441.1987 46
9432.1986 08
9441.1990	06
9432.1986(01
9502.00-6
9441.1988(19)
9432.1988(01)
9432.1987(02
9432.1986(07)
9432.1987(01)
9432.1906(15)
9400.1907(02)
9441.1906(69)
9441.1907(61)
9441.1905
9441.1986
9441.1991
9571.1990
9444.1966
9441.1967
9444.1987
9441.1986(30
9441.1989(24
9441.1987(31
9554.1989(04
9441.1990(12
04/30/06
10/16/07
12/30/06
00/30/09
06/30/86
08/30/85
06/30/66
02/20/66
03/30/86
01/30/68
10/30/68
09/14/07
02/13/85
12/05/89
01/09/86
05/18/88
02/05/86
11/20/85
07/28/86
01/10/63
12/30/65
04/30/91
11/04/87
10/11/91
10/11/91
06/17/87
04/30/86
03/19/90
01/06/86
07/02/87
05/26/88
02/11/88
04/02/87
02/11/66
03/17/87
12/22/86
10/29/67
09/12/86
08/12/67
07/01/85
05/01/86
05/30/91
05/30/90
09/29/66
05/18/07
10/16/87
06/30/68
08/16/89
04/30/87
11/28/69
05/09/90
-------
Page No.
04/06/92
KEYWORD INDEX
ORY CLEANING AND MAINTENANCE SERVICES HASTE NOT EXCLUDED AS HOUSEHOLD WASTE
HOUSEHOLD HAZAROOUS WASTE COLLECTION PROGRAMS, CERCLA AND RCRA LIABILITY OP MUNICIPAL SPONSORS OF
HOUSEHOLD HAZARDOUS WASTE EXCLUSION GENERATED BY CONTRACTORS
HOUSEHOLD WASTE EXCLUSION SCOPE
HOUSEHOLD WASTES - DISPOSAL OF CARBON-ZINC BATTERIES
LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS
MERCURY ORV CELL BATTERIES AND APPLICABLE REGULATIONS
RESIOUES FROM U.S. NAVY SALVAGE FUEL BOILER
USED CRANKCASE OIL DISPOSED OF 8Y DO-IT-YOURSELFERS
Regulated Wastes
•SPENT SOLVENT LISTINGS
OREDGE SEDIMENTS
STORAGE FACILITIES, RCRA APPLICABILITY TO
Scrap Metal
ASBESTOS/LEAD/SOIL/OEBRIS AS INORGANIC SOLID DEBRIS
BATTERIES, SCRAP METAL, AND PRECIOUS METALS
DROVE RECLAMATION IN BRASS INDUSTRY, BY-PRODUCT DESIGNATION
HAZARDOUS WASTES THAT ARE RECYCLED. HANDLING
RECLAIMING PRECIOUS METALS FROM DISCARDED AUTOMOTIVE AND ELECTRONIC DEVICES
SCRAP METAL REMOVED FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED
TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING, REGULATION OF
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
USED OIL FILTERS - REGULATION
USEO OIL FILTERS, REGULATORY DETERMINATION
Secondary Materials
•CLOSED LOOP RECYCLING
ACCUMULATION OF SECONDARY MATERIAL - ABANDONED VS. OISPOSEO OF
BRIQUETTINS OF FLUE DUST (K061) FOR STEEL PRODUCTION
COPPER-BEARING SECONDARY MATERIALS AS FEEDSTOCK
DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE
LAND DISPOSAL RESTRICTIONS APPLIED TO EXPORTED WASTES
LUBRICATING OIL AND JET FUELS USEO TO PRODUCE PETROLEUM PRODUCTS
METAL GALVANIZING PROCESS RESIDUES AS BY-PRODUCTS/SECONDARY MATERIALS
RECYCLING OF ELECTROPLATING SLUDGES (F006) FOR CEMENT/AGGREGATE MANUFACTURE
RETURNED PHARMACEUTICAL PRODUCTS
SECONDARY MATERIAL SUBJECTED TO NOTICE REQUIREMENTS UNDER THE US-CANAOIAN BILATERAL TREATY
SECONDARY MATERIALS RECYCLED IN PHOSPHORIC ACID RECIRCULATING SYSTEMS
SECONDARY MATERIALS REGULATION - USED SULFURIC ACID
Spent Materials
•CONTAMINATED SOLDER AS SPENT MATERIAL
•SPENT SOLVENTS FROM VARNISH STRIPPING
•WASTES GENERATED IN PROCESS UNITS
CARBON REGENERATION FACILITIES
CARBON REGENERATION FACILITIES
CHLOROFLUMOCARBON RECYCLING
ETCHANTS USED TO MANUFACTURE COPPER SALTS
INDUSTRIAL PLATING OPERATIONS. STATUS OF VARIOUS WASTES FROM
NICKLE/CADMIUM BATTERIES, REGULATORY STATUS
PHOTOGRAPHIC FIXER RECYCLING
PLASTIC PACKING MEDIA FROM AIR STRIPPING TOWER TREATING CONTAMINATED GROUNDWATER
POSITION PAPER ON SPENT ABSORBENT MATERIALS
SECONDARY MATERIAL SUBJECTED TO NOTICE REQUIREMENTS UNOER THE US-CANADIAN BILATERAL TREATY
SOLOER WOSS GENERATED IN MANUFACTURING PRINTEO CIRCUIT BOARDS
9441.1986(32)
9441.1966(09)
9441.1990(09)
9574.199101
9441.1984(0?)
9443.1987(28)
9443.1986(18)
9441.1987 16
9441.1987 64
9444.1986(14
9443.1989(00
9432.1983(02
9551.1990(14)
9441.1985(44)
9441.19891IS)
9441.1986(76)
9432.1989(03)
9441.1986(79)
9441.1986 14
9432.1986(07)
9441.1990(30)
9442.1990(05)
9471.1968(06
9441.1985(25
9441.1987(58
9441.1968(08
9441.1988(11
9551.1991(07
9494.1985(01
9441.1989(14!
9441.1989(19!
9455.1991(02!
9441.1989(29
9571.1990(04
9441.1988(23
9441.1987(66)
9441.1986(57)
9441.1986 96
9441.1986(26
9442.1986(03
9441.1988(32
9441.1986(82
9441.1980(50
9441.1990(13
9496.1990(01
9441.1989(17
9441.1991(09
9441.1989(29
9441.1991(18
04/21/86
01/28/86
03/30/90
05/30/91
04/19/84
11/20/87
09/04/86
03/17/87
08/13/87
06/30/86
08/11/89
11/29/83
12/11/90
12/18/85
04/05/89
10/08/86
06/06/89
10/20/86
02/25/86
02/11/86
10/30/90
10/30/90
12/30/88
07/01/85
07/31/87
03/22/88
04/21/88
04/23/91
10/01/85
04/02/89
04/26/89
05/16/91
06/15/89
06/27/90
06/06/88
06/30/87
05/30/86
12/30/86
04/02/86
04/30/86
07/21/88
11/08/86
12/07/88
05/23/90
07/16/90
04/14/89
06/21/91
06/15/89
12/09/91
-------
I
KEYWORD INDEX
\
SPENT ACIDS AS WATER CONDITIONER
SPENT LEAD-ACID BATTERIES MANAGEMENT
SPENT PICKLE LIQUOR USED/REUSED IS NOT SOLID WASTE
USED REFRIGERANTS UNDER 40 CFR 261.2
USED X-RAY FILK AS A SPENT MATERIAL - SILVER RECLAMATION
USED X-RAY FILMS
Subtitle D
•SUBTITLE 0 SURVEY
LETTER TO STATE ENVIRONMENTAL COMMISSIONERS: SUBTITLE 0 STATE SOLID WASTE MANAGEMENT PLANS
MININQ WASTE REGULATED UNDER SUBTITLE 0 RATHER THAN SUBTITLE C
SOURCE REDUCTION AND RECYCLING TECHNICAL ASSISTANCE GRANTS FOR STATES
SOLIO WASTE MANAGEMENT UNIT (SWMUs)
5441.19871
9497.1909
9441.19861
9441.19901
9441.19B6I
9443.19861
9573.1987(01)
9572.00-02
9441.1986(55)
9581.1988)
0B/31/B7
10/19/89
08/18/86
10/18/90
05/20/86
05/23/86
03/30/87
02/22/88
07/16/86
11/01/80
(Sm Corrective Action)
SOLIDIFICATION
XREF
/ /
(Sea Treatment)
SOLVENTS
XREF
/ /
W
(See also Lilted Hazardous Waste, Wastewater, Electroplating. Reclamation, RecoveryRecycle)
¦BOAT FOR WASTEWATER
•LAND 0ISP0SAL BAN OF SOLVENTS
•LAND OISPOSAL RESTRICTIONS - IX NATIONAL VARIANCE (SOLVENTS)
•LAND DISPOSAL RESTRICTIONS - SOLVENT AND DIOXIN WASTES
•METHYL CHLOROFORM
•PARTS WASHING WITH MINERAL SPIRITS, SMALL QUANTITY GENERATORS
•SOLVENT DRIPPINGS FOR DEGREASING OPERATIONS
•SOLVENT ORIPPINGS FROM DEGREASING OPERATIONS
•SOLVENTS USED IN CLEANING. EXTRACTION. 8ENEFICIATION, AND PROCESSING MACHINERY
•VARIANCES TO BAN - EFFECTIVE DATES FOR SOLVENTS ANO DIOXINS
•WASTES GENERATED IN PROCESS UNITS
•WASTEWATER TREATMENT SLUDGE FROM CHEMICAL ETCHING
•WASTEWATER TREATMENT SLUDGE FROM ELECTROPLATING OPERATIONS
ACETONE AND METHANOL CONTAMINATED WASKWATERS
ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED OWING PAINT APPLICATION
CAUSTIC RINSING METAL PARTS
CLEAN SOLVENT FROM RECYCLED SOLVENT-CONTAINING WASTE - STILL BOTTOMS
DELISTING OF WASTE GENERATED FROM ZINC PH0SPHAT1NG ON CARBON STEEL
DRY CLEANING CARTRIDGE FILTERS, DISPOSAL OF
DRY TOLUENE AND CARBON TETRACHLORIDE, SAFE OISPOSAL OF
ORYCLEANING INDUSTRY WASTES
ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE F006 LISTING
ELECTROPLATING R1NSEWATERS		
ELECTROPLATING RINSEWATERS NOT I* F007-009 LISTINGS
F SOLVENT WASTES
F003 10X RULE AND ASSOCIATED REGULATIONS DRUGS
F005 LISTING FOR PYRIDINE STILL BOTTOMS
F006 ANO F019 ELECTROPLATING LISTINGS
F006 LISTING ANO DEFINITION OF CONVERSION COATING
F019 LISTING AND THE CONVERSION COATING PROCESS
XREF
9432.1986(161
9551.1906 03
9551.19871241
9553.1988(01)
9444.1984(17)
9441.1986(451
9441.1987(19)
9443.1987 08)
9441.1984(33)
9551.1986 22
9441.1986(96
9444.1984(02)
9453.1984(02)
9444.1989(051
9444.1986(08)
9444.1987(33
9441.1987(26
9441.1984(24
9553.1986 03
9451.1986	06)
9444.1987(07}
9444.1987	03
9442.1987(03)
9444.1988(07)
9444.1985(03)
9444.1987(30
9444.1987(53)
9444.1986i09|
9444.1987(09)
9444.1987(22)
/ /
12/30/86
02/28/86
11/30/87
02/28/88
08/30/84
05/30/86
03/30/87
04/30/87
11/30/84
12/30/86
12/30/86
03/30/84
05/30/84
07/21/89
05/02/86
08/07/87
04/17/87
09/06/84
12/11/86
12/15/86
03/06/87
01/27/B7
07/28/87
04/07/88
04/01/85
07/21/87
12/15/87
05/02/86
03/26/87
06/24/87
-------
Page No.
04706/92
KEYWORD INDEX
FILTER CAKE WASTE CONTAINING SOLVENT USED TO SOLUBILIIE PRODUCT
HAZAROOUS VASTE FUEL CADENCE PRODUCT 312, REGULATION OF
IMMERSION PLAT INS WASTEWATERS-BRONZE PLATING
LAND DISPOSAL RESTRICTIONS ON THE METAL FINISHING INDUSTRY
MECHANICAL PLATING WASTES IN THE F006 LISTING, NON-INCLUSION OF
MIXED SOLVENT WASTES
MIXTURE RULE CALCULATION-INCLUDING VOLATILIZED SOLVENT
MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTS
MOBILE SOLVENT RECYCLER. GENERATOR DETERMINATION FOR
PAINT FILTERS, USED
PAINT SPRAY BOOTH AIR FILTERS
PAINT WASTES ANO OF THE SPENT SOLVENT LISTINGS
PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATOR
PAINTS CONTAINING SOLVENTS
PERMITTING AND CORRECTIVE ACTION REQUIREMENTS AFFECTING COMPLIANCE WITH LAND OISPOSAL RESTRICTIONS
PRC-COAT WASTE CONTAINING 2-ETHOXYETHANOL (EXTRUDING PROCESS WASTE)
PROCESS WASTES CONTAINING INKS, PAINTS, MID ADHESIVES
REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENT
RECLAIMED METHANOL IS A PRODUCT RATHER THAN A WASTE
RECYCLING NICKEL, COPPER AND CHROMIUM-CONTAINING ELECTROPLATING SLUOGES
RECYCLING OF ELECTROPLATING SLUDGES (F0061 FOR CEMENT/AGGREGATE MANUFACTURE
RESIDUALS FROM TREATMENT OF RESTRICTED WASTES NOT COVERED BY LESS-THAN-tX SOLVENT EXTENSION
RINSE WATERS CONTAINING TCE SOLVENT
SLUDGES GENERATEO FROM THE FIRST CLEANING STAGES OF PHOSPHATING PROCESS
SOLVENT LISTINGS AND LANO DISPOSAL RESTRICTIONS
SOLVENT LISTINGS FOR PAINT WASTES/REMOVER ANO SPILL RESIDUE
SOLVENT LISTINGS, SCOPE OF
SOLVENT-BEARING WASTEWATER, SLUDGE, AND BRINE TREATEO ANO STORED IN SURFACE IMPOUNDMENTS
SOLVENT/MIXTURE BLENDS
SOLVENTS USED AS COOLANTS AND APPLICABILITY OF SOLVENT LISTINGS
SOLVENTS USED AS REACTANT AND SOLVENT WASTES GENERATED BY A PRODUCTION PROCESS
SOLVENTS USEO AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCT
SPENT ANO RECLAIMEO SOLVENTS. BLENDING OF RECLAIMED XYLENE
SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY
SPENT SOLVENT MIXTURE (NALCAST 6015/WATER/WAX)
STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION
STILL BOTTOMS FROM LISTED SOLVENT RECLAMATION
SUBSTITUTION OF EXTRACTION SOLVENTS FOR METHYLENE CHLORIDE
TCLP EXTRACTIONS APPLIEO TO LIQUID WASTES, OILS ANO SOLVENT-BASED PRODUCTS
TCLP IN THE LANO DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS WASTE IDENTIFICATION PROGRAM
TETRACHLOROETHYLENE CONTAMINATED WITH POLYCHLORINATEO BIPHENYLS (PCBi)
THERMAL TREATMENT UNITS, SCOPE OF SUBPART X
TOLUENE AS A OILUANT OR CARRIER ANO THE SCOPE OF THE F005 LISTING
TOLUENE-CONTAINING PAINT PRODUCTS FROM WOOD PIECES, REGULATORY STATUS
TOLUENE-LAOEN FILTER RESIDUE GENERATED FROM AN INK PRODUCTION PROCESS
VOLATILIZATION OF SOLVENTS COUNTED AS SOLVENTS USEO
WASTE FROM CHEMICAL ETCHING USING CYANIDE
WASTE FROM ELECTROLESS PLATING PROCESSES NOT COVERED UNDER REINTERPRETED F006 LISTING
WASTE INK ANO SOLVENT MIXTURES GENERATED FROM PRINTING FACILITIES
WASTE LISTINGS F006 AND K062, SCOPE OF
WASTES FROM BRIGHT DIPPING UNDER THE REINTERPRETED F006 LISTING
WASTES FROM ZINC PLATING (SEGREGATED BASIS! ON CARBON STEEL EXCLUDED FROM F006
WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER
WASTEWATER TREATMENT SLUDGE RESULTING FROM METAL CLEANING PROCESS
WASTEWATER TREATMENT SYSTEM. SOLVENT RECOVERY STILL BOTTOMS IN
WATER WALL SPRAY BOOTH WASTES AMD THE SOLVENT LISTINGS
5444
9494
9442
9554
9444
9444
944!
9441
9432
9444
9442
9444
9441
9444
9502
9444
9441
9444
9441
9441
9441
9553
9441
9444
9444
9444
9444
9553
9444
9444
9444
1441
9441
9441
9444
9444
9444
9441
9442
9443
9444
9489
9444
9443
9444
9441
9444
9444
9443
9444
9444
9444
9441.
9444.
9441.
9444.
1907143
1986(04
1988(0$
1907(02
1986(13
1988 02
1987 28
1986(30
1986(13
1908(13
1990(01
1987(17
1986(47
1988(11
1986(11
1986(IS
1987 09
1987(49
1985(33
1988(09
1909(19
1987(07
1987(59
1986(11
198718
1987(11
1986(26
1987(01
1988(06
1987	02
1986(27
1986(92
1987(24
1989(34
1985(15
1987(38
1987(05
1988
1991
(25
14
1987 29
1989(10
1988(01
1987(36
1988(01
1985109
1991(08
1987(16
1987(11
1984(08
1986(32
1987(28
1987(14
1986(S2
1989 08
1985(43
1987(06
10/09/87
04/11/86
10/03/88
02/03/87
06/24/86
01/22/88
04/30/87
04/16/86
08/06/86
07/28/88
05/03/90
05/20/87
06/02/86
05/05/88
06/16/86
08/04/86
02/19/87
10/26/87
10/23/85
04/06/88
04/26/89
04/27/87
08/07/87
05/22/86
05/20/87
04/14/87
11/07/86
01/12/87
03/31/88
01/27/87
12/05/86
12/05/86
04/15/87
07/06/89
06/24/85
09/01/87
02/02/87
06/09/88
10/29/91
11/18/87
09/22/89
05/18/88
08/17/87
01/04/88
06/03/85
06/10/91
05/20/87
12/04/87
11/23/84
12/12/86
07/13/87
05/08/87
07/02/86
08/21/89
12/17/65
02/28/87
-------
Page No.
04/06/92
\
KEYWORD INDEX

ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS	9441.1986(21
PAINT WASTES AS HAZARDOUS WASTES, RECYCLED/REUSED PAINT WASTES	9441.1981
PICKLE LIOUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE	9432.19871
POPPING FURNACES-DOD DISPOSAL OF OUTDATED ORONANCE BY INCINERATION - METALS RECOVERY	9441.1983
QUANTUM TECH PLASHA ARC UNIT - REGULATORY CLASSIFICATION	9488.1991
RECLAMATION OF SPENT ALKALINE ETCHANT-REOUEST FOR VARIANCE UNDER HOD. CLOSED-LOOP PROVISION	9433.1985
RECYCLABLE CLOTH WIPERS AND DISPOSABLE INDUSTRIAL WIPERS USED TO CLEAN UP HAZARDOUS WASTES	9441.1986
RECYCLED CHARACTERISTIC HAZARDOUS WASTE SLUDGES	9441.1965
RECYCLED GASOLINE/WATER AND FUEL OIL/WATER MIXTURES	9441.1986
RECYCLING ACTIVITIES	9451.1989
RECYCLING EXCLUSION OF WASTES	9441.1990
RECYCLING NICKEL. COPPER AND CHROMIUM-CONTAINING ELECTROPLATING SLUDGES	9441.1988
RECYCLING OF ELECTRIC ARC FURNACE OUST	9441.1988
RECYCLING OF ELECTROPLATING SLUOGES (F006) FOR CEMENT/AGGREGATE MANUFACTURE	9441.1989
RECYCLING OF K061 AS AN INGREOIENT IN CEMENT	9441.1990
RECYCLING OF LEAD-ACID BATTERIES	9497.1989
RECYCLING OF MOLOING AND CASTING SANDS	9441.1986
REGION V FUEL-BLENDING FACILITIES CONCERNS	9441.1991
REPROCESSING OF BATTERIES	9497.1987
RESIDUE FROM SPENT SOLVENT RECLAMATION CONSIDERED HAZARDOUS	9441.1984
SCRAP METAL REMOVEO FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED	9441.1986
SECONOARY MATERIALS REGULATION - USEO SULFURIC ACID	9441.1988
SLUDGE WASTE HANOLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY	9433.1986
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS	9441.1986
SOLVENT STILL AS RECYCLING UNIT - REGULATORY STATUS OF	9441.1985
SOURCE REOUCTION AND RECYCLING TECHNICAL ASSISTANCE GRANTS FOR STATES	9581.1988
SPENT LEAD-ACID BATTERIES BEING RECLAIMED	9497.1987
SPENT PICKLE LIQUOR USED IN PROOUCTION OF FERRIC CHLORIOE	9441.1985
SPENT PICKLE LIQUOR, USE/REUSE EXEMPTION AS APPLIED TO	9441.1985
SPENT SOLVENT RECOVERY. WASTE MANAGEMENT TAX	9441.1986
SPENT SULFURIC ACID ACCUMULATED SPECULATIVELY	9441.1988
SPENT SULFURIC ACID PICKLE LIQUOR USED TO PRODUCE FERTILIZER	9493.1985
STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION	9444.1987
STILL BOTTOMS GENERATEO AND REMOVED FROM A RECYCLING UNIT	9453.1989
STORAGE PERMIT FOR FACILITIES INVOLVEO IN HAZARDOUS WASTE RECYCLING	9441.1989
TANK TREATMENT SYSTEM OF METAL-RICH RINSEWATERS	9483.1990
TC RULE - IMPLEMENTATION	9441.1990
TNT REO WATER. REUSE OF	9441.1981
TORPEDO PROPULSION UNITS SHIPPEO FOR RECYCLING. REGULATION OF	9441.1986
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER	9432.1986
TWO WASTE OIL MANAGEMENT PRACTICES REGULATORY STATUS	9495.1991
USED OIL BURNED FOR ENERGY RECOVERY. INTERPRETATION OF SUBPART E	9495.1989
USED OIL CONTAMINATION THROUGH NORMAL USE OR MIXING WITH HAZARDOUS WASTES - RECYCLING OEFINED	9441.1984
USED OIL FILTERS - REGULATION	9441.1990
USED OIL FILTERS. REGULATORY DETERMINATION	9442.1990
USED OIL INTRODUCED INTO REFINERY PROCESS UNOER HAZARDOUS WASTE OERIVED REFINERY FUEL PRODUCTS EXEMPTION	9441.1986
WASTE-AS-FUEL RULES AT DOD FACILITIES, IMPLEMENTATION	9494.1986
WASTE-DERIVED FUELS AT IRON AND STEEL HILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIRED	9441.19661
Precious Metals
~EXPORT OF RECYCLABLE MATERIALS
'NOTIFICATION REQUIREMENTS FOR RECYCLABLE MATERIALS
•PRECIOUS METAL RECYCLING (SILVER). SMALL QUANTITY GENERATOR
BATTERIES. SCRAP METAL. AND PRECIOUS METALS
EXPORT OF HAZAROOUS WASTES UTILIZED FOR PRECIOUS METALS RECLAMATION
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENT
9456.1986(01)
9441.1988 13)
9441.1985 28a)
9441.1985(44
9455.1991(01
9493.1991(04
9493.1991(05
03/13/86
04/06/81
11/10/87
06/08/83
09/30/91
10/29/85
07/03/86
11/25/85
03/19/86
05/03/89
03/19/90
04/06/88
06/15/88
04/26/89
02/13/90
11/17/89
01/06/86
11/04/91
02/19/87
02/16/84
10/20/86
06/06/88
09/30/86
12/02/86
06/27/85
11/01/88
04/17/87
07/16/85
06/05/85
05/20/86
05/26/68
11/14/85
09/01/87
04/18/89
03/27/89
08/01/90
10/01/90
04/10/81
02/25/86
02/11/86
06/05/91
05/15/89
10/22/84
10/30/90
10/30/90
02/11/86
03/19/86
01/24/86
10/30/86
04/30/88
07/30/85
12/18/85
02/05/91
10/11/91
lU/11/91
-------
Pag* No.
04/06/92
KEYWORD INDEX
PHOTOGRAPHIC FIXER RECYCLING
RECLAIMING PRECIOUS METALS FROM DISCAROEO AUTOMOTIVE AND ELECTRONIC OEVICES
RECYCLABLE MATERIALS WERE PRECIOUS METALS ARE RECLAIMEO
RECYCLED PRECIOUS METALS. BATTERIES FROM DEFENSE DEPT. SUPPLIES
SILVER IN VASTES ANO IN SEWER DISCHARGES FROM THE PHOTO-FINISHING INDUSTRY
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY
SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY, CHEMICAL RECOVERY CARTRIDGES FOR
SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY
USED X-RAY FILM AS A SPENT MATERIAL - SILVER RECLAMATION
Regeneration
CARBON REGENERATION FACILITIES
CARBON REGENERATION FACILITIES
CARBON REGENERATION UNITS - REGULATORY STATUS
REGENERATION OF USEO BATTERIES EXEMPTED FROM REGULATION
Reus*
SPENT PICKLE LIQUOR. DEFINITION AS HAZARDOUS
USEO BATTERIES RETURNED FOR REGENERATION EXEMPTION
I
•SOL10 ANO HAZARDOUS WASTE, DEFINED FOR SPENT SULFURIC ACIO
BAGHOUSE OUSTS USEO AS. OR TO PROOUCE. AGGREGATE
BRIQUETTING OF FLUE OUST (K0611 FOR STEEL PRODUCTION
CHLOROFLUOHOCARBONS (CFCs) AS REFRIGERANTS, RECYCLING OF SPENT
COAL TAR DECANTER SLUOGE WASTE PILE [TOLEOO COKE)
COLOREO GLAIE SOLIDS COLLECTED IN POTTERY MANUFACTURING OPERATIONS
COMMERCIAL FERTILIZERS CONTAINING K061 VASTES
COUNTING DRV CLEANING INDUSTRY WASTE ONLY AFTER REMOVAL FROM THE PROCESS - SQG RULE
DE10N12AT10N ACIO
OEIONIZATI0M ACID REUSED. NOT A WASTE
t DROSS FROM ALUMINUM SMELTING USEO IN MANUFACTURE OF CEMENT
EXCLUSIONS FOR K-WASTES DENIED (LACLEOE STEEL)
MERCURY SUITABLE FOR DIRECT USE (99X PURE) NOT SOLID WASTE
MERCURY. REFINING/REUSE OF SCRAP
RESIDUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES
REUSE/RECYCLE REGULATIONS IMPACT ON SPENT LEAD-ACID BATTERY RECYCLING
-5L	SPENT ACIDS AS WATER CONDITIONER
C	SPENT PICKLE LIQUOR USED/REUSED IS NOT SOLID WASTE
SPENT PICKLE LIQUOR, DEFINITION AS HAZARDOUS
SPENT PICKLE LiqUOR, REUSE OF
USE/REUSE EXCLUSION TO RED WATER (K047) FROM WHICH SODIUM SULFITE IS RECOVERED AND WHICH IS USED AS A FUEL
USED OIL OESTINEO FOR RECYCLING
USED REFRIGERANTS UNOER 40 CFR 261.2
WASTE ACIO AS WASTEWATER CONDITIONER AND AS INGREDIENT IN FERTILIZER
Use Constituting Disposal
•RECLAIMED SPENT WOOD PRESERVATIVE EXCLUSION IN 261.4(a)(9)
•USE CONSTITUTING DISPOSAL, RESIDUES FROM FIRE TRAINING EXERCISES
COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE
COPPER PLATING SOLUTION
OECHARACTERIZATIOH AND DISPOSAL OF HAZARDOUS WASTES WAT HAVE UNDERGONE CHEMICAL SOLIDIFICATION
K-WASTE FILTER CAKE IN THE MANUFACTURE OF CEMENT
PROPOSED BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) FOR K061 WASTE 	
SECONDARY MATERIAL SUBJECTED TO NOTICE REQUIREMENTS UNDER THE US-CANADIAN BILATERAL TREATY
SOIL CONTAMINATED WITH CHLORDANE AS A RESULT OF PESTICIDE APPLICATION
SPENT PICKLE LIQUOR, REUSE OF
USE OF PETROLEUM-CONTAMINATED SOILS AS AN INGREDIENT IN ASPHALT BATCHING
WASTE ACIO AS WASTEWATER CONDITIONER ANO AS INGREDIENT IN FERTILIZER
9496.1990(01
9432.1989
9551.1989(
9441.19861
9443.19061
9441.1987
9443.}987i
9441.1989
9441.1966
03!
03!
85!
is;
02
•*
3*
42!
9441.1986(26
9442.1986!
9489.19911
9441.19661
9441.198?!
949?.1991
9441.1986(17
9493.1991(03
9441.1987(58
9441.1989 40
9441.1987(75
9441.1988(17
9493.1986(05
9441.1986(67
9443.1986(11
9441.1986(39
9441.1989 01
9441.1989 48
9441.1986(43
9441.1986	06
9496.1991(01
9497.1986(01
9441.1987(73
9441.1986(61
9441.1987	39
9441.1987(17
9441.1987(42
9495.1987(06
9441.1990(28
9441.1986(80
9441.1991(19)
9493.1985 04
9441.1986(68)
9443.1986(04)
9493.1985(05
9441.1990(35
9441.1988(06)
9441.1989(29)
9444.1986(20)
9441.1987(17)
9493.1991(02
9441.1986
iSSt
07/16/90
06/06/89
12/20/89
11/19/86
06/26/86
01/06/87
01/06/87
07/06/89
05/20/86
04/02/86
04/30/86
08/02/91
07/02/86
05/20/87
03/04/91
02/28/86
06/21/91
07/31/87
08/02/89
09/04/87
OS/18/88
09/11/86
09/08/86
05/12/86
05/12/86
02/07/89
09/12/89
05/30/86
01/21/86
08/05/91
02/06/86
08/31/87
08/18/86
05/20/87
03/31/87
06/09/87
04/17/87
10/18/90
10/20/86
12/01/91
11/30/85
09/11/86
01/22/86
12/13/85
12/21/90
03/09/88
06/15/89
09/29/86
03/31/87
06/20/91
10/20/86
-------
Page No.
04/06/92
KEYWORD INDEX
Rags and VIpars
DISPOSAL OF RAGS TO WIPE CRUDE OIL
DISPOSAL OR RECLAMATION OF RAGS
RAGS AND SIMILAR MATERIALS ADSORBING V0LIT1LES AND F-WASTES. HANDLING
RECYCLABLE CLOTH WIPERS AND DISPOSABLE INDUSTRIAL WIPERS USED TO CLEAN UP HAZARDOUS WASTES
SCRAP DEHP AND SMALL CAPACITORS CONTAINING DEHP, DISPOSAL REQUIREMENTS FOR
Spent Sol venta
•COMPARATIVE DEFINITIONS OF FOOI AND F002
•LAND DISPOSAL RESTRICTIONS - DISPOSAL OF WASTES GRANTED A VARIANCE
METHANOL TREATMENT STANOARDS
•SMALL QUANTITY DETERMINATION FOR SOLVENT RECLAIMER
•SOL 10 WASTE VARIANCE FOR SPENT SOLVENT
•SOLVENT MIXTURE RULE
•SOLVENT MIXTURE RULE APPLIED TO SPILL OF TOLUENE/BENZENE MIXTURE - CERCLA INTERFACE
•SPENT SOLVENT LISTING
•SPENT SOLVENT LISTINGS
•SPENT SOLVENT LISTINGS
•SPENT SOLVENT MIXTURES (F-WASTESI
•SPENT SOLVENTS FROM VARNISH STRIPPING	j
1,1,1-TRICHLOROETHAHE CONTAINED IN A SAND-METAL-SOLVENT MIXTURE	I
ACTIVATED CARBON CANISTERS SATURATED WITH SPENT SOLVENTS
BIF REGULATIONS EFFECTS ON INDUSTRIAL BOILER
CHLOROFLUOROCARBONS (CFCsl AS REFRIGERANTS, RECYCLING OF SPENT
EXEMPTION FOR COMMERCIAL CHEMICAL PRODUCTS BURNED FOR ENERGY RECOVERY
INK FORMULATION WASTES AS BOTH K0B6 AND F001-005 WASTES
IRON CAKE WASTE GINERATEO DURING THE PRODUCTION OF METHYLOOPA
LUBRICATING OIL AND JET FUELS USED TO PRODUCE PETROLEUM PRODUCTS
MIXTURES OF SPENT SOLVENTS - F001-F005, REGULATORY STATUS OF
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
* RESIDUALS MATERIALS CONTAMINATED WITH TRACE SOLVENTS
RESIDUE FROM SPENT SOLVENT RECLAMATION CONSIDERED HAZARDOUS
SOLVENT AND COMMERCIAL CHEMICAL PRODUCT WASTE STREAMS
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS
SOLVENT STILL AS RECYCLING UNIT - REGULATORY STATUS OF
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER
SOLVENT-CONTAMINATED WASTESTREAMS FROM PHARMACEUTICAL MANUFACTURER
SOLVENT-CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTURE
SPENT PIPELINE FILTER CARTRIDGES
SPENT SOLVENT LISTINGS fc LEACHATE FROM SANITARY LFi THAT RECEIVED HAZARDOUS WASTE
SPENT SOLVENT RECOVERY, WASTE MANAGEMENT TAX
STILL BOTTOM WASTE GENERATED 8Y A POLYSTYRENE PRODUCTION FACILITY
STILL BOTTOMS GENERATED AND REMOVED FROM A RECYCLING UNIT
WASTE SOLVENT-BASED GLUE
WASTES GENERATED FROM EXTRACTION PROCESS
SPENT MATERIALS
9441.1909
9444.1989
9441.1989
9441.1986
9441.1905
23)
13
50
53
23
9444.1991(03)
9551.1980 05
9554.1990(04)
9441.1987(10)
9433.1905(03)
9441,1907(10)
9443.1985(11)
9441.1989 55)
9444.1988(091
9444.1966(14}
9443.1906(05)
9441.1986(57)
9443.1989(07)
9441.1986(54)
9468.1991(03
9441.1909(40)
9441.1960(33
9444.1987(41)
9443.1967(32
9494.1985 01
9441.1984(06)
9441.1986(21)
9444.1991(04)
9441.1984(03)
9444.1989(03)
9441.1986(89)
9441.1985(24)
9441,1988 49
9443.1988(11)
9442.1987(06)
9444.1988(03)
9444.1983(01)
9441.1986(41)
9432.1988(01)
9453.1989(04)
9443.1989(02)
9442.1986(07)
05/31/89
10/20/89
10/20/89
07/03/86
06/27/85
05/01/91
05/30/88
03/07/90
02/28/87
09/30/85
03/30/87
11/30/85
10/30/89
04/30/88
06/30/86
01/30/86
05/30/86
07/10/89
07/15/86
09/23/91
08/02/89
07/27/88
09/15/87
12/16/87
10/01/85
04/10/84
03/13/86
08/30/91
02/16/84
06/28/89
12/02/86
06/27/85
12/06/88
12/06/88
10/26/87
02/11/88
06/10/83
05/20/86
02/11/88
04/18/89
04/12/89
07/02/86
(See Solid Watte)
SPENT SOLVENTS
XREF
/ /
(See Solvents)
XREF
-------
Page No.
04/06/92
\
KEYW0R0 INDEX
SPILLS
(Sw Contingency Plan) (See alas Corrective Action)
STATE AUTHORIZATION
XREF
/ /

ABOVE-GROUND LAND EMPLACEMENT FACILITIES. N.J. LAW
ALTERNATE CONCENTRATION LIMIT (ACL) POLldv FOR HSWA PROVISIONS
CALIFORNIA AUTHORIZATION - EVALUATION OF THE WASTE EVALUATION TEST
CLOSURE AND POST CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS
COAL ASH AS A SOLID WASTE
rnPBFrrivf irTiiw at (tnrtii path mrc
EFFECTIVE DATES FOR CHARACTERISTIC & LISTED WASTES PER 03/19/87 CLEAN CLOSURE REGULATION
JURISDICTION AND REGULATION OF MIXED WASTE MANAGEMENT INCLUDING INCINERATION AND LOCATION CRITERIA
K006 WASTE ANO ONSITE DISPOSAL UNIT CONTAINING THESE WASTES
PROCESS WASTE OELISTED BY THE STATE DESIGNATES THE WASTE NON-HAZARDOUS WITHIN THE STATE
RCRA 3001(f)(2)(b) AND STATES' EXCLUSION OF WASTES FROM REGULATION AS HAZARDOUS
REGULATION OF HAZARDOUS COMPONENTS OF RADIOACTIVE MIXEO WASTE
RISK RETENTION GROUPS AND FINANCIAL ASSURANCE REQUIREMENTS
STATE AUTHORIZATION TO REGULATE HAZARDOUS COMPONENTS OF RADIOACTIVE MIXED WASTES
WASTEWATER TREATMENT SLUDGES CONTAINING METHANOL
AuthorIcad States
CARBON REGENERATION UNITS - REGULATORY STATUS
CHANGES OURING INTERIM STATUS IN PHASE II AUTHORIZED STATES
DELISTING OF WASTE BY AUTHORIZED STATES
DETERMINING WHETHER STATE HAZARDOUS WASTE REQ. ARE BROADER Oft MORE STRINGENT THAN THE FEDERAL RCRA PROGRAM
ORAFT STATE RCRA PERMITS, EPA REVIEW OF
' EPA ENFORCEMENT OF RCRA-AUTHORIZED STATE HAZARDOUS WASTE LAWS AND REGULATIONS
FEDERAL DELISTING AND RCRA PERMITTING IN INTERIM AUTHORIZED STATES
INTERIM AUTHORIZATION OF PROGRAMS BASED ON EMERGENCY STATE REGULATIONS
K006 WASTE AND ONSITE DISPOSAL UNIT CONTAINING THESE WASTES
MIXED WASTES AT OOE FACILITIES. REGULATION OF
PART B FINANCIAL RESPONSIBILITY INFO. REQ. FOR OWNERS/OPERATORS IN STATES WITH ONLY PHASE I AUTHORIZATION
P1C-82-5 AND RSI *5 JOINT PERMITTING ON PHASE 1 AUTHORIZED STATES
QUANTUM TECH PLASMA ARC UNIT - REGULATORY CLASSIFICATION
RCRA PERMIT REAUTHORIZATION ISSUES IN REGION III
RELEASES OF HAZARDOUS WASTE, RCRA APPLICABILITY TO
ROLE OF AUTHORIZED STATES IN DISPUTE RESOLUTION
STATE CAPABILITY ASSESSMENT GUIOANCE
STATE PERMITTING DURING PHASE 1 INTERIM AUTHORIZATION
TC APPLICABILITY TO MIXED WASTE
TRANSFER OF FEDERAL RCRA PERMITS TO AUTHORIZED STATES ANO COMPLIANCE WITH 40 CFR 124.10(e)
WASTES NEWLY REGULATED UNOER HSWA. MANAGEMENT OF
Capability Assessments
HAZMOOUS WASTE MANAGEMENT CAPACITY AND RCRA CONSISTENCY ISSUES
Changing Federal Regulations
DOCUMENTING EQUIVALENCE OF PART 265 CLEAN CLOSURE WITH PART 264 REQUIREMENTS
RADIOACTIVE WASTE EXEMPTION IN NORTH AND SOUTH CAROLINA
STATE PERMITTING DURING PHASE I INTERIM AUTHORIZATION
,nt#rRCRAURSIIP|2:tEXTENSI0N OF INTERIM AUTHORIZATION HAZARDOUS WASTE PR06RAMS
9467.1966(04
9481.1987 07
9442.1988(03
9476.1987(08
9571.1990(02
9502.1986(06
9476.00-16
9541.1966(14
9432.1987 09
9541.1986(04
9541.1986(05
9541.1966(19
9477.00-5
9541.1986(20)
9441.1989(52)
9489.1991(04
9542.1983
9542.1980
1541.1984
9522.1984
9541.1982
9542.1982
9542.1980
9432.1987
9503.1985' 02
9477.19821 01
9543.00-1
9488.1991(04
9541.1985 01
9502.1987(05
9541.1987(01
9543.1984(01
9542.1980(03
9441.1991(02
9541.1984(05
9541.1985 05
9572.1988(03) 12/23/88
9476.00-18
9541.1984(08)
9542.1980(03
05/12/88
09/13/84
10/17/80
9542.1985(01) 01/11/85
-------
Page No.
04/06/92
KEYWORD INDEX
sz
s>
Joint Perm)ttlno
FEDERAL PERMITS IN STATES WHICH HAVE RECEIVED FINAL AUTHORIZATION
HSWA AUTHORIZATION ISSUES - JOINT PERMITTING
RCRA PERMIT REAUTHORIZATION ISSUES IN REGION III
RCRA PERMITS WITH HSWA CONDITIONS - JOINTLY ISSUED PERMITS
WASTE MINIMIZATION: PERMIT CERTIFICATION AND JOINT PERMITTING
WASTES NEWLY REGULATED UNOER HSWA, MANAGEMENT OF
Nora Stringent/Broader In Scopt
'STATE PROGRAMS
AUTHORIZATION OF STATE PROGRAMS TO IMPLEMENT LAND DISPOSAL RESTRICTIONS PROGRAMS
DETERMINING WHETHER STATE HAZARDOUS WASTE REQ. ARE BROADER OR MORE STRINGENT THAN THE FEDERAL RCRA PROGRAM
SLUDGES WITHIN SURFACE IMPOUNDMENTS. NEWLY REGULATED DUE TO TC RULE
Pre-HSWA Provisions
INDUSTRIAL FURNACES BURNING HAZARDOUS WASTES ANO THE RESIDUALS GENERATED (LOUISIANA REG)
State Laws
'LAND DISPOSAL RESTRICTION
DESIGNATED FACILITY UNOER THE TREATABILITY STUOY EXCLUSION
HSWA AUTHORIZATION ISSUES - JOINT PERMITTING
STATE AUTHORIZATION ANO REGULATION OF RADIOACTIVE MIXED WASTES
USED BATTERIES RETURNED FOR REGENERATION EXEMPTION
State Permits
DRAFT STATE RCRA PERMITS, EPA REVIEW OF
INVOLVEMENT OF STATES WITHOUT PHASE II INTERIM AUTHORIZATION IN RCRA PERMITTING
REQUIREMENT THAT STATE-PERMITTED HAZAROOUS WASTE FACILITIES HAVE INTERIM STATUS
STATE PERMITS ISSUED BEFORE RECEIVING RCRA PHASE II AUTHORIZATION
State Programs
•DELISTING BY STATES
EXCLUSION OF WASTES GENERATED AT INDIVIDUAL FACILITIES (OEL1STING)
HSWA EFFECT ON STATE DELISTING DECISIONS
LETTER TO STATE ENVIRONMENTAL COMMISSIONERS:SUBTITLE 0 STATE SOLID WASTE MANAGEMENT PLANS
SOURCE REDUCTION AND RECYCLING TECHNICAL ASSISTANCE GRANTS FOR STATES
STATE PROGRAM ADVISORY 12 - RCRA AUTHORIZATION TO REGULATE MIXED WASTE
STATE PROGRAM REVISION AUTHORIZATIONS PILOT DELEGATION TO THE REGIONS
TRANSFER OF NOTIFICATION ANO PERMIT APPLICATION INFORMATION TO STATES
State Regulations
CONTAINED-IN POLICY
INCINERATORS FOR DESTRUCTION OF NERVE AGENTS. HIGH PRIORITY PERMITTING
LEAD SHEILDING FOR RADIOACTIVE WASTE IS A RCRA SOLID WASTE
LOCATION STANDARDS FOR HAZARDOUS WASTE MANAGEMENT FACILITIES
PROCESS WASTE DELISTED BY THE STATE DESIGNATES THE WASTE NON-HAZARDOUS WITHIN THE STATE
STATE REGULATION OF FEDERAL AGENCIES FOR PURPOSE OF INTERIM AUTHORIZATION
9541.1964(09)
9541.1985 09
9541.1985 01
9502.1967(06)
9560.1985 01
9541.1985 05
9572.1966(01)
9541.1986(13)
9541.1984(04)
9484.1991(0l|
9541.1987(10
9432.1991
9541.1985
9541.1987
9497.1991
9522.1984(04)
9542.1981(01)
9542.1960(01)
9542.1982(03)
9541.1966(24
9542.1982 01
9433.1965(02
9572.00-02
9581.1988(01)
9541.00-6
9541.1991(01)
9542.1981(02)
9441.1991(04
9501.1986(01
9444.1991(02
9472.1991(01
9541.1966(04
9542.1960(05
04/04/84
07/01/65
03/06/85
06/30/87
09/11/85
05/06/85
09/30/86
06/24/86
05/21/84
03/08/91
9494.1967(02) 04/15/87
12/30/87
09/27/91
07/01/85
06/29/87
03/04/91
10/01/64
02/12/81
10/03/80
08/09/82
10/30/86
05/25/82
05/16/65
02/22/88
11/01/88
07/30/87
03/11/91
03/24/81
03/26/91
09/11/86
04/30/91
10/01/91
03/03/86
11/14/80
STATE LAWS
(See State Authorization)
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
\
STATE PEWITS
(S«a State Authorization)
STATE PROGRAMS
XREF
I /
(See State Authorization)
STATE REGULATIONS
XREF
/ /
(See State Authortzat(on)
STATUTORY AUTHORITY
XREF
/ /
REGULATION OF HAZARDOUS COMPONENTS OF RADIOACTIVE MIXED WASTE
STEEL FOUNDRIES
9S41.1986(19) 10/14/86
(Sea Listed Hazardous Waste)
ST0RA6E
XREF
/ /
Ov
&
(See also Containers, Hazardous Waste Fuel, Tank System, Permit Conditions)
MOO-1000 Kj/MONTH GENERATORS
'CERTIFICATION FOR CONTAINER STORAGE
'HAZARDOUS WASTE TANK CLOSURE ANO POST CLOSURE
•LAND DISPOSAL RESTRICTIONS - STORAGE OF HAZAROOUS WASTE
'PROHIBITION ON STORAGE OF RESTRICTED WASTES
•SATELLITE ACCUMULATION
•SECONDARY CONTAINMENT VARIANCES FOR TANKS
•SQG, 100-1000 Kg/HONTH GENERATORS, ANO THE MANIFEST
•STORAGE OF RESTRICTED WASTES
•STORAGE PRIOR TO RECYCLING
•WASTE ANALYSIS FOR SIMPLE STORAGE AT INTERIM STATUS FACILITIES
ABOVE-GROUND LAND EMPLACEMENT FACILITIES, N.J. LAW
ACCUMULATION OF HAZARDOUS WASTE IN TANKS I90-OAY1
ACCUMULATION OF SECONDARY MATERIAL - ABANDONED Vs. DISPOSED OF
ADMINISTRATIVE CONTROLS ANO STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
CLOSURE REQUIREMENTS
CONTAINERS FOR SAFE AND ECONOMICAL STORAGE, TRANSPORT, AND DISPOSAL OF HAZAROOUS WASTE, DEVELOPMENT OF
CONTAINMENT AND DETECTION OF RELEASE FROM HAZAROOUS STORAGE TANK SYSTEMS
COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZER
OOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO DISPOSE OR OESTROY THEM
FOUNDRY SANOS RECYCLEO AND RETURNED TO THE FOUNDRY
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
HAZARDOUS WASTE RECYCLERS
HAZARDOUS WASTES THAT ARE RECYCLED, HANDLING
HOLDING. TEMPORARY. PERIOD, STORAGE, AND DISPOSAL (DEFINITIONS)
INTERPRETATION OF 3005(i)(l)
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER
MIXED WASTE REGULATION - RCRA. REQUIREMENTS VS. NRC REQUIREMENTS
XREF
9451.1987(04
9523.1983 02
9476.1986(02
9551.1967(05
9453.1986(06
9453.1985(06
9483.1986(06
9475.1905(02
9551.1986(24
9475.1987(01
9472.1983(01
9487.1986(04
9453.1982(01
9441.1985(25
9494.1986(05
9476.00-12
9482.1985(01
9483.1988(10
9493.1986(01
9441.1985(31
9441.1987(13
9432.1986(05
9461.1988(01
9441.1986 76
9432.1986 12
9484.1985(01
9441.1986(73
9451.1989 02
/ /
08/30/87
02/28/83
09/30/86
02/28/87
11/30/86
12/30/85
10/30/86
10/30/85
12/30/06
04/30/87
07/30/83
03/26/86
08/31/82
07/01/85
04/11/86
02/02/88
11/26/85
06/03/88
01/22/86
10/31/85
03/04/87
02/05/86
08/31/60
10/08/86
07/28/86
07/25/85
09/25/86
06/26/89
-------
Page No.
04/06/92
KEY WHO INOEX
\
MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTS
NO-MIGRATION PETITION FOR MARATHON PETROLEUM. 1L
RCRA STORAGE FACILITY REQUIREMENTS. OFF-LOADING FROM TANK TRUCKS
RECYCLING OF MOLDING AND CASTING SANDS
REGULATION AND PERMITTING OF LABORATORIES
REPROCESSING OF BATTERIES
REQUIREMENTS OF A FACILITY GENERATING, STORING. AND MANIFESTING F001
REUSE/RECYCLE REGULATIONS IMPACT ON SPENT LEAD-AC10 BATTERY RECYCLING
SECONDARY LEAD SHELTER VARIANCES
SLUDGE WASTE HANDLING IF TEHP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITY
SOLVENT RECLAMATION OPERATIONS AT SEMICONDUCTOR FIRMS AND APPLICABLE REGULATIONS
SPENT SULFURIC ACID ACCUMULATED SPECULATIVELY
STORAGE FACILITIES, RCRA APPLICABILITY TO
STORAGE PERMIT FOR FACILITIES INVOLVED IN HAZARDOUS WASTE RECYCLING
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
TANK SYSTEMS SINCE CHANGES IN DEFINITION OF HAZARDOUS WASTE, CLASSIFICATION OF
TRANSPORTATION REGULATIONS
STUOENT'S T TEST
(See Groundwater Monitoring)
9441.1986(30
9551.1990(09
9480.1988(01
9441.1986 01
9441,1988(39
9497.1987(02
9475.1986 Ola)
9497.1986(011
9444.1988 14
9433.1986 17
9441.1986(89
9441.1988(19
9432.1983(02
9441.1989(11
9523.00-17
9463.1988 03)
9461.1990(01
XREF
04/16/86
11/06/90
12/09/88
01/06/86
08/30/88
02/19/87
10/30/86
02/06/86
08/26/88
09/30/86
12/02/86
OS/26/88
11/29/83
03/27/89
09/02/88
02/08/88
06/07/90
/ /
SUBPART X
(A
(See also Permit Application. Federal Facilities, Charactertitle Kaiardous Waste)
"TREATABILITY STUDIES ON HAZARDOUS WASTE SAMPLES, PERMIT REQUIREMENTS
DETONATING EXPLOSIVE WASTES
TOTALLY ENCLOSEO TREATMENT EXEMPTION FOR WET-AIR OXIDATION UNIT(VERTECH)
Geologic Repositories
CRYSTAL SALT MINE FOR STORAGE ANO DISPOSAL OF HAZARDOUS WASTE
PERFORMANCE STANDAROS FOR DISPOSAL IN SALT OOMES
PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT MINES
Miscellaneous Units
DETONATING EXPLOSIVE WASTES
DRUM SHREDDER REGULATION
MISCELLANEOUS UNITS SUBPART X. IMPLEMENTATION GUIDANCE
OPEN BURNING/OPEN DETONATION AT ODD FACILITIES
PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT MINES
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
TWEE AND FOUR-SIDED. FLOORED STRUCTURES, REGULATORY CLASSIFICATION OF
TOTALLY ENCLOSEO TREATMENT EXEMPTION FOR WET-AIR OXIDATION UNIT(VERTECH)
Open Burning/Open Detonation (OB/OD)
DEMILITARIZATION OF MUNITIONS
DOD MUNITIONS BECOME SOLID WASTE SUBJECT TO RCRA WHEN THERE IS AN INTENT TO OISPOSE OR OESTROY THEM
FIRE TRAINING PITS. REGULATORY REQUIREMENTS FOR
MISCELLANEOUS UNITS SUBPART X, IMPLEMENTATION GUIDANCE
OPEN BURNING/OPEN DETONATION AT DOD FACILITIES
THERMAL TREATMENT UNITS, SCOPE OF SUBPART X
Thermal Treatment
ASH RESIDUE GENERATED FROM INCINERATION OF K045
CARBON REGENERATION UNITS - REGULATORY STATUS
XREF
9441.1986(58
9443.1987 30
9432.1986(06
9469.1986(03
9489.1991(05
9472.1986(04
9443.1987(30)
9441.1988(28)
9489.00-2
9502.1986(16
9472.1986(04
9523.00-16
9432.1987
9432.1986
9441.1987(03
9441.1985(31
9489.1987(02
9489.00-2
9502.19861
9489.1988
9441.1987(12
9489.1991(04
/ /
06/30/86
11/30/87
02/06/86
04/24/86
02/22/91
06/04/86
11/30/87
06/24/88
04/22/89
09/22/86
06/04/86
03/14/89
04/02/07
02/06/86
01/07/87
10/31/85
07/22/87
04/22/89
09/22/86
05/18/88
03/03/87
08/02/91
-------
Page Ho.
04/06/92
KEYWORD INDEX
ON-SITE TREATMENT EXEMPTION. REINTERPRETATION OF
QUANTUM TECH PLASMA ARC UNIT - REGULATOR? CLASSIFICATION
THERMAL TREATMENT UNITS, SCOPE OF SUBPART X
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR WET-AIR OXIDATION UNIT(VERTECH)
SUBPARTS AA ANO SB
SUMPS
(See also Incineration)
CONTROL DEVICES REQUIRED BY THE ORGANIC AIR EMISSION STANDARD
SUBTITLE D
(Saa Solid Waste)
(Sea Secondary Containment)
9453.1987
9460.1991
9489.1988
9432.1966
081
04)
Oil
06}
XREF
9534.1991(01)
XREF
XREF
12/15/8?
09/30/91
0S/18/B8
02/06/86
12/03/91
/ /
/ /
SUPIRFUND
(See RCRA/CERCLA Interface)
SURFACE IMPOUNDMENT
XREF
/ /
V
(See also Land Disposal Facility)
'CIRCUMSTANCES FOR OBTAINING INTERIM STATUS FOR UNITS AT AN INTERIM STATUS FACILITY
•CLEAN CLOSURE
~CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT AND WASTE PILE
•CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENTS
~CORRECTIVE ACTION FOR INTERIM STATUS SURFACE IMPOUNDMENT
~EXISTING SURFACE IMPOUNDMENTS WITH LINERS
~INTERIM STATUS VS. PERMIT MODIFICATION FOR NEWLY-REGULATED UNITS
~LEAK NOTIFICATION AT A DOUBLE-LINEO SURFACE IMPOUNDMENT
•POST CLOSURE PERMITS FOR SURFACE IMPOUNDMENT
~REMOVAL OF TC WASTE FROM A SURFACE IMPOUNDMENT
•RETROFITTING FOR PERMITTED SURFACE IMPOUNDMENTS
•RETROFITTING INTERIM STATUS SURFACE IMPOUNDMENTS
•RETROFITTING SURFACE IMPOUNDMENTS
•SURFACE IMPOUNDMENTS CONTAINING WASTEWATER WHICH BECOMES REACTIVE WHEN DRY
•SURFACE IMPOUNDMENTS RECEIVING HAZARDOUS WASTE
ADJACENT WASTE PILES INTO REGULATED SURFACE IMPOUNDMENT, PLACEMENT OF (C1BA-GEIGY)
CLOSURE AFTER CESSATION OF RECEIPT OF HAZARDOUS WASTE
CLOSURE ANO POST CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS
CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUS
CLOSURE PERFORMANCE STANDARD
CLOSURE REQUIREMENTS
COMBINATION OF SLUDGES FROM ALL IMPOUNDMENTS TO DETERMINE WASTE VOLUME FOR VHS ANALYSIS
CONTAMINATED GROUND WATER ANO VOLATILES FROM AIR STRIPPING, TREATMENT OF
DEADLINES APPLICABLE TO PROPOSEO DELAY OF CLOSURE WWUTieN, GUIDANCE
HYDROGEN SULFIDE WASTE IN SURFACE IMPOUNDMENT - REACTIVITY CHARACTERISTIC
IMPROVEMENTS TO SURFACE IMPOUNDMENTS UNDER INTERIM STATUS
INTERIM STATUS SURFACE IMPOUNDMENTS * CLEAN CLOSEO WASTE PILES, CODIFICATION RULE 12/01/87
XREF
9522.1984(01)
9476.1987(03)
9522.1968(01)
9484.1987 04
9484.1986 07
9522.1984(02)
9525.1989(01)
9484.1965(02)
9522.1986(02a)
9443.1991(02)
9484.1967(09)
9528.1988(03
9476.1986(04)
9443,1983(02)
9441.1983(01)
9484.1987(06)
9476.1966(03
9476.1987(08)
9484.1986(02)
9476.00-13
9476.00-12
9433.1967(07)
9441.1966(86)
9476.1968(04)
9443.1967(31)
9528.1984 01)
9522.1988(05)
/ /
/ /
06/30/87
02/26/88
04/30/87
07/30/86
05/30/84
05/30/69
08/30/85
10/30/66
11/01/91
07/30/67
05/30/88
10/30/86
01/30/83
02/01/83
06/26/87
10/08/86
12/17/87
04/02/66
02/06/68
02/02/66
04/13/87
11/20/86
05/31/66
12/07/67
09/10/S4
11/30/88
-------
Page No.
04/06/92
KEYWORD INDEX

INTERPRETATION OF 3005(11(1)
K03S LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS
K103/K104 WASTE STREAMS - RELATIONSHIP OF CWA BAT. LAND DISPOSAL RESTRICTIONS, BOAT, AND DELISTING CRITERIA
LAND DISPOSAL UNIT CLOSURE CLARIFICATION OF PROPOSED AND PROMULGATED RULES
LIME SLUDGE IMPOUNDMENT SLUOGE, DELISTING OF
METAL. K061 WASTES IN SURFACE 1MPOUNDHENT-OEL1STINS PETITION
NTR COMPLIANCE DATES FOR SURFACE IMPOUNDMENTS (THERMEX ENERGY
1
NEUTRALIZATION SURFACE IMPOUNDMENTS. GROUNDWATER MONITORING FOR CLOSURE OF INTERIM-STATUS
NO-MIGRATION PETITION FOR ROBINSON. IL
OILY WASTEWATER TREATMENT PONDS, PERMITTING COVERAGE OF
OPERATING DAY DEFINED FOR TANKS ANO SURFACE IMPOUNDMENTS
PERMIT REQUIREMENTS, THERMEX ENERGY/RAOIAN
PETROLEUM REFINERY WW, MIXTURE ANO DERIVEO-FROM RULES
POTENTIALLY CONFLICTING REGULATION OF INFILTRATION GALLERIES BY THE OGWOW AND OSW
PREVIOUSLY UNREGULATED SURFACE IMPOUNDMENT - CORRECTIVE ACTION OROERS
PROTECTIVE COVERS FOR INTERIM STATUS SURFACE IMPOUNDMENTS
REOESIGNATION OF SURFACE IMPOUNDMENTS AS LANDFILLS DURING INTERIM STATUS
REPLACEMENT UNIT, DEFINED - WASTE CONSOLIDATION FROM SEVERAL IMPOUNDMENTS
REPLACEMENT UNIT, DEFINITION, FOR SURFACE IMPOUNDMENT
SECONDARY LEACHATE COLLECTION AND REMOVAL SYSTEMS - FML TOP LINERS
SLUDGE CONTAINING 1.1.1-TRICHLOROETHANE (TCE1
SLUDGES WITHIN SURFACE IMPOUNDMENTS, NEWLY RtGULATEO OUE TO TC RULE
SOLVENT-BEARING WASTEWATER, SLUDGE, AND BRINE TREATED AND STOREO IN SURFACE IMPOUNDMENTS
SPENT PICKLE LIQUOR. USE/REUSE EXEMPTION AS APPLIED TO
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
SURFACE IMPOUNDMENT CLOSURE. APPLICABILITY OF 300511) OF RCRA TO
SURFACE IMPOUNDMENT DELISTING PETITIONS, USE OF VHS MODEL
SURFACE IMPOUNDMENT RECEIVING LEACHATE. REGULATION OF
SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWEO FOR CLOSURE
SURFACE IMPOUNDMENT SAMPLING PLAN FOR HOLLOMAN AIR FORCE BASE
SURFACE IMPOUNDMENTS HOLDING ONLY K-WASTES GENERATED UNDER A TEMPORARY EXCLUSION
SURFACE IMPOUNDMENTS VIS-A-VIS NPDES-PERMITTED OISCHARGE POINTS
SURFACE IMPOUNDMENTS/LAND TREATMENT UNITS REGULATION IF ASSOCIATED WWT SLUDGES ARE LISTED
TANK AND SURFACE IMPOUNDMENT, 0EFINT10NS
TC RULE HAZARDOUS WASTE DETERMINATION
THREE AND FOUR-SIDED, FLOORED STRUCTURES, REGULATORY CLASSIFICATION OF
TREATMENT SURFACE IMPOUNDMENTS, REGULATORY OPTIONS AVAILABLE TO WOOD PRESERVERS
UCAPCO APPLICATION FOR A VARIANCE UNDER 3004(c)(2) OF RCRA
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
Retrofit
ACLt APPLIED TO SURFACE IMPOUNDMENT RETROFITTING PROVISION 3005(J)(3)
ALTERNATE CONCENTRATION LIMIT (ACL) POLICY FOR HSWA PROVISIONS
NEUTRALIZATION SURFACE IMPOUNDMENTS. RETROFITTING VARIANCES
SURFACE IMPOUNDMENT (IS) RETROFITTING WAIVER REQUEST (OCCIDENTAL CHEMICAL)
SURFACE IMPOUNDMENT RECEIVING NON-HAZARDOUS WASTE AFTER HAZARDOUS WASTE W/0 RETROFITTING
SURFACE IMPOUNDMENT RETROFITTING REQUIREMENTS
SURFACE IMPOUNDMENT RETROFITTING WAIVER REQUEST (UNION CARBIDE)
9484.19B5
9444.1907
9433.19871
9476.1905
9484.19861
9433.1987...
9484.1987(11
9484.19861
9551.19911
9502.1984
9483.1987 19
9521.1987
9441.19851
9521.1991
9502.1986(07a)
9484.1984
9528.1988102
9404.1987
9484.19861
9484.1967(03
01
52
06
05)
05 i
18
03)
14
01
01)
01)
01
13)
01
01
20)
9551.19871
9484.1991
9553.19871
9441.1985
9523.00-12
9476.1987(01)
9433.1987(25)
9484.1985(01b)
9484.00-5*
9484.1988(03)
9433.1987(23
9484.1986(09
9480.1985(02
9483.1983 01
9441.1991(12
9432,1967(02
9484.1987(12
9480.1987(02
9441.1986(28
9484.1987(08)
9481,1987(07)
9484.1986(04)
9484.1987 07)
9484.19861OS)
9484.1987 02
9484.1987 05
07/25/85
12/11/87
04/02/87
12/13/85
05/23/86
08/07/87
08/07/87
04/09/86
05/01/91
12/07/84
10/16/87
08/07/87
08/23/85
08/27/91
04/30/86
/ /
05/11/88
03/11/87
03/26/86
04/30/87
06/26/87
03/08/91
01/12/87
06/05/65
03/30/87
06/09/87
10/26/87
11/14/85
10/15/88
06/20/88
10/05/87
12/29/86
07/17/85
04/08/83
07/31/91
04/02/87
11/25/87
10/29/87
04/07/86
07/14/87
07/24/87
04/21/86
07/14/87
09/05/86
04/15/87
06/08/87
SURFACE WATER
1Se« «1*o Wastewater. Clean Water Act)
CLt PROPOSED BY UNION CARBIDE CORP., INSTITUTE, WV, COMMENTS ON
MARINE DEBRIS IN WATERS, DISPOSAL OF
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
XREF
9481.1987(04)
9432.1987(12a)
9523.00-14
/ /
06/19/87
11/04/87
03/14/86
-------
No.
06/91
KEYWORD INOEX
SW-846
ALLOWABLE HOLOINQ TINES WHEN TESTING RCRA SAMPLES
ANALYTICAL METHODS FOR CONDUCTING TESTING UNDER THE TC RULE
ASTH STANDARDS IN THE RCRA PROGRAM
DEFINING IGNITA6LE LIQUIDS METHOD
DILUTION OF TEST SAMPLING
LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISIIC LEACHING PROCEDURE (TCLP)
LAND DISPOSAL RESTRICTIONS REGULATION OF CVANIOES
METHODOLOGIES EMPLOVEO IN USED OIL SAMPLING
METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEDURE FOR OILY WASTE
METHODS 8240 AND 8260 DIFFERENTIATION AND EQUIVALENCY
SELECTION OF NON-USEPA APPROVED METHODS FOR SUBPART X PERMITS
SW-846 FOR REQUIRED WASTE ANALYSIS PURSUANT TO 264.13 AND 265.13
SW-846 TEST METHODS
SW-846, THIRD EDITION. HOLDING TIMES FOR SEMIVOLATILES
TCLP EXTRACTIONS APPLIED TO LIQUID WASTES. OILS AND SOLVENT-BASED PRODUCTS
USE OF THE METHOD OF STANDARD EDITIONS
9445.1987(04
9442.1991(17)
9445.1987 05
9442.1991(05
9442.1991(04
9443.1986(10)
9554.1991(01
9442.1991(11
9443.1987(14
9442.1991 06
9442.1990(03
9472.1905(01
9554.1991(04
9445.1987 06
9442.1991(14
9443.1987(121
12/04/87
10/01/91
12/21/87
03/27/91
03/25/91
05/05/86
01/08/91
07/09/91
08/11/87
05/09/91
11/19/90
05/30/85
12/01/51
06/30/87
10/29/91
06/23/87
SWMUs
(See Correction Action under Solid Waste Management Unit)
TANK SYSTEM
XREF
/ /
(See also Generator*. Secondary Containment)	XREF
t 'CHANGES DURING INTERIM STATUS - CORRECTION	9528.1988(05)
•CHANGES TO INTERIM STATUS TANK FACILITIES	9483.1988(16}
•GENERATOR CLOSURE/FINANCIAL REQUIREMENTS FOR TANK SYSTEMS	9483.1989(01)
•MANUFACTURING PROCESS UNIT	9441.1989(54)
—	*POST CLOSURE PLANS FOR HAZARDOUS WASTE TANKS	9476.1988(031
^	"WASTEWATER TREATMENT UNIT DEFINITION	9432.1988(05)
JL	CONCRETE LINERS FOR HAIAROOUS WASTE TANK SYSTEMS	9483.1988 04
CONTAINMENT AND DETECTION OF RELEASE FROM HAZARDOUS STORAGE TANK SYSTEMS	9483.1988 10)
INTEGRITY ASSESSMENT FOR TANKS AND POST-CLOSURE	9483.1989(04)
SECONDARY CONTAINMENT FOR EXISTING HAZARDOUS WASTE TANK SYSTEMS	9483.1989 03)
SECONDARY CONTAINMENT SYSTEMS CERTIFICATION	9483.1988 18)
SECONOARY CONTAINMENT SYSTEMS FOR HAZARDOUS WASTE TANKS	9483.1989 07)
STANDARDS FOR SECONDARY CONTAINMENT OF HAZARDOUS WASTE TANK SYSTEMS	9483.1989(02)
TANK SYSTEMS SINCE CHANGES IN DEFINITION OF HAZARDOUS WASTE, CLASSIFICATION OF	9483.1988(03)
TANK TREATMENT SYSTEM OF METAL-RICH RINSEWATERS	9483.1990(01)
Ancillary Equipment
HAZARDOUS WASTE TANK SYSTEM STANDARDS TO ANCILLARY EQUIPMENT AND EXEMPTED ELEMENTARY NEUTRALIZATION SYSTEMS	9483.1988(01)
INOEPENOENT ENGINEER QUALIFICATIONS ANO SCOPE OF THE TERM	9483.1987 II)
LOADING/UNLOADING AREA IN THE DEFINITION OF TANK SYSTEM	9483.1989i 08
OPERATED TO CONTAIN. DEFINITION	9483.1989 06)
PRESSURIZEO PIPING 4YSTEMS WITH AUTOMATIC SHUT-OFF DEVICES	9483.1987 14)
SEALEO BELLOW VALVES USED IN LIEU OF SECONDARY CONTAINMENT FOR GLOBE VALVES	9483.1986 02)
SEALLISS VALVE DEFINITION	9483.1987 18)
SECONDARY CONTAINMENT FOR PIPING SYSTEMS	9403.1987110
SECONOARY CONTAINMENT REQUIREMENTS FOR ABOVE GROUND WELDED FLANGES AND SEALLESS VALVES	9483.1987 17)
TANK SYSTEM APPLICABLE TO PRODUCTION TANKS DURING CLEAHOUT. PROCESS TRANSFER EQUIPMENT, AND HOSE LINES	9483.1986111
TANK TREATMENT PROCESSES	9483.1990(02)
/ /
10/30/88
09/30/88
04/30/89
10/30/89
04/30/88
10/30/88
03/16/88
06/03/88
10/30/89
03/14/89
12/12/88
11/30/89
01/09/89
02/08/88
08/01/90
01/27/88
07/20/87
03/17/88
11/30/89
08/03/87
08/27/86
10/01/87
07/09/87
09/23/87
12/19/86
08/15/90
-------
Page No.
04/06/92
KEYWORD INDEX
Empty
TANKS AND ANCILLARY EQUIPMENT DESIGN
TEMPORARY TANK SYSTEMS USED IN RESPONSE TO EMERGENCIES, REQUIREMENTS FOR
EMPTY CONTAINER RULE APPLIED TO TANKER OR VACUUM TRUCKS
EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCT
PESTICIDE DISPOSAL 8Y FARMERS AND CONTAINER MANAGEMENT
RESIDUES REMAINING IN EMPTY CONTAINERS. BURNING OF
TANK CARS AND ORUMS, DEFINITION OF EMPTY
UNRINSED CONTAINERS WHICH FORMERLY CONTAINED AN UNUSED FORMULATION OF PENTACMLOROPHENOL
Minimum Shall Thickness
HAZARDOUS WASTE TREATMENT/STORAGE TANKS. PERMITTING
MINIMUM SHELL THICKNESS REQUIREMENT, WAIVER
TANK SHELL THICKNESS REQUIREMENT
Tanks
(K
U'.
~APPLICABILITY OF SUBTITLE I
•CHANGES AT INTERIM STATUS TANK FACILITIES
•COKE AND COAL TAR RECYCLABLE MATERIAL REQUIREMENTS
•CONTINGENT CLOSURE I POST-CLOSURE PLANS FOR TANKS
•GENERATOR ACCUMULATION AND SECONDARY CONTAINMENT
•HAZARDOUS WASTE TANK - LEAK DETECTION
•HAZAROOUS WASTE TANK CLOSURE AND POST-CLOSURE
•HAZARDOUS WASTE TANK REGULATIONS
•HAZARDOUS WASTE TANKS
•HAZARDOUS WASTE TANKS
•HAZARDOUS WASTE TANKS - EXISTING VS. NEW TANK
•HAZARDOUS WASTE TANKS - INSTALLATION/CERTIFICATION OF SECONDARY CONTAINMENT
•HAZARDOUS WASTE TANKS AND GROUNDWATER MONITORING
•HAZARDOUS WASTE TANKS-AGE DETERMINATION
•HAZARDOUS WASTE TANKS/CONTAINERS - CAPACITY OF SECONDARY CONTAINMENT
•INSPECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKS
•LEAK DETECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKS
•LEAK TESTING FOR EXISTING HAZARDOUS WASTE TANKS
•MOBILE WASTEWATER TREATMENT UNITS
•RECIRCULATING TANK. REGULATION OF
•RELEASES FROM 90-DAY ACCUMULATION TANKS
•SECONOARY CONTAINMENT FOR HAZARDOUS WASTE TANKS
•SECONDARY CONTAINMENT FOR TANKS
•SECONOARY CONTAINMENT VARIANCES FOR TANKS
•TANK CLOSURE IN 1977 - RCRA APPLICIBILITY TO
•TANK INTEGRITY ASSESSMENTS
•TANK REPLACEMENT
•TANK WASTEWATER TREATMENT UNIT DEFINITIONS
•TANKS HOLDING HAZARDOUS WASTE
•TEMPORARY CLOSURE OF USTi
•TREATMENT TANKS FOR LEACHATE OR LIQUID WASTES
•WASTEWATER TREATMENT UNIT/GENERATOR ACCUMULATE TANK
ACCUMULATION AND TREATMENT OF WASTES 0N-S1TE/PERH1T REQUIREMENTS
CLOSURE REQUIREMENTS FOR THE OISPOSAL OF STORAGE TANKS
EVAPORATOR USED TO REMOVE WATER FROM HAZARDOUS WASTE
HAZARDOUS WASTE TREATMENT/STORAGE TANKS, PERMITTING
K035 LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS
MINIMUM SHELL THICKNESS REQUIREMENT, WAIVER
9483.1987(09)
9483.1987(04)
9441.1986102)
9441.1905 41
9457.1987(01)
9441.1986(041
9441.1984(34)
9444.1986(03)
9483.1984(01
9483.1983(05
9483.1983(02
9483.1988(05;
9528.1987(09
9441.1989(04
9483.1987(08!
9483.1986(10
9483.1988(08
9476.1986(02
9483.1986(05;
9483.1986(07
9483.1987(07
9483.1988(09
9483.1988(13
9483.1986 04
9483.1988(12
9483.1988(14
9483.1987(06
9483.1986(03
9483.1986(13
9432.1987(05
9483.1984(03
9453.1986(05
9483.1988(06
9483.1987(13
9403.1986 06
9480.1987(01
9483.1987(15
9477.1988(03)
9432.1988(03
9483.1987(02
9483.1989(05
9471.1984(01
9483.198B15
9453.1986 01
9483.1987(03
9441.1986(86
9551.1990(05
9432.1987(03
9483.1984 01
9444.1987(52
9403.1903(05
06/25/87
04/20/87
01/07/86
12/12/85
03/25/87
01/07/86
11/28/84
02/12/86
02/23/84
12/14/83
04/20/83
03/30/88
08/30/87
02/28/89
05/30/87
11/30/86
01/30/88
09/30/86
08/30/86
10/30/86
05/30/87
05/30/88
06/30/88
08/30/86
06/30/88
06/30/88
05/30/87
08/30/86
12/30/86
06/30/87
11/30/84
08/30/86
04/30/88
07/30/87
10/30/86
05/30/87
08/30/87
07/30/88
03/30/88
03/30/87
10/30/89
03/30/84
07/30/88
04/16/86
04/08/87
11/20/86
10/09/90
05/01/87
02/23/84
12/11/87
12/14/83
-------
KEYWORD INDEX
~
TANKS
ON-SITE TREATMENT EXEMPTION. RIINTERPRETATION OF
OPERATING OAY DEFINED FOR TANKS AND SURFACE IMPOUNDMENTS
PERMIT-EXEMPT STATUS OF SLUDQE DRYERS ADDED TO WASTEWATER TREATMENT UNITS
PETROLEUM REFINERY WASTES AND EXEPTIONS FOR WWTUs
ROM) PERMIT FOR A SLUDGE DRYING PROCESS IN A WASTE WATER SYSTEM
REGION V FUEL-BLENDING FACILITIES CONCERNS
SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANKS
SLUDGE DEHYDRATION EQUIPMENT THAT IS PART OF A WASTEWATER TREATMENT FACILITY
SLUDGE DRYER AODED TO WASTEWATER TREATMENT UNIT-EFFECT ON WWTU EXEMPTION
SHALL QUANTITY GENERATOR WASTE STREAMS - TANK RISK ANALYSIS
SOLID WASTE MANAGEMENT UNIT (SWHU1 DETERMINATION
TANK AND SURFACE IMPOUNDMENT, DEFINITIONS
TANK CONVERSION FROM WASTE STORAGE TO FEEDSTOCK STORAGE - REGULATION
TANK INSPECTION PROCEDURES
TANK RULES APPLIED TO WWT UNITS ANO DISTRIBUTION SYSTEMS
TANK SHELL THICKNESS REQUIREMENT
TANK SYSTEM DESIGN-SECONDARY CONTAINMENT
TANKS USED FOR EMERGENCY CONTAINMENT
THREE AND FOUR-SIDED, FLOORED STRUCTURES, REGULATORY CLASSIFICATION OF
TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING, REGULATION OF
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
TOTALLY ENCLOSED TREATMENT EXEMPTION ANO ACCUMULATION PROVISIONS APPLICABILITY TO AN ASH TREATMENT FACILITY
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR WET-AIR OXIDATION UNITIVERTECH1
TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWED FOR ALL GENERATORS SUBJECT TO 262.34
TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORS
TREATMENT OF HAZARDOUS WASTE IN GENERATOR'S ACCUMULATION TANKS
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANT
TREATMENT OF HAZARDOUS WASTES IN A GENERATOR'S ACCUMULATION TANKS AND CONTAINERS
USED OIL TANK CLASSIFICATION
WASTE STORAGE TANK ATTACHED TO FILTRATION UNIT
WOOD TREATMENT CYL1NOER CREOSOTE SUMPS
9453.1987(08)
9483.1987(19)
9503.52-1A
9403.1990(03)
9503.51-1A
9441.1991(17
9483.198?)IS
9522.1988(02
9432.1906 01
9441.1986(25
9483.199101
9483.1983(01
9483.1986(01'
9483.1983 03
9483.1986(09
9483.1983(02
9483.1987(05
9471.1984(03!
9432.1987(02;
9441.1986(14;
9432.1986(07
9432.1987(10
9432.1986(06;
9453.1986(07
9453.1991(02
9453.1987 02
9441.1986 62
9453.1986(08
9483.1906 06
9483.1983(04
9502.1986(15
12/15/87
10/16/87
01/02/86
09/20/90
12/24/85
11/04/91
09/11/87
03/07/88
01/06/86
03/26/86
01/04/91
04/08/83
08/13/86
09/21/83
11/28/86
04/20/86
05/29/87
09/06/84
04/02/87
02/25/86
02/11/66
08/28/87
02/06/86
12/05/86
09/20/91
03/25/87
08/19/86
12/22/86
10/31/86
09/30/83
09/12/86
(f.
6^
TAX
(See Tank System)
XREF
/ /
(See RCRA/CERCLA Interface)
TCLP (TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
XREF
/ /
J See Characteristic Hazardous Waste, Hazardous Waste Identification)
PPROPRIATENESS OF THE EP/ECLP SIMULATION OF CO-DISPOSAL SITUATION FOR MINING WASTES
XREF
9571.1985(01)
/ /
10/03/85
TEMPORARY EXCLUSION
(See Delisting)
XREF
/ /
-------
Pag* No.
04/06/92
KEYWORD INDEX
TEST METHODS
(See alio Analytic Methods, SW-846)
"SW-846 TEST METHOD 3060
ANALYTES TO LOOK FOR WHEN PERFORMING RCRA ANALYSIS
ANALYTICAL METHODS FOR PETROLEUM REFINING RESIDUES AND WASTES
BLAST SLAS TESTING PROCEDURES
CALIFORNIA AUTHORIZATION - EVALUATION OF THE WASTE EVALUATION TEST
COMPRESSIVE STRENGTH OF TREATED VASTES - USE OF SW-846 METHODS. WASTE IDENTIFICATION
OIOXIN STANDARD USEO TO TEST GAS CHROMATOGRAPHY COLUMNS, HANDLING OF
ELECTROPLATING SLUDGE, EXCLUSION PETITION
LAND DISPOSAL RESTRICTIONS TESTING AND RECORD KEEPING REQUIREMENTS
LIQUID, FREE LIQUID, RELEASABLE LIQUIO DEFINITIONS
RCRA METHODS AND QA ACTIVITIES (NOTES)
RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)
RCRA METHOOS AND QUALITY ASSURANCE ACTIVITIES (NOTES)
SOXTEC EXTRACTION SYSTEM VS. SOXHLET EXTRACTION SYSTEM FOR PREPARATION OF PCB SAMPLES
SULFIDE REACTIVITY CHARACTERISTIC
TESTING REQUIREMENTS ANO SOLIDIFICATION ISSUES UNDER LAND DISPOSAL REQUIREMENTS
Procedure
EXTRACTION PROCEOURE TOXICITY TEST
FLUFF ANALYSIS/SAMPLES
MULTIPLE EXTRACTION PROCEOURE, METHOD 1320
THERMAL TREATMENT
f (Sea Subpart X) (See also Incineration)
TNT
I
(See Hazardous Waste Identification)
* TOLUENE
(See Listed Hazardous Waste)
TOTALLY ENCLOSED TREATMENT UNITS
(See Exclusion)
TOXICITY
(See Hazardous Waste Identification)
TRANSFER FACILITIES
(See Transporters)
XREF	/ /
9443.1987(20)	09/30/67
9442.1989(03)	04/20/69
9445.1984 03	05/25/64
9442.1969(09)	11/03/69
9442.1988 03)	05/02/66
9445.1987(03a)	11/17/67
9441.1985(07)	02/13/85
9433.1964(05)	12/11/84
9551.1966(03)	05/13/86
9432.1969(04)	07/20/69
9445.1965(02)	04/23/85
9445.1984(01)	04/23/84
9445.1984 05)	12/20/84
9443.1968(06)	05/31/88
9443.1985(04)	07/16/85
9551.1988(01)	05/05/08
9443.1981101) 06/17/81
9442.1989 02) 01/25/89
9442.1989(08) 10/19/06
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
XREF	/ /
-------
Page No,
04/06/92
N
\
KEYWORD INDEX
TRANSPORTER
Transportation
DESIGNATED FACILITY UNDER TREATABILITY STUDY EXCLUSION
TRANSPORTERS
9432.1991(01) 09/27/91
(Set alio Generators)
*100-1000 Kg/MONTH GENERATORS
'DOMESTIC SEWAGE EXCLUSION
•EXPORT OF RECYCLABLE MATERIALS
'GENERATOR STANDARDS APPLICABLE TO TRANSPORTERS
•MANIFESTING REQUIREMENTS
EXPORT OF HAZARDOUS WASTES UTILIZEO FOR PRECIOUS METALS RECLAMATION
LABELING OF STEEL DRUMS NEEO HOT INCLUDE PREVIOUS CONTENTS
MIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS
SATELLITE ACCUMULATION
Transfer Facilities
•TRANSFER FACILITY AS CENTRAL COLLECTION POINT
GENERATION OF AIOS TO NAVIGATION (ATOM BATTERIES)
HAZARDOUS WASTE RECYCLERS
HAZARDOUS WASTE TRANSFER OPERATIONS
TEN DAY REGULATION FOR TRANSPORTATION OF HAZARDOUS WASTE
TRANSFER FACILITY REGULATION INTERPRETATION
UNIFORM HAZARDOUS WASTE MANIFEST COMPLETION INSTRUCTIONS
Transportation
• EXPORT OF HAZARDOUS WASTE
•MANIFEST REQUIREMENT FOR TRANSPORTATION OF SPENT SOLVENTS
•MANIFESTING REQUIREMENTS AND EPA 10 NUMBERS
BATTERY RECYCLING AND EXPORT
BULKING ANO CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WTIH DIFFERENT HAZARDOUS CODES
cA	BULKING OR CONTAINERIZING COMPATIBLE HAZARDOUS WASTES FOR TRANSPORTATION
CONSOLIDATION OF SHIPMENTS AND MIXING OF HAZARDOUS WASTE BY TRANSPORTERS
CONTAINERS FOR SAFE ANO ECONOMICAL STORAGE, TRANSPORT, AND DISPOSAL OF HAZARDOUS WASTE, DEVELOPMENT OF
DOT'S ROLE IN THE TRANSPORTATION OF HAZAROOUS WASTE
EXPORTATION OF MUNICIPAL WASTE TO CENTRAL AMERICA
EXPORTERS OF HAZARDOUS WASTE TO MEXICO, RESPONSIBILITIES OF
HAZARDOUS WASTE MARKING REQUIREMENT APPLIED TO STATE REGULATED WASTE
HAZAROOUS WASTE RECYCLERS
HAZARDOUS WASTES THAT ARE RECYCLED, HANDLING
INTERNATIONAL TRANSPORT OF LAB SAMPLES
LOR RULES REGAROING ALTERNATIVE TREATMENT STANDARDS FOR LAB PACKS
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER
MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OF
MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTS
PIPELINE TRANSPORTATION OF HAZAROOUS WASTE
PROCESS WASTE DELISTED BY THE STATE DESIGNATES THE WASTE NON-HAZARDOUS WITHIN THE STATE
RAW MATERIAL TRANSPORT VESSEL EXCLUSION FOR ALL WASTES GENERATED ON SUCH VESSELS
RCRA STORAGE FACILITY REQUIREMENTS. OFF-LOADING FROM TANK TRUCKS
RECYCLING OF MOLDING AND CASTING SANDS
REGULATION AND PERMITTING OF LABORATORIES
TRANSPORTATION REGULATIONS
XREF
9451.1987(04
9461.1987 04
9456.1986 01
9461.1989(02
9462.1907(02
9462.1966(01
9463.1900(01
9455.1991(01
9453.1987(07
9451.1989(02
9453.1989(07
9461.1991
9461.1987
9461.1988
9461.1989
9461.1986
9461.1990
9452.1991
9455.1986(01
9541.1985(07
9452.1989(01
9497.1987 01
9461.1985(01
9432.1990(02
9461.1983(01
9482.1985(01
9463.1980(01
9573.1990(01
9455.1987(02
9453.1984(01
9461.1988(01
9441.1986(76
9441.1989(20
9554.1990(13
9441.1986(73
9494.1986(01
9441.1986(30
9432.1986(08)
9541.1986(04
9441.1986 65
9488.1988(01
9441.1986(01
9441.1988(39)
9461.1990(01)
/ /
08/30/87
07/30/87
10/30/86
04/30/89
10/30/87
01/21/86
06/16/80
02/05/91
11/17/87
08/26/89
07/13/89
11/01/91
07/30/87
08/31/88
01/03/89
04/10/86
10/30/90
07/26/91
09/30/86
05/30/85
12/30/89
02/12/87
09/19/85
03/01/90
01/30/83
11/26/85
06/16/80
02/16/90
06/15/87
05/18/84
08/31/88
10/08/86
04/27/89
11/20/90
09/25/86
02/09/86
04/16/86
04/30/86
03/03/86
09/03/86
12/09/88
01/06/86
08/30/80
08/07/90
-------
Page No.
04/06/92
KEYWORD INDEX
TRUCK OR RAIL SHIPMENT OF HAZARDOUS WASTE TO A POTV
UNIFORM MANIFEST FORM, USE OF CONTINUATION SHEET
WASTE AS FUEL RULES AT 000 FACILITIES, IMPLEMENTATION
TREATABILITY STUB*
9441.1966(66
9452.1967(02
9494.1986(02
11/30/66
04/30/87
03/19/86
(Sea RCRA/CERCLA Interface)
TREATED WASTE
XREF
/ /
(See Treatment)
TREATMENT
XREF
/ /
(A
-9
'CONDITIONS FOR EXCLUSION OF PORTABLE TREATMENT UNITS
•SURFACE IMPOUNDMENTS RECEIVING HAZARDOUS WASTE
•TREATMENT CAPACITY
•TREATMENT OF INFECTIOUS WASTE
•TREATMENT-TWO PARTS TO DEFINITION
ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTS
AEROSOL CANS, ON-SITE OEPRESSURIZATION OF
BULKING AND CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WITH DIFFERENT HAZARDOUS CODES
CAPACITY VARIANCES AND UNDERGROUND INJECTION
CEMENT KILN OUST WASTE
CHEMICAL AGENT/MUNITIONS SYSTEM (CAOMS) IS NOT TOTALLY ENCLOSED AND SUGGESTED ROID PERMIT
COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-848 METHODS. WASTE IDENTIFICATION
CONTAMINATED GROUND WATER AND VOLATILES FROM AIR STRIPPING, TREATMENT OF
OECANNINQ AND CRUSHING OPERATIONS
DELISTING RESIDUE FROM TREATMENT OF LISTED WASTES
DIOXIN TRIAL BURNS FOR PURPOSES OF CERTIFICATION OR A RCRA PERMIT
ELECTRIC ARC FURNACE OUST AFTER ENCAPSULATION TREATMENT PROCESS
EVAPORATOR USED TO REMOVE WATER FROM HAZARDOUS WASTE
FOUNDRY SANDS RECYCLED AND RETURNED T® THE FOUNDRY
GRAY IRON FOUNORY WASTE DISPOSAL
GROUNDWATER CONTAMINATED WITH HAZARDOUS WASTE LEACHATE
HAZARDOUS WASTE TREATMENT TECHNOLOGIES. APPLICATION OF
HAZARDOUS WASTEWATERS USEO AS QUENCHWATER IN CEMENT PRODUCTION
LOR DETERMINATION OF WASTE STREAM DILUTION
LEA0-8EARING WASTES TREATMENT STANDAROS
MIXTURES OF LISTED AND CHARACTERISTIC WASTES
ON-SITE TREATMENT BY GENERATORS UNDER 262.34
ON-SITE TREATMENT EXEMPTION
ON-SITE TREATMENT EXEMPTION. REINTERPRETATION OF
PCB DECHLORINATION TREATMENT PROCESS
PERMITTING OF TREATMENT ACTIVITIES IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERS
PETROLEUM REFINERY WW. MIXTURE AND DERIVED-FROM RULES	
REFRACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY
REJECT SUBSTRATES CONTAINING VENAOIUM PENTOXIOE REGULATION UNDER RCRA
RESIDUE FROM SPENT SOLVENT RECLAMATION CONSIDERED HAZARDOUS
RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE, l.D. NUMBERS FOR
SOURCE REDUCTION
SPENT IRON SPONGE REGULATION ANO TREATMENT
STABILIZED WASTE PICKLE LIQUOR FROM STEEL/IRON INDUSTRY
SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTS
9471.1984102)
9441.1983(01)
9S2S.1986(07)
9432.1987(11)
9444.1990 01
9453.1986(01)
9432.1966(04)
9461.1985(01)
9489.1990(01)
9441.1988(36)
9432.1985(07)
9445.1987103a)
9441.1986(86)
9432.1984 03)
9441.1981(05)
9488.00-1A
9444.1986(33)
9432.1987(03
9441.1987(13
9486.1981(01)
9441.1986(83
9486.1985(01
9489.1991(01
9551.1990(06
9554.1990 06
9441.1987(68
9453.1987(03
9521.1987(03
9453.1987(08
9441.1988(47
9453.1986(04
9441.1985(29
9444.1988 05
9444.1986(17
9441.1984(03
9441.1966(05
9454.1987(01
9443.1986(02
9441.1990(16
9523.00-17
03/30/84
02/01/83
12/30/86
09/30/87
01/30/90
04/16/86
09/30/88
09/19/85
08/30/90
07/29/88
11/19/85
11/17/67
11/20/86
04/26/64
04/14/81
05/07/86
12/29/86
05/01/67
03/04/87
06/18/81
11/13/86
03/27/85
02/15/91
10/14/90
06/25/90
08/19/87
07/01/87
12/15/87
12/15/87
11/07/86
07/25/86
08/23/85
03/11/88
09/04/86
02/16/84
01/16/86
07/21/87
01/17/86
06/19/90
09/02/88
-------
Page Ho.
04706/92
KEYWORD INDEX
TANK TREATMENT PROCESSES
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECVCLER
TOTALLY ENCLOSEO TREATMENT EXEMPTION APPLICABILITY TO A BAGHOUSf SYSTEM
TOTALLY ENCLOSEO TREATMENT FACILITY, REGULATORY CLARIFICATION OF
TREATMENT AS DEFINED IN 40 CFR 260.iO SUBPART B
TREATMENT IN ACCUMULATION TANKS ANO CONTAINERS ALLOWED FOR ALL 6ENERAT0RS SUBJECT TO 282.34
TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORS
TREATMENT OF HAZARDOUS WASTE IN GENERATOR'S ACCUMULATION TANKS
TREATMENT OF HAZARDOUS WASTES IN A GENERATOR'S ACCUMULATION TANKS AND CONTAINERS
TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HAZARDOUS WASTE
WASTEWATER TREATMENT SYSTEM, SOLVENT RECOVERY STILL BOTTOMS IN
Biological
TC RULE HAZARDOUS WASTE DETERMINATION
I
I
Chemical Stabilization
BULK LIQUID HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTS
DRAFT SAMPLIN6 AND ANALYSIS PLAN FOR NH PLATING COMPANY
LAND DISPOSAL RESTRICTIONS REGULATION OF CYANIDES
LIQUIOS FOR WIND OISPERSAL CONTROL AT HAZARDOUS WASTE LANDFILLS, USE OF
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
Definition
BEVILL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
COMPACTING HAZARDOUS WASTE INSIOE STEEL DRUMS AS TREATMENT
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANT
DRUM
IInj Unit
SHREDDER
REGULATION
'Primary Treatment
SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS
Secondary Treatment
_	PERMIT-EXEMPT STATUS OF SLUDGE DRYERS ADDED TO WASTEWATER TREATMENT UNITS
G-	R010 PERMIT FOR A SLUDGE DRYING PROCESS IN A WASTE WATER SYSTEM
O	SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS
SLUDGE DEHYDRATION EQUIPMENT AS A WASTEWATER TREATMENT UNIT
SLUDGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WWTU EXEMPTION
Solidification
ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTS
BULK LIQUID HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTS
BULK LIQUIOS ANO DRAIN/LEACHING FIELDS
DECHARACTERIZATION ANO DISPOSAL OF HAZARDOUS WASTES THAT HAVE UNDERGONE CHEMICAL SOLIDIFICATION
FCB-CONTAMINATED WASTES, STABILIZATION OF
TESTING REQUIREMENTS AND SOLIDIFICATION ISSUES UNDER LAND DISPOSAL REQUIREMENTS
Totally Enclosed Treatment Unit
ARMY CHEMICAL/MUNITIONS SYSTEM, REGULATORY STATUS OF
Treated Waate
* TREATMENT WITHOUT A PERMIT - MIXING WASTE
REGION V FUEL-BLENDING FACILITIES CONCERNS
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE
TANK TREATMENT SYSTEM Of METAL-RICH R1N3EWATERS
9483.1990
9432.1986
9431.1986
9432.1983
9432.1984
9453.1986
9453.1991
9453.1987
9453.1986
9441.1988
9441.1985
9487.1987(01
9433.1990(06
9554.1991(01
9487,00-IA
9523.00-14
9441.1987(76
9503.199101
9441.1986(62
9503.52-1A
9503.51-IA
9441.1985(08
9432.1987(08
9432.1986(01
9453.1906
9487.19871
9487.1986
9493.19851
9487.19881
9551.19881
01)
Oil
09
05)
Oil
oil
08/15/90
02/11/86
12/22/86
02/18/83
11/26/84
12/05/88
09/20/91
03/25/87
12/22/86
10/27/68
12/17/85
9441.1991(12) 07/31/91
01/20/87
11/27/90
01/08/91
04/21/86
03/14/86
09/15/87
05/21/91
08/19/86
9441.1988(28) 06/24/88
9441.1985(08) 02/22/85
01/02/86
12/24/85
02/22/85
08/03/87
01/06/86
04/16/86
01/20/87
06/12/86
12/13/85
02/03/88
05/05/88
9527.1985(01) 11/19/85
9441.1986(45*)
9441.1991(171
9493.1991(Oil
9483.1990(01)
05/31/86
11/04/91
01/08/91
08/01/90
-------
Pag* No.
04/06/92
KEYWORD INDEX
TREATMENT STANOAROS
(Sea Land Disposal Restrictions)
TREATMENT STORAGE AND DISPOSAL FACILITIES (TSDFs)
XREF
/ /
GENERATOR WITH RESPECT TO REGULATION OF OPERATIONAL WASTES FROM SHIPS, DEFINITION
LEAKS. SPILLS. AND ILLEGAL DISCHARGES OF LISTED VASTES TO SURFACE WATERS, MIXTURE RULE APPLIED TO
LOCATION STANOAROS FOR HAZARDOUS WASTE MANAGEMENT FACILITIES
PRETREATHENT OF CHARACTERISTIC WASTES SUBJECT TO LAND DISPOSAL RESTRICTIONS
Active/Inactive Facilities
CORRECTIVE ACTION/PERMIT ISSUES-U.S. ARMY-ABERDEEN PROVING GROUNDS
OOD'S IRP PROGRAM AND RCRA CORRECTIVE ACTION
FACILITY TRANSFER/RECONSTRUCTION DURING INTERIM STATUS
NIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS
PERMIT ISSUES REGARDING ONSITE TREATMENT BY FLU10IZED BEO INCINERATION
RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIES
RISK RETENTION GROUPS AND FINANCIAL ASSURANCE REQUIREMENTS
SATELLITE ACCUMULATION AREA ANO REGULATIONS
SWNU CORRECTIVE ACTION RIA FACILITY DATA BASE
TRIAL BURN
KRFF
9441.1991(13)
94??.00-8
9432.1986(05)
9441.1986(071
9472.1991(01)
9551.1990 03
9502.1986!
9502.19861
94??.19861
9451.19891
9522.19851
9502.1986!
9477.00-5
9453.1987(01
9502.1987
iS»l
/ /
07/01/91
11/23/87
02/05/86
01/23/86
10/01/91
09/30/90
05/08/86
09/29/86
01/03/86
06/26/89
12/13/85
01/31/86
11/23/87
02/22/87
08/11/87
* (Set Incineration)
U-WASTES
XREF
/ /
(See Listed Hazardous Waste)
"""*' UNDERGROUND INJECTION
XREF
/ /
(See also Land Disposal Restrictions, Corrective Action, Disposal)	XREF
'CORRECTIVE ACTION FOR UIC WELLS	9502.1986(07
BULK LIQUIDS ANO DRAIN/LEACHING FIELDS	9487.1986 09
CAPACITY VARIANCES AND UNDERGROUND INJECTION	9489.1990 01
010XIN-C0NTAINING WASTE RINSEATES, DISPOSAL BY DEEP WELL INJECTION	9444.1985(14
LAND DISPOSAL OF HAZARDOUS WASTES - USE OF NUCLEAR TEST SITES	9480.1984(01
PERFORMANCE AND PERMITTING STANOAROS IN 3004(b). PROHIBITION OF PLACEMENT OF HAZAROOUS WASTE IN SALT DOMES	9489.1985(01
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR WET-AM OXIDATION UNIT(VERTECH)	9432.1986(06
9502.00-3
UIC CORRECTIVE ACTION REQUIREMENTS, IMPLEMENTATION
/ /
04/30/86
06/12/86
08/30/90
09/10/85
06/12/84
09/20/85
02/06/86
08/04/86
UNIVERSITIES
(See Generators) (Sea also EPA ID Number)
XREF
/ /
-------
Page No.
04/06/92
KEYWORD INDEX
UNSATURATED ZONE
($•¦ (rmmikitor Monitoring)
USE-CONSTITUTINS DISPOSAL
XREF
/ /
(Sm Recycle)
USED OIL
XREF
/ /
er
iSra also Burning and Blending, Harardous Waste Fuel, Patrolaun Refining Wastes)
URNIN6/8LINDIN6 OF UNUSEO COMMERCIAL CHEMICAL PRODUCT (XYLENE) WITH USEO OIL
•OFF-SPECIFICATION USEO OIL FUEL
•RECYCLED USED OIL-TECHNICAL CRITERIA FOR LISTING, COURT DECISION
•USED OIL AS OUST SUPPRESSANT
•USED OIL FOR MIST SUPFRESSION/ROAD TREATMENT
•USED OIL, DEFINITION OF
ATOMIZER MULTI-OIL FUELED HEATERS, INSPECTION AND CERTIFICATION CRITERIA FOR
AUTOMOTIVE FLUIDS, REGULATION OF
AUTOMOTIVE FLUIDS. STATUS OF
BOILERS USED IN GREENHOUSE OPERATIONS ARE INDUSTRIAL BOILERS
BURNIN6 OF USEO OIL
DECISION NOT TO REWIRE NOTIFICATION FROM GENERATORS WW BURN SPECIFICATION USEO OIL ON-SITE
HSWA PROHIBITION ON THE USE OF HAZARDOUS WASTE AS A OUST SUPPRESSANT
HYDRAULIC DEVICES CONTAMINATED WITH OIL DURING QUALITY CONTROL TESTING
LUBRICATING OIL CONTAMINATED WITH TCDD THROUGH USE AS AN ANALYTICAL STANDARD
METHODOLOGIES EMPLOYED IN USEO OIL SAMPLING
~ MIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTS
PROPOSED PERMIT-BY-RULE FOR USEO OIL RECYCLERS
REGULATION OF OILY HAZARDOUS PETROLEUM REFINERY WASTE
TC RULE OELAY OF IMPOSITION ON OIL FILTERS
TC RULE RELATIONSHIP TO USEO OIL FILTER DISPOSAL
TWO WASTE OIL MANAGEMENT PRACTICES REGULATORY STATUS
USEO OIL AND IDENTIFICATION OF LISTED HAZAROOUS WASTE
USED OIL CONTAMINATION THROUGH NORMAL USE OR NIXING WITH HAZAROOUS WASTES - RECYCLING DEFINED
USED OIL DEFINITION APPLICABILITY TO OPEN-GEAR LUBRICANT
USED OIL DEFINITION TO OPEN-GEAR LUBRICANT "GEAR1TE"
USED OIL OESTINED FOR RECYCLING
USED OIL FILTERS - REGULATION
USEO OIL FILTERS. REGULATORY DETERMINATION
USEO OIL FOR INDUSTRIAL BURNERS
USEO OIL INTRODUCED INTO REFINERY PROCESS UNDER HAZARDOUS WASTE DERIVED REFINERY FUEL PRODUCTS EXEMPTION
USEO OIL TANK CLASSIFICATION
Oo-It-Yoursalfera (OlYERS)
BURNING USED OIL IN SPACE HEATERS, INDUSTRIAL FURNACES, AND BOILERS
USED CRANKCASE OIL DISPOSED OF BY DO-IT-YOURSELFERS
Fual
•HAZARDOUS WASTE FUEL
•HAZARDOUS WASTE FUEL BROKERS
•HAZARDOUS WASTE FUEL IN INCINERATORS
•HAZARDOUS WASTE FUEL MARKETERS
•USE CONSTITUTING DISPOSAL, RESIDUES FROM FIRE TRAINING EXERCISES
XREF
9442.1905(01
9454.1986(02)
9433.1980(02
9493.1985(06
9441.1990	08)
9431.198801
9495.1980(02
9441.1987 14
9495.1987(04
9432.1986(03
9495.1985(02
9495.1987(05
9493.00-1A
9495.1986(20
9444.1987(48
9442.1991(11
9451.1989(02
9495.1986(30)
9493.1991	01
9441.1991(15
9451.1991(03
9495.1991(01!
9495.1990(01
9441.1984(30
9441.1990(33
9441.1990 27
9495.1987(06
9441,1990(30;
9442.1990(05
9495.1986 22,
9441.1986(11'
9483.1986(06
9495.1986(03)
9441.1987(64)
9494.1986(03
9454.1986(01
9441.1986(87
9453.1985(04
9493.1985(04
/ /
12/30/85
02/28/86
11/30/88
12/30/85
03/30/90
01/30/88
09/22/88
03/06/87
03/06/87
01/09/B6
10/17/89
03/26/67
05/31/86
08/22/86
10/23/87
07/09/91
06/26/89
11/24/86
01/08/91
09/25/91
04/16/91
06/05/91
06/13/90
10/22/84
11/30/90
11/30/90
04/17/87
10/30/90
10/30/90
09/15/86
02/11/86
10/31/86
02/13/86
08/13/87
03/30/86
01/30/86
11/30/86
11/30/85
11/30/85
-------
Pag# No. 1
Pag# No,
04706/92
KEYWORD INDEX
«r
ADMINISTRATIVE CONTROLS AND STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
BEV1LL AMENDMENT APPLIED TO COAL GASIFICATION FACILITY
8DILERS AND INCINERATORS, DISTINCTION BETWEEN/INTEGRAL DESIGN STANDARD
BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERY
BURNING COMPRESSOR OIL WITH AMMONIA IN SPACE HEATERS
BURNING OF OFF-SPEC USED OIL
BURNING OF USED OIL IN THE MARINE INDUSTRY AND USED OIL GENERATOR NOTIFICATION REQUIREMENTS
BURNING OFF-SPECIFICATION USED OIL FUEL IN GREENHOUSES
BURNING USED OIL AND THE LEAD SPECIFICATION
BURNING USED OIL GENERATEO BY PRIVATE BOAT OWNERS ON-SITE
BURNING USED OIL IN SPACE HEATERS, INDUSTRIAL FURNACES. AND BOILERS
BY-PRODUCT CRUDE OIL TANK BOTTOMS
COAL TAR OECANTER SLUDGE WASTE PILE (TOLEDO COKE)
ENFORCEMENT POLICY ON WASTE BURNING FOR ENERGY RECOVERY
HAZARDOUS WASTE FUEL CADENCE PRODUCT 312. REGULATION OF
HAZARDOUS WASTE HAS BEEN NIXED WITH USED OIL (lOOOppm total halomns) (REBUTTABLE PRESUMPTION)
INTERIM STATUS QUALIFICATION REQUIREMENTS TO HAZARDOUS WASTE FUEL STORAGE FACILITIES, APPLIED
LUBRICATING OIL AND JET FUELS USED TO PRODUCE PETROLEUM PRODUCTS
MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OF
NIXING HAZARDOUS WASTE WITH USED OIL (REBUTTABLE PRESUMPTION)
NOTIFICATION BY BURNERS OF USED OIL WHO FIRST CLAIM THAT USED OIL MEETS SPECIFICATIONS
OFF-SPECIFICATION JET FUEL BURNED AS KEROSENE FUEL
RECYCLED GASOLINE/WATER AND FUEL OIL/WATER MIXTURES
SPENT SOLVENT RECOVERY. WASTE MANAGEMENT TAX
SQG COMPLIANCE WITH TC RULE
USED OIL AND OIL BEARING HAZARDOUS WASTE-DERIVED REFINERY PRODUCTS
USED OIL CONTAMINATION THROUGH NORMAL USE OR MIXING WITH HAZARDOUS WASTES - RECYCLING DEFINEO
USED OIL FIRED SPACE HEATERS
USED OIL FUELS BURNED IN INCINERATORS
USED OIL INTRODUCED INTO REFINERY PROCESS UNDER HAZARDOUS WASTE OERIVEO REFINERY FUEL PRODUCTS EXEMPTION
USED OIL, BURNING OF OFF-SPECIFICATION FUEL, DUMPING
WASTE-AS-FUEL RULES AT OOD FACILITIES, IMPLEMENTATION
WASTE-DERIVED FUELS BURNED IN CEMENT KILN, REGULATION OF
Marketer
*USED OIL MARKETER - OEFINITION
ADMINISTRATIVE CONTROLS AND STORAGE STANDARDS FOR MARKETERS OF HAZARDOUS WASTE
HAZARDOUS WASTE FUEL CAOENCE PRODUCT 312, REGULATION OF
MARKETING OR BURNING HAZARDOUS WASTE FUEL. NOTIFICATION OF
USED OIL BURNED FOR ENERGY RECOVERY, INTERPRETATION OF SUBPART E
WASTE-AS-FUEL RULES AT DOD FACILITIES, IMPLEMENTATION
9494.19B6
9441.!987i
9432.1986i
9441.19B6
9494.1991
9494.1986
9495.198#
9491.1986
9495.1986
9494.1991
949S.1986
9441.1986
9441.1987
9494.1986
9494.1986
9495.1986
9528.1986
9494.1985
9494.1986
9495.1986
9495.1987
9441.1986
9441.1986
9441.1986
9441.1990
9495.1986
9441.1984
9495.1986
9495.1986
9441.1986
9441.1986
9494.1986
9494.1985
OS)
76
02
95
03:
05a)
09)
05
28
04|
03!
37!
98!
06
04!
08:
io!
01
01
01
19
22!
02
30!
*1
13
40
02!
03!
9495.1990(02)
9494.1986 05
9494.1986(04)
9494.1986(01)
9495.1989 01
9494.1986(02)
04/11/86
09/15/87
01/03/86
12/23/86
04/23/91
06/30/86
04/21/86
03/05/86
11/12/86
04/23/91
02/13/86
05/01/86
12/24/87
07/14/86
04/11/86
04/08/86
11/13/86
10/01/85
02/09/86
02/28/86
01/20/87
03/08/86
03/19/86
05/20/86
09/20/90
01/11/66
10/22/84
09/15/86
06/27/86
02/11/86
07/31/86
03/19/86
10/11/85
08/30/90
04/11/66
04/11/66
02/09/86
05/15/89
03/19/66
VARIANCE
(Set also Land Disposal Restrictions)
HAND DISPOSAL RESTRICTIONS VARIANCES
•SECONDARY CONTAINMENT VARIANCES FOR TANKS
'SOLID WASTE VARIANCE FOR SPENT SOLVENT
•VARIANCE FROM A TREATMENT STANDARD
'VARIANCES TO BAN - EFFECTIVE DATES FOR SOLVENTS AND DIOXINS
BOILER VARIANCE FOR A WASTE HEAT RECOVERY BOILER NOT OF INTEGRAL 0ES1GN, DENIAL OF
CAPACITY VARIANCES AND UNDERGROUND INJECTION
CONOCO PART B PERMITS
CONTAMINATED SOIL AND DEBRIS TREATED REPLACEMENT UNDER A TREATABILITY VARIANCE
GROUND-WATER MONITORING VARIANCE REQUIREMENTS
K001, P093, AND U059 CONTAMINATED SOIL TREATMENT STANDARDS
XREF
9551.19861
9483.19861
9433.1985
9433.19861 24
9551.1986
9433.1987
9489.19901
9553.19901
9551.19901
9481.19851
9554.19901
19)
OS)
03
22)
01
01)
Olj
05
03)
09)
/ /
10/30/86
10/30/86
09/30/85
12/30/86
12/30/86
01/07/87
08/30/90
05/11/90
10/09/90
10/28/65
01/13/90
-------
I.
Page No.
KEYWORD INDEX
NEUTRALIZATION SURFACE IMPOUNDMENTS, RETROFITTING) VARIANCES
PERSONAL PROTECTIVE GEAR DISPOSAL
SECONDARY LEAD SHELTER VARIANCES
SURFACE IMPOUNDMENT IIS) RETROFITTING WAIVER REQUEST (OCCIDENTAL CHEMICAL)
WASTES GENERATED IN MANUFACTURING PROCESS UNIT NOT SUBJECT TO LAND OlSPOSAL RESTRICTIONS UNTIL REMOVED
9404.1916
9441.1990
9444.19BS
9484-19871
9441.198?!
04/21/88
06/14/90
08/26/88
07/14/8/
06/19/8/
VMS HODEl
(See 6rounck«»t«r Monitoring, Otlllting)
VOLUNTARY CLEANUPS
XREF
/ /
(See Corrective Action)
VASTE ANALYSIS
XREF
/ /
(See alia Analytic Method, SV-846)
*PH TESTING OF SOLID/WATER MIXTURE
•WASTE ANALYSES FOR SIMPLE STORAGE AT INTERIM STATUS FACILITIES
ASTM STANOAROS IN THE RCRA PROGRAM
CLOSURE AND POST CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTS
GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS
LABORATORY EVALUATION PROGRAM
LIQUID VASTE, DEFINITION OF
METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEOURE FOR OILY VASTE
RCRA TESTING TECHNIQUES
SV-846 FOR REQUIRED VASTE ANALYSIS PURSUANT TO 264.13 AND 265.13
SV-846, THIRD EDITION. MOLDING TIMES FOR SEM1VOLATILES
TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZAROOUS VASTE IDENTIFICATION PROGRAM
TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF VASTE SAMPLE
USE OF THE METHOD OF STANDARD EDITIONS
VASTE ANALYSIS REQUIREMENTS IN INCOMING WASTE SHIPMENTS - LOR
€T HASTE DERIVED FUELS
J-
(See Hazardous Waste Fuels)
VASTE EXCHANGE PROGRAM
XREF
9443.1983(03
94/2.1983(01
9445.1987(05
9476.190/08
9451.1906 03
9472.1986	02
9432.198101
9443.1987	14
9445.1987(03
9472.1905(01
9472.1987(10
9443.1987(29
9443.1987(33
9443.1987(12)
9551.1987(10
XREF
/ /
02/28/83
07/30/83
12/21/8/
12/17/87
04/28/86
01/29/86
06/20/81
08/11/87
10/20/87
05/30/85
06/30/87
11/18/87
12/31/87
06/23/87
06/12/87
/ /
(See Haste Minimization)
VASTE MINIMIZATION
XREF
/ /
(See also Generators, HSVA, Manifest)
¦WASTE MINIMIZATION
•WASTE MINIMIZATION PROGRAM ACTIVITIES
EFFicTSMWITWAmLRQ3i!NTITYN8CNERATOR RULE ON VARIOUS ««"*ISr,«*5I!t?2!!A?S!!1!L',RACT,CES
MANIFEST CERTIFICATION SIGNATURE BLOCK FOR EMPLOYEES SIGNING ™ "NERATINQ COHPAN*
MODIFIED MANIFEST VASTE MINIMIZATION CERTIFICATION FOR SMALL QUANTITY GENERATORS
ON-SITE RECYCLING OF SPENT SOLVENTS BY GENERATORS
XREF
9451.1985(03
9431.1987
9431.1987i
9411.19861
9452.1985
94l2.1986i 02
9441.1986
21
/ /
10/30/85
06/30/87
06/30/87
03/17/86
10/17/85
10/20/86
03/13/86
-------
Page No.
04/06/92
KEYWORD index
SLUDGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WVTU EXEMPTION
SOURCE REDUCTION
SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
WASTE MINIMIZATION AND INCLUSION OF RECYCLING
WASTE MINIMIZATION CERTIFICATION REQUIREMENTS
WASTE MINIMIZATION: PERMIT CERTIFICATION AND JOINT PERMITTING
9432.1986(01
9454.1917(01
9523.00-12
9452.1986(03
9452.1966(01
9560.1905(01
01/06/86
07/21/87
03/30/87
02/06/86
04/28/86
09/11/85
WASTE Oil
(Sm Used 011} (Sm alto Hazardous Waste Identification)
WASTE PILES
XREF
/ /
(See land Disposal Facilities)
WASTE STREAM
XREF
/ /
•LAND DISPOSAL RESTRICTIONS - CORROSIVE WASTE
•TREATMENT CAPACITY
OERIVED FROM/MIXTURE RULE APPLICATION 10 REFINERY WASTEWATER TREATMENT SYSTEMS
IMMERSION PLATING WASTEWATERS-BRONZE PLATING
LOR DETERMINATION OF WASTE STREAM DILUTION
METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS
MIXTURES OF LISTED ANO CHARACTERISTIC WASTES
OIL FIELD OPERATIONS. EXEMPTIONS FOR CERTAIN
SMALL QUANTITY GENERATOR WASTE STREAMS - TANK RISK ANALYSIS
SOLVENT AND COMMERCIAL CHEMICAL PRODUCT WASTE STREAMS
9551.1987
9525.1986
9441.1987
9442.1988
9551.1990
9441.19871
9441.19871
9441.1989
9441.1986
9444.1989
19)
07)
70
05)
06)
46)
68)
27)
25)
03)
09/30/87
12/30/86
08/28/87
10/03/88
10/14/90
06/17/87
08/19/87
06/06/89
03/26/06
06/28/89
WASTE-AS-FUEl
(See Hazardous Waste Fuels)
WASTEWATER
o
(See also Clean Water Aet, Listed Hazardous Waste, Land Disposal Restrictions, Mlxure Rule)
•BOAT FOR WASTEWATER
•MIXTURE RULE - DISCHARGES TO WASTEWATER
ACLs PR0P0SE0 BY UNION CARBIDE CORP., INSTITUTE, WV, COMMENTS ON
ANTARCTICA WASTE DISPOSAL PRACTICES
CARBON REGENERATION FACILITY. MIXTURE OF SOLID AND HAZARDOUS WASTES (CALGON)
DISCARDED WASTEWATER AT A CORROSION CONTROL FACILITY
EXEMPTION FOR WASTEWATER DISCHARGES AND GENERATOR ACCUMULATION PROVISIONS
HAZARDOUS WASTEWATERS USED AS QUENCHWATER IN CEMENT PRODUCTION
LAND DISPOSAL OF SOLVENTS
REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENT
SAMPLING LOCATION IN A SEPARATOR - THICKENER TREATMENT TRAIN AND THE MIXTURE RULE
SLUDGE ORYER ADDEO TO WASTEWATER TREATMENT UNIT-EFFECT ON WVTU EXEMPTION
SOLVENT CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTURE
SOLVENT LISTINGS, SCOPE OF
SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER
TANK TREATMENT PROCESSES
WASTES COVERED UNDER THE D10XIN LISTING
XREF
XREF
9432.1906
9522.19871
9481.1987
9442.19891
9441.1986(33
9444.1991
9441.1987
9489.1991
9453.1987
9444.1987
9433.19861
9432.1986(01
9442.1987	06*
9444.1986 26
9441.1988	49
9483.1990 02
9444.19861 23
/ /
/ /
12/30/86
12/30/87
06/19/87
04/26/89
04/23/86
11/26/91
12/10/87
02/15/91
12/10/87
10/26/87
04/24/86
01/06/86
10/26/87
11/07/86
12/06/88
08/15/90
10/21/86
-------
Page No,
06/92
KEYWORO INDEX
WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT NATTER
WASTEWATERS EXCLUSION FROM THE DEFINITION OF F02I FOR PCP MANUFACTURE
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
NPDES FaeUttlM
•TRUCK TRANSPORT OF WASTEWATER FOR PURPOSES OF SECTION 2«l.J(a}(2)( W
LEAKS, SPILLS. AND ILLEGAL DISCHARGES OF LISTED WASTES TO SURFACE WAT:
PERMIT REQUIREMENTS FOR ZERO WASTEWATER TREATMENT SYSTEM
TC RULE HAZARDOUS WASTE DETERMINATION
MIXTURE RULE APPLIED TO
POTW
EFFECTS OF THE SMALL QUANTITY GENERATOR RULE ON VARIOUS GENERATOR WASTE MANAGEMENT PRACTICES
MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWER
MIXED RADIOACTIVE HOSPITAL WASTES AND THE OOMESTIC SEWAGE EXCLUSION
PROPER DISPOSAL OF OLD MEDICATIONS
TRUCK OR RAIL SHIPMENT OF HAZARDOUS WASTE TO A POTW
WASTES GENERATED FROM EXTRACTION PROCESS
SntBoe Sludae
OOMESTIC SEWAGE SLUDGE EXCLUSION
RESIDUALS GENERATED BY PROCESS FOR SEWAGE SLUDGE
Sludge
TREATMENT
MP I SEPARATOR WASTEWATER AND SLUDGE
'SLUDGES WHEN RECLAIMED, REGULATION OF
F019 LISTING AND THE CONVERSION COATING PROCESS
F0I9 LISTING APPLICABILITY TO WASTEWATER TREATMENT SLUDGES
INDUSTRIAL PLATING OPERATIONS, STATUS OF VARIOUS WASTES FROM
OILY WASTEWATER TREATMENT PONds. PERMITTING COVERAGE OF
REINTERPRETATION OF THE F006 LISTING
• SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLER
ZINC OXIDE DUST RECLAIMEO OR USED AS FERTILIZER
— Wastewater Treatment
'FILTER PRESS IN WASTEWATER TREATMENT UNIT, EXCLUSION FOR
(T	'MOBILE WASTEWATER TREATMENT UNITS
*	'TANK WASTEWATER TREATMENT UNIT DEFINITIONS
'WASTEWATER TREATMENT UNIT DEFINITION
'WASTEWATER TREATMENT UNIT/GENERATOR ACCUMULATION TANK
'ZERO DISCHARGE AT FACILITIES ANO SURFACE IMPOUNDMENTS. RCRA EXCLUSION. CWA APPLIES
DERIVED FROM/MIXTURE RULE APPLICATION TO REFINERY WASTEWATER TREATMENT SYSTEMS
F019 LISTING AND THE CONVERSION COATING PROCESS
F019 LISTING APPLICABILITY TO WASTEWATER TREATMENT SLUDGES
FILTER PRESS PROPOSED AS PART OF CORRECTIVE ACTION - NOT EXCLUDED FROM PERMITTING
LOR DETERMINATION OF WASTE STREAM DILUTION
MODIFICATIONS TO WASTEWATER TREATMENT SYSTEM UNDER EXCLUSION
OIL/WATER EMULSIONS GENERATED BY PETROLEUM REFINERY WW SYSTEMS-K049 WASTE
PERMIT REQUIREMENTS FOR ZERO WASTEWATER TREATMENT SYSTEM
PERMIT REQUIREMENTS RELATING TO ON-SITE TREATMENT ft WASTEWATER TREATMENT UNIT EXEMPTIONS
PERMIT-EXEMPT STATUS OF SLUOGE DRYERS ADDED TO WASTEWATER TREATMENT UNITS
PESTICIDE RINSEATE TREATMENT/RECYCLING SYSTEM
PETROLEUM REFINERY WASTES AND EXEMPTIONS FOR NWTUs
PETROLEUM REFINERY WW. MIXTURE AND DERIVED-FROM RULES
RDftD PERMIT FOR A SlUfiGE DRYING PROCESS IN A WASTE WATER SYSTEM
SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS
SLUOGE DEHYDRATION EQUIPMENT
9441.1986(52
9444.1987(39
9441.1986(20
9441.1991(13)
9441.1986(07)
9471.1989(01)
9441.1991(12)
9451.1986(01
9441.1986 73
9441.1966(94
9574.1990(01
9441.1986(88
9442.1986(07
9441.1990(02
9442.1988
9444.1984
9441.1986
9444.1987
9441.1989
9441.1988!
9502.1984
9444.1986
9523.00-12
9432.1986(07)
9441.1987(61)
06)
59
22
53
SO
01
19
9432.1984(04
9432.1987	05
9432.1988(03
9432.1988(05
9483.1988	15
9441.1984(14
9441.1987(70
9444.1987(22
9441.1989(53
9433.1987(10
9551.1990 06
9441.1991(01
9441.1984 35
9471.1989(01
9522.1988 04
9503.52-lA
9471,1988(04)
9483.1990(03)
9441.1985(29)
9S03.51-1A
9441.1585(08)
9527.1987(02)
07/02/86
09/02/87
04/07/86
07/01/91
01/23/86
03/20/89
07/31/91
03/17/86
09/25/86
12/19/86
11/28/90
11/30/86
07/02/86
02/12/90
02/10/88
04/30/84
06/30/86
06/24/87
10/30/89
12/07/88
12/07/84
09/25/86
03/30/87
02/11/86
08/12/87
05/30/84
06/30/87
03/30/88
10/30/88
07/30/88
05/30/84
08/28/87
06/24/87
10/30/89
06/12/87
10/14/90
01/03/91
12/07/84
03/20/89
11/02/88
01/02/86
10/27/88
09/20/90
08/23/85
12/24/85
02/22/85
08/03/87
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Page No.
04/06/92
KEYWORD INDEX
SLUDGE DEHYDRATION EQUIPMENT AS A WASTEWATER TREATMENT UNIT
SLUDGE ORVER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WWTU EXEMPTION
SLUDGE-DEHYDRATION EQUIPMENT THAT IS PART OF A WASTEWATER TREATMENT FACILITY
TANK RULES APPLIEO TO WWT UNITS AND DISTRIBUTION SYSTEMS
TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING. REGULATION OF
TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEAOING TO A WASTEWATER TREATMENT PLANT
WASTE ACID AS WASTEWATER CONDITIONER AND AS INGREDIENT IN FERTILIZER
WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATMENT SLUDGE
WASTEWATER TREATMENT ELEMENTARY NEUTRALIZATION UNITS EXEMPTION
WASTEWATER TREATMENT SLUDGE EXEMPTION FOR ANODIZING OF ALUMINUM
WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOL
WASTEWATER TREATMENT SYSTEM. SOLVENT RECOVERY STILL BOTTOMS IN
WASTEWATER TREATMENT UNIT EXEMPTION
WASTEWATER TREATMENT UNIT EXEMPTION/DEFINITION
WASTEWATER TREATMENT UNITS ARE NOT DESIGNATED FACILITIES AND MAY NOT RECEIVE OFF-SITE HAZARDOUS WASTES
9432.I987<
9432.1986
9522.1988
9483.19861
9441.19861
9441.19861
9441.19861
9444.19841
9471.19871
9441.1986
9444.19841
9441.19851
9431.19891
9432.1984
9452.19871
08/03/B7
01/06/86
03/07/88
11/28/86
02/25/86
08/19/86
10/20/86
07/25/84
12/21/87
04/09/86
04/26/84
12/17/85
09/26/89
12/24/84
02/24/87
WASTEWATER TREATMENT
(See Wastewater)
WASTEWATER TREATMENT SLUDGE
XREF
/ /
(See Listed Hazardous Waste)
WELL CONSTRUCTION
XREF
/ /
(See Groundwater Monitoring)
WITHDRAWALS
XREF
/ /
(See Permit Application)
WOOD TREATMENT
XREF
/ /
(See also Listed Hazardous Waste)
Creosote
CREOSOTE TREATED CROSS TIES. OISPOSAL OF, FIFRA INTERFACE
CREOSOTE TREATED CROSS-TIES OISPOSAL
K035 LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS
RAILROAD TIES AS HAZARDOUS WASTES UNDER THE MIXTURE RULE, SHALL QUANTITY 6ENERAT0R
WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM
WOOD TREATED WITH CREOSOTE, OISPOSAL OF
Wood Preserving
*RECLAIMtO SPENT WOOD PRESERVATIVE EXCLUSION IN 261.4(a)(9)
*W00D PRESERVING WASTES - ADMINISTRATIVE STAY
CCA TREATED WOOD WHEN DISPOSED
CLOSURE ISSUES RELATED TD WOOD PRESERVING PLANTS	m
DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOL
DRIPPAGE IN WOOD PRESERVING STORAGE YARDS
F027 LISTING-USEO AND UNUSED fORHULATIONS IN WOOD PRESERVING
XREF
9441.1985(28)
9441.1990(20)
9444.1987(52)
9441.1980(04)
9441.1986(28)
9441.1986(10)
9441.1991
9489.1991
9441.1991
9476.1984
9444.1985(
9489.1991
9444.1987j
19
03
11
04
02
(02
10
/ /
07/16/85
07/03/90
12/11/87
11/17/80
04/07/86
02/11/86
12/01/91
06/01/91
06/28/91
08/07/84
03/04/85
05/31/91
04/09/87
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V
P«ge No.
04/06/92
KEYWORD INDIA
K001-LISTED WASTES FROM WOOD PRESERVINS PROCESSES
PENTACHLOROPHENOL AS A MOD PRESERVATIVE
TREATMENT SURFACE IMPOUNDMENTS, REGULATION OPTIONS AVAILABLE TO WOO PRESERVERS
WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATHENT SLUDGE
WASTEWATER TREATMENT SLUOQES FRO* WOOD PRESERVINS PROCESSES USINS CREOSOTE AND/OR PENTACHLOROPHENOL
WOOO PRESERVINS AND SURFACE PROTECTION FACILITIES. CONTROLLING ENVIRONMENTAL RELEASES FROM
WOOD TREATEO WITH CREOSOTE. DISPOSAL OF
ZINC PLATINO
(Sit Electroplating)
at prtntar to Iptl
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Volume 2
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 2

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9431.1990(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NOV . 5 1990
NOTE TO: Sylvia Lovrance
THROUGH: Dev Barnes
FROM: Susan Absher
SUBJECT: Yakima Indian Nation Involvement in RCRA Program
Decisionmaking on Tribal and Ceded Lands
He recently received a memorandum from Region X concerning
an issue raised by an Indian Tribe during the public comment
period of a Washington State program revision decision. The
Yakima Indian Nation (YIN) raised the question of Federal and
State laws and regulations that allegedly affect YIN Treaty
rights under the Treaty of 1855. Under that Treaty the YIN ceded
land to the United States Government (land, which subsequently
became 25.4% of the State of Washington), and the U.S. Government
guaranteed the YIN certain rights (fishing, hunting, etc., at
"all usual and accustomed places"). The YIN have expressed
concern that current and future HWMFs may "affect the Yakima way
of life, its cultural resources, the freedom to practice religion
on tribal and ceded lands, or the promises guaranteed in the
Treaty of 1855" (emphasis added).
At this time the YIN has not asserted any legal claim but is
requesting the opportunity to be involved on a "government-to-
government" basis in RCRA program decisionmaking on tribal and
ceded lands. The Tribe also wishes to be assured that their
, -Treaty rights are not disregarded by agreements between EPA and
the State. Finally, the YIN believe that EPA and the State must
provide technical and financial assistance to the YIN to develop
the ability needed to protect their Treaty rights and resources.
The Washington revision program decision has become
effective. Region X -wrote the YIN agreeing to explore the
"ceded" land issue, and has sent information on the issue to OGC.
Region X ORC has the lead on researching the issue further. We
will track developments through the Region and OGC.
The Tribe* s claim of an interest in "ceded" land is
interesting. One of the fundamental cases of U.S. Indian law,
P. S. v. Winans. 198 U.S. 3?1 (1905), was brought by the U.S., in
behalf of the YIN, to ensure the Tribe's fishing rights under
that same Treatv, on "ceded," and now State/private land. In

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2
that decision "the Indians were given a right in the [ceded] land
- the right of crossing it to the river - the right to occupy it
to the extent and for the purpose mentioned [in the Treaty]." It
is unlikely that fishing and hunting rights can be broadened to
general environmental rights in the "ceded" lands, but it is
certainly possible that a court could so rule, especially in the
event a HWMF were to be proposed near one of the "usual and
accustomed places."
cc;. Jeff Denit
Matt Hale
Suzanne Rudzinski
Karen Morley
Judi Kane

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UNITED STATES IHVtlONMEHTAL PROTECTION AGEKCY 9431.1991(01)
WR 2 6 1991
MEMORANDUM
SUBJECT: Fate and Transport Model
FROM: David Bussard
Director
Characterization and Assessment Division (OS-330)
TO:	Waste Management Division Directors
Regions I-X
This memorandum concerns the possible use (or misuse) of a
subsurface fate and transport model (EPA's Composite Model for
Landfills, EPACML) which was developed by the Office of Solid
Waste (OSW) for the Toxicity Characteristic Final Rule (55 FR
11798, March 29, 1990).
The EPACML was developed for national regulatory purposes
and is implemented using the Monte Carlo procedures. The model
is not intended for site-specific use, since it is not designed
to simulate site heterogeneities and irregular site boundaries.
This is pointed out in the User's Manual for the model.
The OSW is now in the process of proposing to adopt the
EPACML for use in evaluating delisting petitions. In this use,
we plan to propose the continued implementation of the model on a
nationwide basis, although in a modified form. The final
implementation procedure will depend on the nature of comments we
receive on our forthcoming Federal Register Notice, which is
expected to be published later this year. This intended use of
the model has significantly increased interest in its use for
site-specific purposes. We understand that in some instances EPA
Regional staff have recommended using the model in connection
with Corrective Action at a particular site.
We would like to discourage these applications of the EPACML
and ask that you inform your staff working on RCHA as well as
Superfund sites appropriately. We would be happy to assist your
staff in locating a model which is isuitable for use on a site-
specific basis. Please contact Dr. Zubair Saleem of my staff at
FTS-382-4767 with any questions on EPACML or on suitable models
for site-specific applications.
cc: Jeffrey Denit
~
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9431.1991(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 9 1891
oeeici of
SOLID WASTE AIMO EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Application of TC Compliance Date Extension to Shell
We have carefully reviewed your March 19 memorandum and
attachments regarding Shell Oil Company's Wood River facility in
light of our recent action to extend the Toxicity Characteristic
compliance date for hydrocarbon recovery operations at petroleum
refineries. While we understand that someone may view the
operations at Wood River as somewhat similar to the operations
addressed in the proposed (and now final) action—see 56 FR
13406, April 2, 1991—the subject wastestream and waste
management unit are, in fact, significantly different and cannot
reasonably be interpreted to fall within the scope of the
extended compliance date.
First, in our discussions with the petroleum industry
regarding application of the TC rule to hydrocarbon recovery
operations with reinjection components, we were made aware that
treatment of the extracted petroleum-bearing groundwaters (e.g.,
removal of naturally occurring minerals) prior to reinjection can
' 'result in the production of additional wastestreams, some of
which exhibit the Toxicity Characteristic. Issues associated
with the management of these additional wastestreams were given
consideration, but these wastestreams were never considered to be
within the scope of the "groundwaters" for which the compliance
date was extended. More specifically, we concluded that these
treatment wastestreams could and should be managed under RCRA
interim status provisions. This is different in the case of
reinjection of extracted groundwater, given the statutory
requirements of RCRA Section 3020. Because of Section 3020 an
-------
as they are more appropriately defined as treatment sludges per
40 CFR 260.10.
As to the Wood River Solid Waste Disposal Basin (5WDB) as an
infiltration gallery, note that the final compliance date
extension applies only to injection wells. Infiltration
galleries are not included and have been provided with six months
to comply with Subtitle C requirements. However, this six-month
compliance date would not apply to the SWDB since the leaking of
a disposal impoundment, which is designed to contain materials,
is substantially different from the intended design and operation
of an infiltration gallery. Thus, the SWDB would not be
considered as an infiltration gallery for purposes of TC
compliance dates.
Should you have any further questions regarding the
background or scope of the TC compliance date extension for
certain hydrocarbon recovery operations, feel free to contact
Dave Topping of my staff at FTS 382-7737.
114
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9431.1991(03)
1
WASHINGTON, O.C. 20460
NAY1 IT? 1991
0**iC£ OP
SOUO **STE AMO IMiACiNC* WESSONS
Honorable John D. Dingell
Chairman
Subcommittee on Oversight and investigations
committee on Energy and Commerce
House of Representatives	- *
Washington, O.C. 20515 ; H~ •*
Dear Mr. Chairman:	"
ThaiUc you for your letter of February 12, 1991, requesting,
information about the progress of the Resource Conservation and *
Recovery "Act's (RCRA's) corrective action program, and the
Environmental Protection Agency's (EPA's) current approach and
future plans for managing this program. Z appreciate the
opportunity to respond to these important issues.
To provide the facility-specific information you have
requested, we have initiated a considerable effort vithin our
headquarters and regional offices. A substantial amount of
data will also need to be obtained from state agencies. Due
to the volume of this information and our desire to respond as
completely and as accurately as possible to your questions, ve
vera not able to fully respond to your letter by the March 29
date that you requested. As my staff indicated in a recent
telephone conversation with Deborah Jacobean, the Subcommittee
counsel, ve are in the process of collecting this information,
we will be able to give you a complete and detailed response in
June.
X would, like to take this opportunity, nevertheless, to
address • number of issues that you raised in your letter. These
include m'l long-term action plan and budgetary strategy for
implementing corrective actions at RCRA facilities, EPA's plans
for seeking statutory changes to RCRA in the area of corrective
action, EPA's timetable for publishing the final corrective
action rule, and EPA's plans and budget for meeting the 1992
deadline for issuing permits to storage and treatment facilities.
~
\li
-------
Long-Tsxm	for Corrective Actios
our recently published RCBA Implementation Study outlined
a long-term strategy for managing the corrective action program.
Over the past several months, we have been working to put the
components of this strategy into place through the following
initiatives.
Development ef a Consistent National System for Setting
Priorities
This new national system is already being implemented in
several SPA regions. It' uses standard decision criteria to
evaluate specific environmental data, and generates high-,
medium-, and low-priority rankings for facilities. By October
1991, we expect to have completed setting priorities for all
facilities that are currently in the "pipeline" (i.e., pursuing
corrective action under enforcement actions or permits). All
remaining facilities for which preliminary environmental
assessments have been completed will be ranked by April 1992. v>
Acceleration of the Environmental Priorities Initiative
The EPX is an integrated KCRA-superfund effort to identify
and evaluate sites that present the greatest risks to human
health and the environment. As noted in the RCRA implementation
study, this program has experienced initial start-up problems.
However, beginning in FY 1992, EPA will expand this effort to
greatly increase the number of facilities assessed, and to
broaden the scope of the assessments performed to generate
additional data for purposes of ranking. At this time, we are
developing detailed plans and schedules for each EPA region for
implementing the EPI in FI 1992 and beyond.
Development of a Strategy for Stabilizing RCRA Facilities
«e are currently developing a set of operating directives
and technical guidance documents to focus interim measures at
facilities to reduce existing exposures to contamination and to
prevent the contamination from spreading. Although fully
implementing this new program direction will be a longer-term
effort, v* expect that it vill enable the program to accelerate
the overall pace of cleanups, by initiating remedial activities
at a faster rata at a greater number of facilities. For FY 1992,
we expect to bs identifying potential candidates for interim
measures tad to expedite the collection of the data needed to
evaluate UFA facilities (those facilities at the UFA stage of the
corrective action process) for stabilization measures.
fi*
-------
3
P1	Oversight
In May 1991 we will b« issuing guidance for us« by the EPA
regions and the states to tailor their oversight approaches for
implementing corrective actions, as appropriate to site-specific
factors.
Budget Strategy for Corrective Action
EPA's proposed FY 1992 budget for RCMk corrective action and
the RCRA-superfund EPI effort is as follows:
EPA Regions:	169 full-time employees (PTEs)
$22.3 million (extramural fund*)
EPA Headquarters: 28.5 PTEs
$3 million
State Grants:	$14.2 million
EPI: .	16.6 PTEs
$18.3 million
There vas a relatively small decrease in regional PTEs in
FY 1992 from FY 1991 levels (about 1? PTEs). However, EPI
resources in FY 1992 were increased over FY 1991 EPI resource
levels by 4.9 PTEs and $S.S million. When FY 1992 EPI resources
are factored into the total Corrective Action Program resources
for FY 1992, there is a net loss to the Corrective Action Program
of 12.6 PTEs and a net gain of $5.4 million in extramural
resources. In addition to the above resources, several
corrective actions will take place under the Great Lakes
Initiative as well.
These resource levels reflect the high level, of importance
that EPA attaches to the Corrective Action Program. At the same
time, in managing the national hazardous waste program, we must
strike an appropriate resource balance between RCRA's mandates
for both cleanup and prevention. The FY 1992 RCRA Implementation
Plan, which should be released shortly, will describe in more
detail how SPA intends to rank the environmental priority of all
facilities in the MSRA universe and balance priorities between
corrective action and other program activities. We expect,
however, to reevaluate the resource needs for corrective action
over the next two to three years, as we gather more definitive
data on the number of facilities requiring cleanup, and the
severity of their environmental problems. At that time, SPA will
be better able to assess the effectiveness, and the resource
implications, of the corrective action management strategy
outlined above.
' |11
-------
4
The result# of the forthcoming Regulatory Impact Analysis
(RIA) for the corrective action rule will also be useful in
establishing the program's resource needs. The RIA will evaluate
the costs and human health and environmental benefits associated
with different regulatory options for implementing the corrective
action program. Among many other things, it will specifically
address how the timing of corrective action affects both the
costs and the benefits of this program.
The RCRA corrective action program is clearly in a
transition phase. In light of this, we agree that the "outyear
scenarios" that we provided to the Subcommittee in 1989 are no
longer accurate projections of our longer-term expectations for
implementing the program. Although we are unsure at this early
stage of implementation of precisely how adopting our a-trtte^y
will change these outyear scenarios, we can see that it will
alter the fundamental assumptions we used to develop those
earlier projections. Once we have completed the prioritization
effort and the other analyses now under way, we will provide you .
with our new assumptions and our updated multiyear projections. °
Potential 'Statutory Changes
At this time, EPA is examining a number of potential changes
to the statute, in the context of a possible reauthorization of
RCRA in the coming months* Relating to corrective action, we are
analyzing approaches to statutory and regulatory requirements for
managing remediation wastes. We are also considering options for
changing the existing procedural subtitle C permit requirements
as they apply to cleanup actions to accelerate and create more
incentives for private party cleanup actions.
Timetable for Publishing the Rule
As outlined in the FffltriX BwlStlg preamble to the proposed
, -"Subpart S" rule (published July 27, 1990), EPA has committed
itself to conducting a revised RZA for this rule. Before
finalizing the rule, we will publish the rssults of this major
new analysis for notice and comment. He vill provide you with a
detailed status report and description of this RIA effort in our
follow-up response to your letter. Zn short, however, we expect
to be able to publish the results of the new analysis no sooner
than June 1992* the final rule should be published within one
year thereafter, or by June 1993.
1992 Deadline for Issuing Permits
As of search 12, 1991, permitting decisions were made at over
1,000 treatment and storage facilities. Of these determinations,
more than 900 permits were issued, and «4 permits were denied,
lie have approximately 850 remaining RCRA Part B applications to
process for treatment and storage facilities, and just ever 1,700
-------
5
facilities are not pursuing RCSA permits (i.e., they did not file
Part B applications and/or are on track to close).
As you Know, the RCTA Implementation study noted that the
1992 deadline for issuing pernits to treatment and storage
facilities constrains EPA's efforts to focus the prograafs
resources on those facilities that pose the highest risks to
human health and the environment. We believe strongly that it is
EPA's responsibility to allocate the program's resources in such
a way as to maximize the environmental benefits to be gained.
Our draft FY 1992 RCRA program guidance establishes a priority
setting framework for the RCRA program, and ve expect to be
evaluating the environmental priority of all RCRA facilities#
beginning this year and ending in mid-FY 1992. Accordingly, we
plan to continue making permit determinations at treatment and
storage facilities to the extent that determinations at these
remaining facilities are a high environmental priority.
Although ve recognize the importance of substantial progress
in issuing permits to storage and treatment facilities, it is ou*
responsibility as managers of this program to balance that goal >v
against the many other environmental priorities that place
demands oil the program's capabilities. We vill rank corrective
action needs at these facilities using the national priority
ranking system discussed earlier.
Thank you for giving us the opportunity to respond to these
important issues. We look forward to sending you the remainder
of the information that you have requested in June. In the
meantime, please do not hesitate to contact me if you have any
questions.
Sincerely yours.
Don R. CIS?
Assistant Administrator

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9432.1992(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP 2 7 1991
OP* ICE OP
SOLID WASTE AND EMERGENCE "ESPOUSE
Robert M. Scarberry
Chemical Waste Management
1155 Connecticut Avenue
Suite 800
Washington, D.C. 20036
Dear Bob:
In your letter of July 9, 1991, you request clarification of
the RCRA definition of "designated facility" with respect to the
treatability study exclusion, which was published on July 19,
1988 (53 EE 27290). You also ask the Agency to reconsider
whether this exclusion is a HSWA requirement.
On January 23, 1990, EPA clarified the definition of
"designated facility" (see 55 ££ 2342}. This amendment to the
definition in §260.10 clarifies that EPA's regulations allow
waste shipments from a state where a waste is subject to the
hazardous waste regulations as a result of a listing
determination to a facility in a state where the waste is not yet
regulated as hazardous. In this situation, the designated
facility might not need to be permitted or under interim status,
provided that the receiving facility is allowed by the receiving
state to accept such waste.
In your letter, you describe a situation similar to the one
addressed in the January, 1990 clarification notice, regarding
, " the transportation and management of treatability study samples.
In your example, a treatability sample is transported from a
state which regulates the treatability sample as a hazardous
waste (because it does not have the exclusion), to a state that
has adopted the exclusion, and therefore does not regulate the
sample as a hazardous waste. You ask whether the hazardous wast*
manifest, which is required in the originating state, can spec;!,
a treatability study facility as the "designated facility" even
though it does not have a permit or interim status. Furthermore
the facilities which perform the treatability studies in some
cases do not have permits or interim status.
As an initial matter, you should be avare that the
interpretation of the definition of "designated facility" in an
authorized state is a matter of state law. An authorized state
may interpret the provisions of this regulation in a more
@ Pmm.
-------
If you have any further questions regarding this
clarification of the term "designated facility," please call
Wayne Roepe of ay staff at (202) 260-2245.
Sincerely,

r
Sylvia K. Lowrance
Director
Office of Solid Waste

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UNITED STATES EHVIRONMENTAL PROTECTION AGENCY
9433.1990(06)
Mr. George Kavris
Roy F. Weston, Inc.	my o 7 !930
44 Burlington Mall Road
Suite 604
Burlington, Massachusetts 01803
BE: Draft Sampling and Analysis Plan for New Hampshire Plating
Company, Merrimack, Hev Hampshire
Dear Mr. Kavris:
The purpose of this letter is to inform you that we have
completed our review of your draft sampling and analysis plan for
the New Hampshire Plating Company (NHPC), submitted to the Agency
on October 29, 1990. This letter also confirms our initial
response to your plan provided in a conference call on November
8, 1990. The proposed sampling and analysis plan will be used to
collect representative samples of both untreated and treated
soils/sludges. These materials are presently listed as SPA
Hazardous Waste No. F006. We note that these materials also may
be listed as EPA Hazardous Waste Nos. F007 - F012; however, due
to the limited information provided we were unable to make a
determination as to the exact classification of these materials.
We discuss below the results of our review.
Chemical Stabilisation Process
Your draft saapling and analysis plan indicates that between
1962 and 1985, NHPC used three unlined lagoons to dispose of
electroplating wastes consisting of various heavy metals,
' cyanide, acids, and chlorinated solvents. You also indicate that
EPA is currently remediating the site and chemically stabilizing
the contaminated soils and sludges removed from the site. First,
the contaminated soils are mixed with the sludges in a pugmill at
a ratio of 4:1 (soil:sludge). The mixture of soil/sludge then is
mixed with Type 1 Portland Cement (presumably in another pugmill)
at a ratio of 3:1 (soil/sludge mixture:Type 1 Portland Cement).
The chemically stabilized residue is transferred via a six-yard
dump truck to a lined storage cell. The sampling plan states
that between 24 to 38 loads are generated daily; therefore,
approximately 144 to 228 cubic yards of chemically stabilized
residue are generated daily.

-------
Your description of the chemical stabilization process is
not complete. A complete description should include infomation
regarding:
•	The maximum total volume of stabilized vaste you expect
to generate (an accurate measure of vaste volume is
critical to our evaluation);
•	Addition of other reagents and/or water, including
source of water (or does the process rely on the
moisture content of the soil/sludge mixture?);
•	Physical nature of chemically stabilized treatment
residue (solid, monolithic, friable, etc.,);
•	Length of time soil/sludge mixed and length of time
soil/sludge mixture mixed with Type I Portland Cement;
•	Size of pugmills used to mix soil/sludge and
soil/sludge mixture with Type I Portland Cement;
•	Procedure for measuring/metering quantities of soil,
sludges, and reagents to ensure proper mixture ratios;
•	Safeguards (if any) to prevent short-circuiting (e.g.,
inadequate mixing or insufficient quantity of
reagents);
•	Initiation and completion of chemical stabilization
process (i.e., start date, end date, elapsed time
required to treat all of the material).
•	Elapsed time required for reaction to occur, and
elapsed time required for material to fully cure;
•	Explanation for why treatment residue generated between
August 1, 1990 and September 12, 1990 were placed back
into the lagoon system;
•	Clarification of whether the treatment system was down
during the period of September 12 and September 17,
1990; and
•	Procedure for removing chemically stabilized treatment
residue from storage cell.
Sampling and Analysis
Sampling Performed To Date
Your draft sampling and analysis plan states that prior to
October 22, 1990, representative composite and grab samples of
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the chemically stabilized treatment residue were collected at
various frequencies. Initially, aliquota of treatment residue
were collected from each truck and composited every five
truckloads, resulting in the generation of one composite sample
representing 30 cubic yards of treatment residue. Individual
grab samples also were collected, one from each truckload. Zt is
unclear whether composite and grab samples were collected
concurrently or separately (i.e., collection of composite samples
and then at a later date, collection of grab samples). The draft
sampling and analysis plan states that between August 1, 1990 and
September 12, 1990, the treatment residue was analyzed for the
TCLP extraction concentrations of cadmium, chromium, lead,
nickel, and sine.
The draft sampling and analysis plan then states that
beginning on September 18, 1990 aliquots of treatment residue
were collected from each truckload and composited every ten
truckloads, resulting in the generation of one composite sample
representing 60 cubic yards. Individual grab samples also were
collected at a rate of one every five truckloads. Again, it is
unclear whether composite and grab samples were collected
concurrently or separately (i.e., collection of composite samples
and then at a later date, collection of grab samples). The draft
sampling and analysis plan states that starting October 4, 1990,
the list of analytes analyzed using the TCLP increased to nine
with the addition of arsenic, barium, mercury, and selenium. On
September 21, 1990, analyses were again modified to include TCLP
analyses for cyanide and volatile organics. (Due to the
chronological progression of your draft sampling and analysis
plan, ve question whether the date should be October 21, 1990.)
Lastly, samples of the treatment residue also were analyzed for
total, amenable, and reactive cyanide. Unfortunately, we do not
know how many samples were analyzed for TCLP concentrations or
total concentrations, nor do we know the size of each aliquot or
grab sample. We also note that TCLP concentrations of silver do
not appear to have been completed. Lastly, the draft sampling
and analysis plan does not identify the volatile organic
constituents tested for using the TCLP.
Sampling to be Implemented
The draft sampling and analysis plan states that a 16-ounce
aliquot of treatment residue will be collected from every
truckload and an 80-ounce composite sample will be generated. As
we discussed in our conference call, please confirm that the 80-
ounce sample will be taken from a composite sample of all
truckloads generated daily. The plan goes on to state that the
80-ounce composite sample will be divided into three samples: 1)
32-ounce sample for analysis by primary laboratory? 2) 32-ounce
sample for archiving; and 3) 16-ounce sample for QA/QC check by
secondary laboratory. A minimum of four samples will be analyzed
for:
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4-
TCLP for the TC metals, nickel, and zinc;
•	TCLP for the volatile organic compounds?
TCLP for amenable cyanide;
Characteristics of ignitability, corrosivity, and
reactivity?
•	Total metals and volatile organic compounds;
•	Cyanide (total, amenable, and reactive);
•	Reactive sulfide;
•	Total organic carbon (TOC); and
•	Oil and grease.
Although it is stated that a minimum of four samples vill be
analyzed, the draft sampling and analysis plan also states that
daily composite samples of the treatment residue vill be
collected and analyzed for the TCLP analyses for the TC metals,
nickel, zinc, and cyanide. Zn addition, it states that one
composite sample of treatment residue vill be analyzed for TCLP
analyses for the volatile organic constituents every five days,
or as deemed necessary folloving screening of soil and sludge
vith a photoionization detector (PID). As a result, ve are
unclear as to the total number of samples of the treatment
residue to be collected and analyzed.
As ve discussed in our recent conference call, ve believe
that the above-sampling and analysis procedures are inadequate.
Specifically, ve believe that the proposed list of analytes is
insufficient. Based on the information provided in your plan and
our telephone call, ve recommend that the folloving analyses
should be performed:
•	Total oil and grease content.
•	TCLP extractions for all of the TC metals, nickel, and
cyanide (using distilled vater in the cyanide
extraction) • Hovever, in the unlikely event that the
treatment residue exhibits a total oil and grease
content in excess of one percent, the TCLP must be
replaced vith the Oily Haste Extraction Procedure
(OWEP). See SW—846 method number 1330. Lastly, the
draft sampling and analysis plan does not specify if
the TCLP analyses vill be performed on the cured or
uncured CSEAFD. Zf your demonstration is based on
analyses of the fully-cured material, the exclusion (if
granted) vould only apply to the fully-cured material.
Zf you vish the demonstration to be for the uncured
material, the TCLP analyses must be performed on the
uncured material.
•	TCLP extractions for all of the 40 OR §261, Appendix
VZXZ constituents likely to be present in the vaste (ve
note that an analytical feasible subset, such as 40 CFR
$244, Appendix XX, may be used).
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•	Total concentrations of all the TC metals, nickel, and
all of the 40 CFR §261, Appendix VIII constituents
likely to be present in the waste (we note that an
analytical feasible subset, such as 40 CFR 1264,
Appendix XX, aay be used).
•	Total concentrations of cyanide and sulfide. Zf the
total concentration of cyanide exceeds 250 mg/kg,
analyses for reactive cyanide must be performed; and if
the total concentration of sulfide exceeds 500 ag/kg,
analyses for reactive sulfide nut be performed.
•	Multiple Extraction Procedure (KEP) concentrations of
all the TC toxic metals, nickel, and cyanide (using
distilled water in the cyanide extraction) on
representative samples. The KEP analyses should be
aodified by using the TCLP to generate the initial
extraction (see SW-846 Method 1320). However, in the
unlikely event that the treatment residue exhibits a
total oil and grease content in excess of one percent,
instead of using the TCLP, you must perform the initial
extraction using the Oily Waste Extraction Procedure
(OWEP). Furthermore, the saaples of chemically
stabilized treatment residue must be ground and passed
through a 100X mesh screen prior to the TCLP and MEP
analyses. Lastly, Zf you wish the demonstration to be
for the uncured material, the MEP analyses must be
performed on the uncured material.
•	Characteristics of ignitabillty, corrosivity, and
reactivity.
We note that analyses for TCLP and total concentrations of zinc
and total concentrations of TOC are not necessary.
You must perform all of the above analyses on representative
saaples of the stabilized waste. Based on the limited
information you provided to date, we suggest that you complete
the above analyses on a minimum of 8 representative composite
samples collected over the course of the stabilization process.
Zn addition, we recommend that you expand your routine analysis
of all daily coaposite samples to include tide following:
•	TOG? as noted above, if >1%, OWEP should be used to
measure leachable metals.
•	TCLP analyses for all TC toxic metals, nickel, and
cyanide (using deionized water for cyanide).
•	TCLP analyses for volatile organic compounds (VOCs)
likely to be in the waste.
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The above recommendations assume you vill be able to document
that the key analytes of concern are the metals, cyanide, and
selected organics (e.g., VOCs). Therefore, you must demonstrate
(through all available data on the site, the production processes
operating on the site, etc.) that the metals and selected VOCs
are the only constituents likely to be in the vaste. such
arguments would appear to be most persuasive for the absence of
certain classes of compounds (e.g., herbicides/pesticides,
dioxins, PCBs, etc.).
H»e draft sampling and analysis plan also states that
samples of the untreated soils, sludges, and soil/sludges vill be
collected using the above saapling procedure, and analyzed using
the same set of analyses and parameters. The plan states that
this information vill be used to assess the effectiveness of the
onsite treatment process. We agree that samples of the untreated
materials should be collected and analyzed to better characterize
the vaste feed. We, hovever, believe that it is more important
to fully characterize the treatment residue. We, therefore,
suggest that only four representative saaples of the soil/sludge
mixture be collected and that the analyses be limited to the
total concentrations of the TC metals, nickel, cyanide, and the
40 CTR §261, Appendix VIII constituents likely to be present in
the vaste. You may prefer to perform more extensive testing of
the untreated vastes to support treatability studies.
Ground-Water Monitoring Data
The draft sampling and analysis plan states that historical
analytical data including ground-vater data vill be used to
docuaent the absence of Appendix VIZI constituents. We do not
believe that ground-water monitoring data are sufficient to
docuaent vhich constituents vere not present in the vaste.
Specifically, ve are concerned that the veils may be improperly
. installed or insufficient in number, the list of analytes
' " monitored may be incomplete and the concentrations and
solubilities of the materials potentially in the waste vary
videly. Therefore, the mere absence of a specific constituent in
ground-vater is not sufficient basis to determine that it vas
never in the vaste. A more suitable procedure for excluding
potential analytes, is to reviev the list of chemicals, products
and Material Safety Data Sheets (MSDS) for all trade name
products used at the facility to determine if a specific chemical
vas or vas potentially present. As noted above, you also may
rule out the presence of specific classes of chemicals if these
chemicals vere not used or generated at the site. We do request
that any ground-vater monitoring data that may be collected from
veils installed to specifically monitor the storage cell be
submitted. Baued on our recent conference call, hovever, such
data apparently are not available.

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Conclusion
We not® that a complete review of your draft sampling arid
analysis plan vas difficult due to the limited nature of the
information presented. Nonetheless, ve believe that your draft
sampling end analysis plan, with the above modifications, is
adequate. We also believe that ve have addressed to the fullest
extent your draft sampling and analysis plan; therefore, ve are
closing your petition file (ID0828).
Zf you choose to submit a formal petition in the future,
your petition vill be assigned a new petition number and reviewed
in chronological order along with all new petitions. He remind
you that your formal petition (if submitted) must contain all of
the information discussed in the "Petitions to Delist Hazardous
Wastes - A Guidance Manual," U.S. EPA, Office of Solid Waste,
(EPA/530-SW-85-003), April 1985. Please forward any petition to
the following address:
Mr. James Kent
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, B.C. 20460
Mail Code: OS-333
Should you have any questions regarding today*s
correspondence, please call me at (202) 382-2224, or the
technical reviewer of your draft sampling and analysis plan,
Howard Finical of ICF Incorporated, at (703) 934-3656.
cc: Linda Murphy, Region Z
Andrew Kiniuks, legion I
Janis Tsang, Region Z
lob Searberry, EPA HQ
Narendra Chaudhari, EPA HQ
Jim Kent, EPA HQ
Howard Finkel, ZCF Incorporated
Delisting Section

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9433.1990(7)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DX. 20460
DEC 2 I 1990
O** ICE OF
SOUO WASTE AND EMERGENCY RESPONSE
Nr. James D. Phillips
Director of Engineering Development
National Aeronautics and Space Administration
John F. Kennedy Space Center
Kennedy Space Center, f% 32899
Dear Hr. Phillips:
We have completed our review of your delisting petition
(#0823) which requests the exclusion of nitrogen tetroxide (N204)
rinsate generated from draining and rinsing operations associated
with N,04 propellant use at the Kennedy Space Center facility
located on Merritt Island, Florida. This waste is currently
classified as EPA Hazardous Waste No. P078. Based on our
evaluation of the petition, we will recommend to the Assistant
Administrator for Solid Waste and Emergency Response that the
petition be denied.
Our decision to recommend denial of the petition is based on
the results of the corrosivity analyses for two of the four
samples collected on July 26, 1989. The pH of these two samples
was reported to be 2.0, which indicates that the petitioned waste
exhibits the characteristic of corrosivity. Under the Resource
Conservation and Recovery Act (RCRA), liquid wastes which exhibit
a pB of less than or equal to 2.0 or greater than or equal to
12.5 are considered to exhibit the characteristic of corrosivity.
See 40 CFR 5261.22. As stated*%in 40 CFR {260.22(e) (3), the
petitioner must demonstrate that the waste does not exhibit any
pt the characteristics defined in $$261.21 through 261.24, which
' include the characteristic of corrosivity.
Therefore, we conclude that the analytical data submitted as
part of your petition show that the waste exhibits the
characteristic of corrosivity. We believe that the waste should
be considered hazardous and subject to regulation under 40 CFR
Parts 260 through 268 and the permitting standards of 40 CFR Part
270. Accordingly, ve will recommend to the Assistant
Administrator that a notice proposing to deny your petition be
published in the Federal Register.
It is our practice to give petitioners the option of
withdrawing their petition to avoid a negative publication in the
Federal Register. If you prefer this option, you must send us a
letter withdrawing the petition and acknowledging that the wastes
are considered hazardous and will be managed as such. If you
\V\
Frmmi m AccycM
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send such a letter, it should be forwarded to this office within
two weeks of the date of receipt of today's correspondence. If
you choose not to withdraw the petition, we will recommend that a
proposed denial decision be published in the Federal Register.
Please forward any correspondence to the following address:
Mr. James Kent
U.S. Environmental Protection Agency
401 K St., S.N.
Washington, DC 20460
Mail Code OS-333
Please realize that you also have the option of resubmitting
a new petition, at a later date, if you can treat the waste such
that it no longer exhibits the characteristic of corrosivity.
Enclosure 1 to this letter outlines the deficiencies in the
information provided in your present petition that would need to
be addressed should you re-petition the Agency. We suggest that
you contact us if you do plan to submit a new petition so that we
can inform you of any revisions to the petition review process
that may be relevant to your petition effort.
If you have any questions regarding our findings, please
contact Narendra Chaudahari of my staff at (202) 382-4783.
Enclosure
cc: Doug McCurry, Region IV
James Scarbrough, Region IV
Bob Scarberry, EPA HQ
Robert Kayser, EPA HQ
Narendra Chaudahari, EPA HQ
Jim Kent, EPA HQ
Howard FinJcel, ICF Incorporated
Sincerely,
David Bussard, Director
Characterization and Assessment
Division

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ENCLOSURE 1
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
DELISTING PETITION # 0823:
LIST OF DEFICIENCIES IN THE PETITION
The following is a list of information that was either not
included or not sufficiently presented in the delisting petition
submitted in July, 1990.
(1)	General description and schematic of all cleaning, treating,
decontamination, maintenance, handling and all other
processes associated with the application of nitrogen
tetroxide (N204) (i.e., all procedures and activities prior
to, during, and following application of N204 propellant):
Documentation of the use and location of use of
sampling equipment (e.g., containers, hoses),
mobile equipment (e.g., tankers, drums,
cylinders), transfer equipment, drums and other
containers, storage and transfer systems,
propellant components and hoses, and any other
equipment used; and
•	Documentation of any hazardous constituents
associated with surfaces treated with N204 or with
equipment used in cleaning, treating,
decontaminating, and handling treated surfaces
that could potentially enter the rinsate waste
stream.
(2)	Specific description of the cleaning/passivation processes:
Explanation of the types of products/surfaces that
undergo each of the cleaning/passivation
processes;
•	Description and quantity of all substances and
materials used (provide Material Safety Data
Sheets for constituents considered hazardous by
the Occupational Health and Safety
Administration), including trichloroethylene
(listed in Appendix VIZI of 40 CFR $261 as
hazardous) and substances described/identified in
the petition as "caustic", "detergent", and
"deoxidate"; and
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2
•	Justification that undergoing the
cleaning/passivation processes precludes the
introduction of residual solvents or other
cleaning agents in the waste stream.
(3)	Specific description of all types of surfaces on which N»0.
is applied.
(4)	Specific description of surface and equipment
preparation/decontaaination processes following N204
application, including draining, rinsing with water,
decontamination, validation, certification, maintenance, and
cleaning.
•	Description of the location (s) at which the
petitioned waste rinsate is generated; and
•	Explanation of aethod(s) of draining waste
rinsates from eguipaent and surfaces and
subsequent handling of the petitioned waste prior
to drua storage.
(5)	Specific description of spillage collection system:
Explain type of system(s) (e.g., floor drainage);
•	Discussion of potential for substances other than
the petitioned waste to enter the system,
including a list of these substances and
quantities entering the waste streaa annually; and
•	Explanation of the way in which the spillage
collection system operates in conjunction with
cleaning/pass ivation, H204 application, and post-
application cleaning, decontamination, handling,
(6) Description of waste streaa generation and aanageaent:
Length of time that the petitioned waste has been
generated;
Explanation of the difference between drua
accumulation and "bulk* accumulation;
Explanation of the method and length and location
of bulk accumulation;
• Documentation of storage equipment used for drum
and bulk accumulation and method(s) of
transferring accumulated wastes to drum storage;

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3
•	Description of treatment method used on petitioned
waste generated in the past;
•	Explanation of means of on-site storage of the
entire volume of the petitioned waste that was
generated in the past (if the waste rinsate has
been stored in surface impoundments or any other
type of land-based unit, you are required to
submit ground-water monitoring data}t and
•	Specify which of the waste management options will
be used if the petitioned waste is delisted.
(?) Description of waste sampling procedures followed:
•	Description of strategy for sample collection
(i.e., frequency, duration, method of sampling,
number of drums sampled, location of waste
sampled);
•	Justification of sampling frequency given facility
use of N204 during launch schedules;
•	Justification of claim that rinsate generated from
water and residual N204 is uniform given that
different types of equipment are used to apply
H204 propellent at different locations in the
facility (i.e., prove that the type of equipment
used in N204 application and the location of use
do not cause the petitioned waste to vary
significantly);
•	Discussion of the potential for waste rinsates to
settle in temporary storage and final drum
storage; and
•	Documentation of chain-of-custody procedures.
(8) Description of waste testing procedures followed:
•	In the absence of adequate procedures to test for
the presence of HOj in the petitioned waste, the
petitioner must provide a convincing demonstration
to account for the complete conversion of N02 to
other compounds upon contact with water;
•	Justification that the petitioned waste does not
exhibit the characteristic of reactivity (pure
N2o4 is known to react with various organic
substances, solvent residues, chlorocarbons,
alcohols, and other chemicals, resulting in
spontaneous ignition). You should provide
|«|3
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4
evidence that the petitioned N204 rinsate is not
capable of reacting violently with any chemicals.
This argument can be based on the documented
absence of N204 and N02, as required above.
•	Justification that the petitioned vaste does not
exhibit the characteristic of ignitability (the
petitioner is required to show that the flash
point is not less than 60 degrees Celsius; in this
petition, it is stated that the testing laboratory
extinguished the flame at approximately 60 degrees
Celsius; the petitioner oust specify exactly when
the flaae was extinguished in order to determine
whether the testing method was in accordance with
test required as specified in 40 CFR $261.21); and
•	Provide testing date(s) for all samples collected
on October 10, 1989.
(9)	Description of quality assurance and control procedures
followed:
•	Collection and testing of field, trip, equipment,
and laboratory blanks to ensure that contaminants
were not introduced during sample collection and
transportation (the petition states that seals
were not used on the samples because of adhesive
problems).
(10)	Assuming you somehow treat the waste to ensure that the
waste does not exhibit the characteristic of corrosivity
(i.e., pH of 2.0 or less), you must analyze at least 4 more
representative samples for the total' concentrations of all
the TC metals, nickel, cyanide, sulfide, and any
constituents in 40 CFR §261 Appendix VIII or 40 CFR 1264
Appenidix IX likely to be present (see f2 above), and for
the characteristics of ignitability and corrosivity. you
must explicitly justify that the samples are fully
representative of anv variation in constituent
concentrations over time.
(11)	Description of the procedures used to collect and analyze
the newly collected samples. The petitioner is reminded
that the samples must be analyzed as soon as possible
following collection. Please provide resumes for any new
personnel involved in the collection or analysis of the
waste.

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9433,1991(01)
UN (TED STATES ENVIRONMENTAL PROTECTION AGENCY
Mr. Johnny S. Udo
Safety/Environmental Engineer
Fuji Photo Film, Inc.
P.O. Box 1306
Greenwood, South Carolina 29648
Dear Mr. Udo:
The purpose of this letter is to inform you that ve have
completed our review of Fuji Photo Film, Inc.'s (Fuji) petition
(#0835). The petition is for dried wastewater treatment sludge
filter cake resulting from the chemical conversion coating of
aluminum generated at your Greenwood, South Carolina facility.
As indicated in your petition, Fuji believes that this waste is
currently classified as EPA Hazardous Haste No. F019.
Fuji stated in its petition that the Greenwood, South
Carolina facility manufactures pre-sensitized plates for the
lithographic industry. The surface preparation operation
includes the following processes!
•	Etching Process - an aqueous etching solution of
sulfuric acid and aluminum sulfate is used to etch the
aluminum surface and to remove any rolling oil from the
aluminum surface;
Desmutino Process - an aqueous solution of sulfuric
acid and aluminum sulfate is used to remove surface
smut produced in the etching process;
•	Graining Process - nitric acid, aluminum nitrate, and
ammonium nitrate, and a system of ferrite and carbon
electrodes to electrochemically grain the aluminum
surface;
Anodizing Process - an aqueous solution of sulfuric
acid and aluminum sulfate, and a system of aluminum
electrodes to,electrochemically anodize the aluminum
surface; and,
•	Silicate Process - sodium silicate is used to form a
hydrophilic layer on the aluminum surface.
~
The spent aqueous solutions and other materials, along with rinse
waters and wastewater from three fume scrubbers (sulfuric acid,
nitric acid, and sodium hydroxide) generated from the above
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processes are neutralized on-site. The neutralized wastewaters
then are clarified, and dewatered using a filter press and a
sludge dryer. The resulting material is the subject of Fuji's
delisting petition. We note that wastes generated from the
subsequent surface coating operation (utilizing organic solvents)
do not enter the petitioned wastestream.
Wastewater treatment sludges generated from (1) sulfuric
acid anodizing of aluminum, and (2) chemical etching and milling
of aluminum are specifically exempt from the EPA Hazardous Waste
Mo. F006. Although wastewater treatment sludges generated from
the chemical conversion coating of aluminum are listed as EPA
Bazardous Waste Mo. F019, none of Fuji's processes (including its
silicate process) utilize any chromate compounds or involve an
oxide-conversion, phosphate-conversion, or chromate-conversion
coating process. Therefore, we are not convinced that Fuji's
surface preparation processes (including its silicate process)
fall within the scope of the chemical conversion coating
processes regulated by the EPA Hazardous Waste Mo. F019 listing
(see "Background Document, Resource Conservation and Recovery
Act, Subtitle C - Identification and Listing of Hazardous Waste,"
U.S. Environmental Protection Agency, Office of Solid Waste,
November 14, 1980). We suggest you contact South Carolina's
Bureau of Solid and Hazardous Waste Management to confirm whether
or not the waste you generate is Hazardous Waste No. F019.
Based on our review of Fuji's manufacturing processes, we do
not believe that the petitioned waste is a listed hazardous
waste, and therefore, have closed the petition file. However, we
note that in accordance with 40 CFR S262.ll, Fuji still is
required to determine whether this waste exhibits any of the
characteristics of a hazardous waste in 40 CFR §§ 261.21 to
261.24 fe.g.. ignitability, corrosivity, reactivity, or TC
toxicity)-
If you have any questions regarding the closing of your
' petition file, please call Karendra Chaudhari, of my staff at
(202) 382-4787.
Sincerely yours,
Robert Kayser, Chief
Delisting Section
cc: Doug McCurry, Region IV
James Scarbrough, Region IV
Harendra Chaudhari, EPA HQ
Jim Kent, EPA HQ
Howard Finkel, ICF Incorporated

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9433.1991(02)
Mr. Lloyd Williams
Plant Engineer	April 26, 1991
Davis Pipe said Metal Fabricators, Inc.
Birch Street
Blountville, Tennessee 37617
Dear Mr. Williams:
Z am writing in regards to your delisting petition (#0758),
which requests the exclusion of the liquid phase obtained from
the lime neutralization of spent pickle liquor and associated
rinse waters generated at Davis Pipe and Metal Fabricators,
Inc.'s (Davis Pipe) Blountville, Tennessee plant. This waste is
currently classified as EPA Hazardous Haste No. K062.
On February 26, 1991> I was contacted by Davis Pipe's
attorney, Ms. Gladys Smith of Caldwell, Heggie & Helton. Ms.
Smith requested that we postpone any decision regarding your
petition until after Davis Pipe had collected and analyzed weekly
samples generated over a six- to eight-month period. In light of
our concerns regarding the apparent variability in both the total
concentrations of chromium and nickel and the volume of waste
generated annually, we agree that it would be useful for Davis
Pipe to collect additional data. We also believe that
representative weekly samples collected over the course of six to
eight months (roughly 26 to 35 weekly samples) will allow us to
characterize completely any variations in total concentrations of
chromium and nickel. Therefore, we have decided to give Davis
Pipe an additional six months to fully respond to our previous
request for analytical data representative of the petitioned
waste.
During this six-month period, we expect Davis Pipe to
collect samples of the waste on an as-generated basis and to
^produce weekly composite samples representative of all the waste
generated during that particular week. Each weekly composite
sample should be analyzed for pH and the total concentrations of
all the Toxicity Characteristic (TC) metals, nickel, and cyanide.
Davis Pipe also should:
• Demonstrate that the waste does not contain any of the
TC organics by analyzing a minimum of four weekly
composite samples for the total concentrations of all
the TC organics. See 40 CFR §261.24 for a list of the
organic analytes. Note that delisting levels may be
somewhat lower than TC levels. Therefore, we require

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detection levels to be well below TC levels. (We
suggest that your laboratory reach the PQLs for a water
matrix as defined in SW-846.)
Record the volume of wastewater generated and update
(finalize) its estimate of the maximum annual
generation rate. Note that, if delisting is granted,
the waste volume excluded will be specified in the
regulatory language.
•	Provide a detailed description of the sampling strategy
and explain why you believe the collected samples
adequately capture the waste stream's variability.
•	Provide the professional qualifications fe.q.. a brief
resume) for all-new personnel (if any) involved in the
planning and execution of the sampling and analysis
plan.
•	Document the analytical methods and equipment used, the
sample collection and analyses dates, and the sample
weights.
•	Provide analysis with appropriate detection limits, and
include all of the quality control (QC) information
associated with the analytical procedures conducted.
This should include information on method blanks,
matrix spikes and matrix spike duplicates, and standard
additions curves. Information on appropriate QC
procedures can be found in Chapter One of SW-846 (third
edition). Quantification limits (PQLs) for an aqueous
matrix are given in the appropriate chapter for the
individual method.
•	Provide schematic diagrams documenting amy changes made
to the wastewater treatment system, treated wastewater
storage system, and waste management practices, and
fully discuss such changes.
In order for us to complete our evaluation of your petition
in a timely manner, you must fully respond to this request for
additional information within six months of the date of receipt
of today's correspondence. If we do not receive a complete
response from you within six months, in accordance with EPA
policy, we will dismiss your petition from the petition review
process (see 53 £B 6822, March 3, 1988). In that case, we will
notify you of dismissal by letter.
Please note that it is to your advantage to submit the
requested information before the six months expire, so that any
remaining deficiencies identified by the Agency subsequent to
your submittal can be remedied within the six month time frame.
\°&
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-3-
If you do not believe that you can fully respond within six
months, you may wish to withdraw your petition now and submit a
complete new petition later at your convenience. If you prefer
this option, you must send a letter to EPA withdrawing your
petition and indicating that the petitioned waste is considered
hazardous and will be managed as such. This letter should be
forwarded to:
Jim Kent
U.S. Environmental Protection Agency
Office of Solid Waste
Mail Code OS-333
401 M Street, S.W.
Washington, D.C. 20460
Should you have any questions regarding the information
requested in this correspondence, please contact either Narendra
Chaudhari, of my staff at (202) 382-4787, or Howard Finkel, of
ICF Incorporated, at (703) 934-3656.
Sincerely,
Robert Kayser, Chief
Delisting Section
ccs Doug MeCurry, Region IV
James Scarbrough, Region IV
Narendra Chaudhari, EPA HQ
Jim Kent, EPA HQ
Howard Finkel, ICF Incorporated
Gladys F. Smith, Caldwell, Heggie & Helton

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9433.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460

OP •'ICE OP
SOk.ro WASTE AND EMERCENCV RESPONSE
Mr. Ramon Marrero, P.E.
Environmental Engineer
Pfizer Pharmaceuticals, Inc.
P. O. Box 628
Barceloneta, PR 0061?
Dear Mr. Marrero:
This letter concerns delisting petition No. 0801 submitted
by Pfizer Pharmaceuticals, Inc. for the exclusion of ash
generated from the incineration of F002, F003, and F005 process
vastes at its Bareeloneta, Puerto Rico facility. Six months have
passed since our November 20, 1990 letter requesting additional
information was sent out to you, and we have not yet received the
information requested in that letter.
On May 7, 1991, we met with you and your contractor (IBM) to
discuss the deficiencies in your petition and the information
required for a complete petition. At this meeting you indicated
that, in the future, Pfizer plans to incinerate several new non-
liquid waste s-treams, as well as the liquid wastes currently
incinerated. Furthermore, you raised the prospect of upgrading
the incinerator in order to bum the new wastes. We discussed
several options for gathering sufficient data to support a
delisting. Moreover, you and your contractor suggested that you
needed to consider the options further before deciding whether to
pursue the existing petition, or withdraw and resubmit a new
petition in the future. As a result of this meeting, as well as
several follow-up telephone conversations with ESM and other
, -Pfizer representatives, we expected Pfizer to either withdraw its
petition, or attempt to provide sufficient information to support
the existing petition. However, we have received neither a
withdrawal, nor any further information.
As indicated in our November 20 letter, the Agency published
in the Federal Register its policy to dismiss petitions that are
either seriously deficient upon receipt or still incomplete six
months after an Agency request for additional information <53 £B
6822» March 3, 1988). This policy was developed to facilitate
processing of complete petitions by avoiding burdensome,
iterative requests for needed information. In accordance with
this policy, I am writing to inform you that we have dismissed
^ PritmdonfltcyciKiPat
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your petition from the delisting petition review process since
you have not responded to our information request within the
specified six months. The effect of this dismissal is to close
your petition file (No. 0801). Please note that your petitioned
waste is considered hazardous and must be still managed as such.
If you choose to submit a new petition in the future, you
should provide the information outlined in our November 20, 1990
information request letter. Any new petition would be assigned a
new petition number and reviewed in chronological order along
with all new petitions. Please forward any new submittal to the
following address:
Mr. Jim Kent
D. S. Environmental Protection Agency
Office of Solid Waste (Mail Code OS-333)
401 M Street, S.W.
Washington, D.C. 20460
Zf you have further questions regarding the dismissal of
your petition or require any information on hazardous waste
delisting, please feel free to contact Chichang Chen of my staff
at (202)382-7392.
cc: Ed Abrams, EPA HQ
Bob Kayser, EPA HQ
Jim Kent, EPA HQ
John Gorman, EPA Region ZZ
Andy Bellina, EPA Region ZZ
Henry Huppert, SAZC
Sarah Bennett, SAZC
Basilis Stephanatos, ERH
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Volume 3
Inserts
Please Replace the
Attached Memo With
the Current
9441.1985(31) Memo in
Volume 3
B-o*
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i
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
OCT 3 BB5
OMICt or
SOCIO WASTE ANO EMERGENCY RESPONSE
Mr. Carl J. Schafer, Jr.
Director
Envi.ronmen.tal Policy
Acquisition and Logistics
Office of the Assistant Secretary of Defense
washim	)301
) 3 01
Dear Mr. J&
In your letter of July 25, 1985, you requested EPA concurrence
on the proposed DoD policy regarding the applicability of the RCRA
hazardous waste regulations to the demilitarization of military
munitions. These are munitions which have not yet been used and
which now may be recycled or disposed. Your request raises two
>ues: 1.) are such military munitions subject to RCRA prior to
iilitarization and 2.) can DoD directives be applied in lieu of
RCRA requirements for treatment, storage, and disposal of hazardous
waste?
Military Munitions Subject to RCRA
RCRA Section 6001 requires federal facilities to comply with
all Federal, State, and local laws pertaining to the management of
hazardous waste. RCRA hazardous waste regulations apply from the
time and at the point that the material (e.g., military munitions)
becomes a hazardous waste. The identification of munitions subject
to RCRA must be based on the definition of solid and hazardous
waste as presented in 40 CFR Part 261.
Under 40 CFR $261.33, unused commercial chemical products
become hazardous wastes only when discarded or intended for
discard. Recycling (i.e., use, reuse, or reclamation) is ordi-
narily not considered to be a form of discard. Similarly, unused
munitions ordinarily would not be considered to be wastes unless
and until there is an intent to dispose or destroy them, and they
would not be wastes when recycled in lieu of disposal* We thus
agree that the mere assignment of munitions to the Special Defense
Property Disposal Account does not automatically subject munitions
to RCRA. It is not until DoD decides to handle the material in a
iner which classifies it as a hazardous waste that its storage
J transportation must be in accordance with RCRA rules.
ao3
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-2-
You should be aware, however, that burning of these munitions
in military deactivation furnaces is considered to be incineration
because the main purpose of the activity is waste treatment. Like-
wise, storage of these wastes prior to incineration would also be
considered management of a hazardous waste.
The DoD strategy for identifying those munitions subject to
RCRA appears to be in accordance with the RCRA regulations with
the exception of the exclusion of hazardous waste storage. Your
letter states that military munitions are never waste until
demilitarization occurs. We interpret "demilitarization," as
used in the DoD policy, to encompass all activities regulated
under the RCRA rules except storage. Once there is an intention
to dispose or destroy munitions, their storage as well as trans-
portation would be regulated since they are hazardous waste.
Therefore, the storage and transportation of military munitions
that are hazardous waste are subject to RCRA prior to demilitari-
zation.
RCRA Applicability to DoD
Your letter suggests that because DoD directives provide
adequate protection of human health and the environment and
¦conform" to RCRA requirements, that DoD facilities may comply
with DoD directives in lieu of the RCRA requirements. Our initial
review of your directives indicates that in many respects, the DoD
directives adequately address the corresponding RCRA requirements.
However, we have also identified several deficiencies. For example,
RCRA Subpart I 5264.175 requires a containment system for container
storage, whereas your directives do not. Under RCRA Subpart G
5264.113, a closure plan is required for all hazardous waste facil-
ities ''whether or not the facility plans to close. Your directives
inaccurately state that this requirement does not apply.
Enclosed is a checklist which identifies all of the RCRA
regulations promulgated prior to the Hazardous and Solid Waste
Amendments of 1984 (HSWA or the "Amendments"). This checklist is
used by the States during the State authorization review process to
determine the equivalency of State standards to RCRA requirements.
We believe the checklist will be useful to you, as a first step,
to identify major omissions in the DoD directives when compared to
EPA's "base" (pre-HSWA) program. Unlike State programs, however,
the DoD directives must do more than achieve an equivalent level
of environmental protection to EPA's program. DoD facilities must
m^t EPA's standards promulgated under RCRA, and thus the DoD
* ctives would need to be revised accordingly. We would be
j to help you determine whether specific parts of RCRA apply to
DoD (e.g., closure requirements).

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We are currently revising the checklist to reflect the
Amendments and we should be able to provide a copy of the draft
revised checklist in approximately one month. The Amendments will
primarily require additions to the checklist; however, a few of
:he current provisions of the checklist may also need to be revised
slightly. Please contact Char Miller (382-2220) of the State
Programs Branch, Office of Solid Haste, with regard to the use of
ihe checklist and its revisions.
We are confident that the final DOD directives will facilitate
the permitting of DOD facilities and should reduce the need for
authorized States to impose requirements other than those prescribed
in your current directives.
uack W. McGraw
Deputy Assista
Sincerely yours,
Deputy Assistant Administrator
Enclosure
~
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Volume 4
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 4
90^
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9441.1990(28)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DX. 20460
OCT I 8 ff?&
MEMORANDUM
OPflCE Of
SOlID waste ano EME rcenc response
SUBJECT; Status of Used Refrigerants tinder 40 CFR 261.2
FROM:
Michael Petruska, Acting Chief (OS-332)
Waste Characterization Branch
TO
Docket for F-90-CFIF-FFFFF
This memorandum documents EPA's position on the status of used
refrigerants under 40 CFR 261.2. Several parties have informally
petitioned EPA for a determination on whether used refrigerants can
be classified as commercial chemical products, rather than as spent
materials; if so classified, the used refrigerants would not be
"solid wastes" under 40 CFR 261.2, when reclaimed.
There are two scenarios that are at issue when a refrigeration
equipment servicer decides to remove used refrigerants from
refrigeration equipment. In the first scenario, the equipment
servicer collects the used refrigerant and then elects to reuse the
refrigerant directly (i.e., without any filtration or other
processing) as a refrigerant. (Hie equipment servicer could elect to
reuse the refrigerant either with or without conducting analyses or
tests - any such analyses may be recommended by the equipment
manufacturer, or possibly required under future Clean Air Act
regulations, but are not relevant to determining whether the used
refrigerant is a solid waste under RCRA.) This type of reuse is
similar to reuse of a solvent that has been used once, but can still
be used for its solvent properties. See the January 4, 1985 Federal
Register. 50 £g 624. In this situation, the equipment servicer is
not managing a waste, but is merely continuing to use a commercial
'chemical product.
In the second scenario, the equipment servicer collects the used
refrigerant for reclamation prior to reuse. Such reclamation could
range from simple filtration to reinsertion into a chlorofluorocarbon
manufacturing unit. The used refrigerants meet the definition of a
"spent material" in 40 CFR 261.1(c)(1), and are solid wastes when
reclaimed, according to 40 CFR 261.2. See 54 £B 31336, July 28,
1989, for an explanation of why used refrigerants are classified as
"spent materials" rather than "commercial chemical products."
A more detailed analysis of specific points raised by the
Alliance for Responsible CFC Policy is attached.
Attachment
Primed m RtcycUd ft
ao*?
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Attachment
Definition of Solid Waste Arguments
Made by the Alliance for Responsible CFC Policy
Point #1:
The Alliance states that "in many cases removed refrigerant may
simply be re-inserted in refrigeration and air conditioning equipment
after testing, without any processing."
Under the current regulations, used refrigerant that is re-
inserted into equipment for further use is not a solid waste
(and thus, is not a hazardous waste). Some, but not most, CFC's
would fall into this category.
Point #2:
The Alliance states that "in some cases removed refrigerant must
be processed — for example, to remove contamination — before re-
inserting in refrigeration and air conditioning equipment." The
Alliance argues that the removed refrigerant is not a "spent
material" but rather is a commercial chemical product, and thus is
not a solid waste when reclaimed.
Under the current regulations, a "spent material" is any
material that has been used and as a result of contamination can
no longer serve the purpose for which it was produced without
processing. Spent materials are solid wastes when reclaimed.
He stated clearly in a 1989 Federal Register notice clarifying
the applicability of RCRA to used refrigerants that used
refrigerants that are reclaimed are spent materials and not
"commercial chemical products."
The Alliance argues that the refrigerant has not been "used" the
way we define the term in the regulations, because it has not
been "employed in a particular function or application as an
effective substitute for a commercial product" but rather, is
the commercial product. When we said "used" in the definition
of spent material, we meant the ordinary, plain language
definition of "used." However, because CFC recycling is
analogous to very common hazardous waste recycling operations
(i.e., solvents, used oils, batteries), the interpretation
requested by the Alliance would have far-reaching implications.
1
*
act
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Point #3:
The Alliance points out that, if classified as "by-products,"
the used refrigerants would not be solid wastes when reclaimed.
However, in their analysis of the definition of by-product, they
conclude that the term does not apply to used refrigerants.
Point #4:
Finally, the Alliance argues that a variance from the definition
of solid waste should be granted if EPA decides not to suspend the TC
rules and continues to consider the used refrigerant as a solid
waste. They propose a variance under Section 260.31(b).
There are two problems with this approach:
•	These variances are case-by-case determinations for the
Regional Administrators to decide, rather than national policy
decisions for entire wastestreams.
•	The variance under Section 260.31(b) is for materials that are
reclaimed and then reused as feedstock within the original
primary production process where they were generated, if the
reclamation is an essential part of the production process. The
vast majority of used refrigerants would not fall in this
category. (Any operations that do fall into this category are
of course eligible for the variance.)
2
~
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f	9441.1990(29)
L/{
$ £% \
| WHM 1	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DX. 20460
OFFICE Of
SOLIO WASTE AND EMERGSNCV RESPONSE
KEHPRAFPVM
SUBJECT: Implementation Issues Arising from the Toxicity
Characteristic (TC)
FROH: Don R. Clay
Assistant Administrator
TO:	Henry F. Habicht II
Deputy Administrator
The purpose of this memorandum is to summarize five
issues/problems associated with implementation of the TC. A
brief summary of each of the issues/problems follows, along with
a general indication of the time frame in which we expect to
present a recommended solution or options to you for your
consideration.
1.	Reinjection of contaminated (i.e., TC-hazardous) ground
water in association with petroleum product recovery and
remediation programs would be prohibited under the TC, thus
slowing or curtailing these activities. An interim final
rule has been published extending the TC compliance date to
January 25, 1991 for these activities. A proposal for a 2-
year extension, to allow time for further study, is being
finalized for the Administrator's signature. This proposal
will be forwarded to you within two weeks.
2.	Certain CFCs contaminated with residual carbon tetrachloride
and/or chloroform would be brought under RCRA. This will
negatively impact ongoing efforts by OAS to implement
voluntary recycling programs. OSW is finalizing an interim
final rule that would suspend the TC compliance date for
these CFCs in anticipation of regulations OAR will be
required to promulgate in response to expected CAA
amendments. This rule will be combined with the above
proposal and will be forwarded to you within two weeks.
3.	Large volumes of fluff generated by scrap metal processing
(primarily automobiles and appliances} could be TC-hazardous
and thus subject to RCRA. Regulation under Subtitle C may
be impractical and would involve significant economic
impacts. OSW is evaluating options. At present, I
anticipate a briefing for you in mid to late November to go
over the options.
PfwtMdi in Mtcyciidt Pitptf
-------
New York lias petitioned EPA to exclude from the TC
contaminated media from above ground oil cleanups conducted
under state order/oversight. OSW has developed some options
which we plan to send to the Regions for review. A follow-
up teleconference is also planned. After receiving and
considering their positions, I anticipate a briefing for you
to review the options and the Regions' views. This should
occur by the end of November.
As a result of EPA's definition of the scope of the oil
exploration and production (E & P) exemption, off-site crude
oil reclaimers fall outside of the exemption and, as a
result of the TC, will likely be subject to RCRA Subtitle C.
Essentially the same operations at the well head are exempt.
Some reclaimers have shut down and insist that many more
will. Regulation under TC may discourage reclamation and
waste minimization. OSW has developed some options and is
collecting data. I anticipate a briefing for you on the
options before the end of November.

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9441.1990(30)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OCT 3 0 090
OPUCE Of
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Regulatory
Director (8HWM
Oil Filters
FROM:
Sylvia Lowrarice,
Office of Solid"
Robert L. Duprej/, Director (8HWM-RI)
Hazardous Hasle Management Division
EPA Region VIII
Thank you for your memorandum of August 30, 1990, requesting a
regulatory interpretation of the status of used oil filters under the
new Toxicity Characteristic (TC). In your memorandum, you inquired
about used oil filters that are crushed in vehicle maintenance shops,
where a certain portion of the residual used oil in the filter is
^parated from the filter. The answers to the specific questions you
ced are listed below.
1.	The Toxicity Characteristic Leaching Procedure (TCLP) is
performed on used oil filters by crushing, cutting or grinding the
waste (filter plus contents) until the pieces are smaller than 1
centimeter in their narrowest dimension (and thus are capable of
passing through a 9.5 mm standard sieve). See Step No. 7.3 of the
TCLP. The surface area criterion referred to in Step 7.3 does not
apply to used oil filters. (Note: If the generator recycles both the
used oil and metal, you do not need to test because recycling of both
type> of materials is exempted from hazardous waste regulation as
discussed below.)
2.	and 3. Assuming a used oil filter exhibits the TC, you had
inquired whether the act of crushing filters is regulated treatment
or exempt recycling. Generally, the types of used oil filter
crushers you described would not be regulated if the used oil was
being recycled (see 40 CFR 261.6(a)(2)(iii) and (a)(3)(iii)). That
is, since the purpose of the crushing is to remove the used oil for
recycling, we view the crushing to fall within the used oil recycling
exemption. The crushing may be performed on- or off-site, for profit
or not. The determining factor is whether the used oil will be
recycled. The filter may be shipped off-site for crushing under the
used oil exemption, providing the oil is collected for recycling.
AM m kttfcbd Paper

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2
4. Generally, automotive oil filters are not considered to be
containers because they are designed to filter particulates from oil
that circulates through them, not devices for the storage of oil. As
a result, a filter could not be an "empty container" under 40 CFR
261.7. However, as described next, a drained or crushed filter is
considered scrap metal, and scrap metal is exempt from regulation
when recycled.
Under the definition of "solid waste," EPA has determined that
"recycled hazardous scrap metal is a solid waste when disposed of or
recycled" (see 50 £E 624, January 4, 1985). However, pursuant to
section 261.6(a)(3)(iv), hazardous scrap metal is exempted from
Subtitle c regulation when recycled. The scrap metal recycling
exemption in 40 CF1 261.6(a) (3) (iv) is applicable to used oil filters
(scrap metal) that are going to be recycled. However, an undrained
or uncrushed oil filter would contain too much oil to qualify for the
scrap metal exemption. The January 4, 1985 preamble provided
examples of items qualifying for the exemption, such as bars,
turnings, rods, sheets, wire (i.e., scrap metal that is going to be
recycled to recover their metal content) and examples that do not
qualify, including metal-containing waste with a significant liquid
component, such as spent batteries.
To increase the probability that the used oil filter (hazardous
scrap metal) will qualify for the scrap metal recycling exemption,
vhe generator or recycling facility should drain (gravity) the filter
.or an amount of time sufficient to ensure that all free-flowing oil
is removed. The amount of drain time will vary based on a number of
variables, including the size of the filter and temperature (both
ambient and that of the filter). Alternately, the generator or
recycling facility could crush the oil filter using the most
appropriate crushing method that will force excess residual oil from
the filter, tie will be examining this issue further, but we
currently have no information indicating that substantial amounts of
oil will remain in the filter after either sufficient draining or
adequate crushing. As a best operating practice, the Agency
recommends that the generator or recycling facility both drain and
crush used oil filters to be certain that the used oil filters would
qualify for the hazardous scrap metal recycling exemption.
If the crushed or drained filter will be recycled, it is
unnecessary to determine whether it exhibits the TC because the scrap
metal exemption is applicable. It would also be unnecessary to
manifest these used oil filters if they will be recycled. However,
if the filter will be disposed of, the generator must determine if it
is hazardous under the TC. If the filter is hazardous waste, the
Part 262 and 268 regulations apply to the generator, and Parts 264
and 265 apply to the treatment, storage and disposal facilities.
Non-hazardous waste filters may be disposed in a Subtitle D facility.
20
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3
Finally, in the sales brochures you sent, there was mention of
an open container used to accumulate the used oil after the filter
was crushed. (Currently, used oil accumulation by generators is not
regulated if the used oil is recycled, but EPA did propose that such
containers be Kept closed. See 50 EE 49252, November 29, 1985.)
Storage or accumulation of characteristically hazardous used oil is
regulated if the used oil is to be disposed of; in that case, the
containers must be closed except when adding or removing the used oil
(per §265.173(a)).
Please contact Daryl Moore at (202) 475-8551 if you have any
additional questions on the applicability of the Federal hazardous
waste regulations with respect to used oil filters.
cc: Waste Management Division Directors, Regions I - VII and IX - X
Jeff Denit
RCRA/Superfund Hotline
Regional TC Contacts

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RCRA/SUPERFDND HOTLINE MONTHLY SUMMARY
OCTOBER 1990
9441.1990(31)
Regulatory Status of Petroleum Contaminated Media and Debris Under
the Toxicity Characteristic UST Temporary Deferral
The owner/operator of a petroleum underground storage tank (UST) is
conducting a corrective action pursuant to Subpart F of 40 CFR Part 180.
During corrective action, sludges are removed from the inside of die
tank. These sludges exhibit the toxicity characteristic (TP for benzene.
Pursuant to 40 QFR Section 261.4 (b) (10) ".4pktro!eum-contaminated
media and debris that fail the test for the toxicity characteristic of
Section 261.24 and are subject to the corrective action regulations under
Part 280 of this chapter..." are excluded from the definition of
hazardous waste. The preamble to the Mardi 29,1990. Federal Register
does not explicitly define petroleum contaminated "media" and
"debris." (55 FR 11836). Would the deferral apply to those sludges that
are removed from the tank, or is the deferral intended only for
environmental media such as soil and groundwater?
~
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RCRA/SUPERFDMD HOTLIKE MONTHLY SUMMARY
OCTOBER 1990
2. Regulatory Status of Petroleum Contaminated Media and Debris Under
the Toxicltv Characteristic UST Temporary Deferral (Conf d)
In the March 29 preamble, the Agency stated that "further
evaluation of the impacts of applying the TC to soils and ground
water contaminated by petroleum from USTs and subject.to the
Subtitle I program is necessary in order to determine whether an
exemption for such materials is warranted—" (55 FR 11836) The
deferral only applies to contaminated ground water, soil and debris,
but not to wastes such as sludges generated in a raw material storage
tank. Section 261.4(a) states "(a) hazardous waste which is generated
in a product or raw material storage tank„..is not subject to
regulation under Parts 262 through 265,268,270,271 and 124 of this
chapter or to the notification requirements of Section 3010 of RCRA,
until it exits the unit in which it was generated^-" Therefore,
sludges removed from Underground Storage Tanks during
corrective actions pursuant to Part 280 Subpart F do not meet the
criteria of "media and debris" and, therefore, the deferral from TC
regulation does not apply.
NOTE: The June 29, 1990, Federal Register contains a clarification of
the deferral which states," (t)his exclusion applies only to
petroleum contaminated media and debris which exhibit the
TC for any one or more of the newly identified organic
constituents, and which are subject to corrective action under
Part 280." (55 FR. 26986) Therefore, those constituents
previously regulated under the IP Toxicity rule (D004-D017)
and now regulated under the TC are not eligible for the TC
underground storage tank deferral even if they meet the
criteria of media and debris. A generator must still determine
if the media and debris is a characteristic hazardous waste for
the TC constituents D004-D017.
Source:	Steven Cochran, OSW (202)382-4769
Research: Mic LeBel, GRC

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9441.1990(32)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Z<£ Hqc
OFFICE OF
SOUD WASTE AND EMERGENCY RESPONSE
Ms. Kathleen Ream
American Chemical Society
1155 Sixteenth Street, N.W.
Washington, D.C. 20036
Dear Kathy:
Thank you for your letter of November 5, 1990, requesting
that the Environmental Protection Agency (EPA) give special
consideration to the impacts of the Resource Conservation and
Recovery Act's (RCRA's) regulations on laboratories. I sun
pleased to be able to provide some insights on your very
thoughtful comments.
Some of the concerns identified in your White Paper appear
to relate to the Department of Transportation's (DOT'S)
regulations that govern the transport of hazardous materials.
Thus, you may wish to contact DOT directly on those issues. A
contact there is George Cushmae at (202) 366-4488.
With respect to the RCRA regulatory issues, as you have
pointed out, some of the concerns your White Paper identifies as
problems do not require regulatory changes, and may result from
an incorrect reading of the regulations. For example, the
question of when a chemical becomes a waste is not addressed
' directly in the regulations; EPA views commercial chemical
products as non-wastes until a decision is made to discard them.
Surplus chemicals that are intact and unused are classified as
commercial chemical products. In contrast to the statement made
on page 2 of the White Paper, 40 CFR Section 261.1(c)(8) does not -
require that at least 75 percent of commercial chemical products
be recycled or transferred for recycling in a calendar year.
Under Section 261.2(c)(4), commercial chemical products that are
accumulated speculatively are not solid wastes, and thus are not
subject to the RCRA regulations. Your proposed solution,
"Guidelines for Chemical Exchange," is consistent with EPA's
reading of the applicability of RCRA Subtitle C regulations for
reagent chemicals and solvents in their original condition and
original containers.

Fraud mR*cyd*df*P"
-------
Thank you once again for the useful information you
provided. If you need further assistance, please contact
Becky Cuthbertson of ay staff at (202) 475-9715.
Sincerely yours,
Don R. Clay
Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9441.1990(33)
NOV so fa®
Mr. William A. Anderson, IX
Bracevell and Patterson
2000 K Street, Northwest
Washington, D.C. 20006-1809
Dear Mr. Anderson:
This is in response to your letter of November 5, 1990
concerning the applicability of the Agency's used oil definition
to your client's open-gear lubricant, "Gearite." This lubricant
is described as a petroleum-based, semi-solid material which
becomes liquefied when heated, and is sprayed onto the bull gears
of cement kilns for lubrication. The spent Gearite is collected
in drip pans at the bottom of the enclosed gears and is
eventually piped back into the original product drums, where it
solidifies upon cooling. The Gearite is TC hazardous but can be
reused as a fuel in cement kilns.
You contend that Gearite fits the definition of "oil" and
not "grease* because it lacks the saponification agent necessary
to classify it as a grease (as described in the Agency's
Development Document for Effluent Limitation Guidelines). you
also referred to the Agency's November 29, 1985 definition.of
used oil, which included spent "gear oils." Although EPA has not
yet finalized the used oil definition proposed on November 29,
1985, the Agency agrees with your interpretation that spent
Gearite should be classified as a used oil.
«r
As you indicated, used oils that exhibit the characteristics
of hazardous waste are either exempt when recycled or subject to
special used oil standards under 40 CFR 266 Subpart E when burned
for energy recovery in industrial furnaces and boilers per 40 CFR
261.6(a)(3)(iii) and (a)(2)(iii). State regulations for used
oil, however, may be more stringent than the Federal standards
and should be consulted.

-------
Should you have any further questions on used oil, please
feel free to contact Ms. Denise Wright of my staff at
(202) 245-3519.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste
2
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RCRA/SUPERFOm HOTLINE HOHTHLY SUMMARY 9441.1990(34,
NOVEMBER 1990
l- Mixm gx^rion
A generator meets the mixture rule exclusion of 40 CFE Section 2£13(a)(2XivXA), by
proving that the concentrations of trichloroethylene In his waste stream before it
enters the hsadwcrks of his wastewater treatment ladlity is below one part per
million. This wss^eroter treatment Polity produces a sludge which exhibits a
hazardous da— "—c. Does the mixture rule exclusion also apply- to the sludge
produced in the generator's wastewater treatment ladlity? Or is this sludge a newly-
generated hazardous waste subject to full RCRA regulation?
Aajudge generated from a wastewater mixture feat meets all of the criteria
v- : speckled in Section 2613(aX2)(fo) would be exempted from the hazardous
waste listing because the original wastewater mixture became exempt at the
headworks of the WWTF. The exemption prevents the mixture and deri ved-
from rules from operating for certain listed wastes. (They can only apply
when the original material is a hazardous waste.) In addition, the mixture
rule exemption would not apply if fee wastewater met another listing
Tlie sludge, moreove, might be a hazardous waste for other reasons. For
examsleffee exemption criteria in Section 2613(a) <2) Chr) are carefully
limited. They do not apply to any waste t^od^atorfo^w^te
consequentiy,asthequestionalxe«iyfta«rthesliidgewould
be a hazardous waste if it Med any of the characteristic tests.
Source: RonJosephson,05W	(202)4754715
Research: Kenneth Sandler, GRC

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9441.1990(35)
$ A \

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC 2 ! 1990
0**IC£ OF
SOLIO WASTE *NO EMERGENCY RESPONSE
Earl F. Bouse
Vice President
Minerals and Environmental Services
Pacific Basin Resources
3480 Buskirk Ave., Suite 205
Pleasant Hill, California 94523
Bear Mr. Bouse:
This responds to your letter dated September 13,1990 to Mr. Bob Holloway
concerning the regulatoiy status of using K048-K052 filter cake as an ingredient in the
manufacture of cement Specifically, you requested a determination regarding whether
such use will be allowed under the final rule for burning hazardous wastes in boilers and
industrial furnaces (BIF rule), which has not yet been promulgated.
I am unable to address whether the process described in your letter will be
allowed under a rulemaking that we are still in the process of evaluating and finalizing.
The proposal published in the October 26, 1989 FEDERAL REGISTER (54 FR 43718) is
the best guide available for you to use in making your assessment of what our final rale
may require until die final rale is promulgated. We currently expect the final rule to be
promulgated by January 1991.
As current Federal regulations provide at 40 CFR 2612(e)(2)(i)» the filter cake
used to produce cement would meet the definition of a solid waste (and thus be
^classified as hazardous waste K048-K052) because it is being used as an ingredient (Le.,
a substitute for raw materials) to produce a product that is used in a manner
constituting disposal (Le„ placement on the land). However, this does not answer the
question of whether such use of the filter cake is legitimate recycling. This regulatory
determination is made on a site-specific basis by the regulating agency (Le., the State
regulatoiy agency or EPA Regional Office) in the State in which the activity occurs.
Additional, more specific information to supplement the information in your letter wOl
be required to make such a determination.
Some of the criteria used in evaluating such situations at the Federal level may
be of assistance to you in preparing your request for a regulatory determination should
you continue to seek such a determination. To evaluate whether a hazardous waste is
being legitimately recycled as a substitute for, or being used as, au ingredient in a
manufacturing process, a comparison must be made between the constituents contained
in the hazardous waste and the constituents in the analogous raw material Because the

Primudm kscydadfapi
-------
2
hazardous wastes and raw materials may change at each different site, this analysis is
required on a site-specific basis.
There are several factors to consider in determining whether a hazardous waste is
being used as a legitimate substitute in a manufacturing process. It is not enough to say
that because a hazardous waste can be used as an ingredient and still result in a
marketable product such usage is legitimate recycling (rather, this is a demonstration
that the hazardous waste-derived product itself may be an effective substitute for a
nonwaste-derived product, not a demonstration that the hazardous waste is a legitimate
ingredient). Nor is it enough to say that such use of the hazardous waste does not have
an adverse impact on the environment (rather, this may be a demonstration of a good
hazardous waste treatment technology, not a demonstration of "legitimate" exempt
recycling). One key consideration is the extent to which a hazardous waste contains
hazardous constituents not otherwise found in analogous raw materials (e.g^ volatile
oipnics), or contains hazardous constituents at levels significantly higher than those
found in the raw materials (e.g, lead and chromium), hi such cases, the hazardous
waste is generally determined to not be used as a legitimate substitute for raw materials
in a manufacturing process, but rafter is to be treated and/or disposed of by
incoiporation into a product If such a determination is made, the process may require
a hazardous waste treatment permit (However, you may make a demonstration that the
hazardous constituents are useful to the manufacturing process such that the hazardous
waste actually functions better than the raw material it is replacing.) Again, this is a
site-specific determination that is more appropriately made by the regulating agency.
If you have further questions regarding the factors considered in evaluating
whether the use of the hazardous wastes is legitimate recycling under Federal
reflations, you may contact Mitch KidweQ, of my staff, at (202) 475-8551. If you have
questions regarding the regulatory status of the use of K048-KQ52 as an ingredient in the
manufacture of cement, (or other site-specific regulatory determinations) you should
contact the appropriate regulatory agency (Le., authorized State agency or EPA Regional
Office) in which the facility is located. For your information and reference, I am
, -enclosing a list of EPA Regional offices and telephone numbers.
Sincerely,
David Bussard
Director
Characterization and
Assessment Division
Enclosure
cc Bob Holloway

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WASTE MAHAGEMEHT DIVISION DIRECTORS
EPA REGIONAL OFFICES
Region it
Merrill S. Hohman, Director
Waste Management Division
USEPA Region Z
John F. Kennedy Bldg.
Boston, MA 02203
Region 6:
Allyn M. Davis, Director
Hazardous Waste Management
Division, USEPA Region VI
First interstate Bank Tower
1445 Ross Avenue
Dallas, TX 7S202-2733
Region 2s
Conrad Simon, Director
Air t Waste Management -Division
USEPA Region II
26 Federal Plaza
Nev York, New.York 10278
Region 7:
David Wagoner, Director
Waste Management Division
USEPA Region VII
726 Minnesota Ave.
Kansas City, KS 66101
Region 3:
tephen R. Wassersug, Director
azardous Waste Management Division
USEPA Region III
841 Chestnut Street
Philadelphia, PA 19107
Region 8:
Robert L. Duprey, Director
Hazardous Waste Management
Division
USEPA Region VIII
1 Denver Place, Suite 500
999 18th Street
Denver, CO 80202
Region 4:
Patrick M. Totoin, Director
Waste Management Division
USEPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Region 9:
Rich Vaille, P.E.
Assistant Director
Toxics & Management
Division
USEPA Region IX
215 Fremont Street
San Francisco, CA 94105
Region 5:
William E. Muno
Associate Division Director
Waste Management Division
USEPA Region V (5HS-13)
30 S. Dearborn Street
.Aicago, 111 60604
Region 10:
Charles E. Findley
Director
Waste Management Division
USEPA Region X
1200 6th Avenue
Seattle, m 98101

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UNITED STATES ENVIROHMENTAL PROTECTION AGENCY
9441.1991(01)
JAN 3 1991
Mr. Lynn Cooper
Michelin Tire Corporation
P.O. Box 2846
Greenville, South Carolina 29602-2846
Dear Mr. Cooper:
This letter is in response to your November 7, 1990 letter
regarding modifications to Michelin1s Sandy Springs wastewater
treatment system. According to your letter and our December 11,
1990 telephone conversation, you have already changed to a new
belt filter press which produces a higher percent solids and
processes higher rate of sludge production. In addition,
according to your letter and our telephone conversation, you will
soon institute other modifications to the current wastewater
treatment system to address greater capacity needs resulting from
ongoing production expansion at Sandy Springs. Specifically, the
planned modifications are:
o The existing turbocirculators are to be replaced by a
lamella clarifier and sand filter.
o The existing Diapac sanitary package plant will be
replaced by a pair of sequencing batch reactors (SSR)
for sanitary treatment and organics removal.
o The wastewater will be routed to the new SBR for
biological treatment prior to discharge.
When the original exclusion for the waste generated at
Michelin's Sandy Springs facility was granted by the Agency, it
was conditioned by stating that "the exclusion remains in effect
unless the waste varies from that originally described in the
petition (e.g., the waste is altered as a result of changes in
the manufacturing or treatment process)." Although you submitted
results of TCLP testing on the sludge conducted by KMT Laboratory
to show that the original exclusion should still apply to the
waste that is currently being generated, these data are not
sufficient for our evaluation. As discussed further below, we
cannot fully assess the impact of the modifications on the
exclusion of your wastewater treatment sludge without knowing
more details about these modifications and their impact on the
comoosition of tae filter press sludge.

-------
We are concerned about the modification you have already
implemented (the new belt filter press) and the others you are
planning to implement. The increase in the amount of wastewater
treated, improved metals removal, higher degree of biological
treatment, and higher percent of solids in sludge may change the
chemical form/composition of the waste. In order to make certain
that the original exclusion still applies to the waste that is
currently being generated at Michelin's Sandy Springs facility,
we request that you submit the information specified below. If
you decide to not submit the information requested below, you
must notify the Agency within two weeks of the receipt of this
letter.
A.	Process Information
We need more detailed information on the modifications
planned. Therefore, you must submit the following:
o A description of the Lamella clarifier, the sand filter, the
biological treatment (sequencing batch reactors), the belt
filter press (including the percent solids), and any other
process information that you believe might be pertinent.
The drawings referenced on page two of your letter (62005P01
and 62006P05) might provide some of this information but
they were not attached to the letter we received. A
description and revised drawing similar to those submitted
in the letter to Myles Horse on January 20, 1986 would be
appropriate (see Enclosure I).
o An estimate of the new average and maximum sludge generation
rates on a monthly and annual basis.
o If there are any other reasons, besides those already stated
in your November 7, 1990 letter, which make your planned
modifications necessary (e.g., NPDES permit requirements).
B.	Sampling and Analysis Information
' o An explicit statement explaining why the three samples
collected in June and July 1990 (and future samples
undertaken in response to today's letter) are representative
of any process or waste variability.
o Total constituent analysis results for at least four
representative samples collected over a one-month period for
the eight metals listed in 40 CFR §261.24 and nickel. He
request that you quantify total levels to support your claim
that the system modifications are minor and "will not change
the characteristics of the sludge".
o Total sulfide and total cyanide analyses for four
representative samples. You must also submit results from
2

-------
reactive sulfide and reactive cyanide testing if total
sulfide and total cyanide levels exceed 500 and 250 parts
per million (ppm), respectively. Leachability analysis for
cyanide, using the TCLP, is also required if total cyanide
levels are greater than 100 ppm. When testing for leachable
cyanide, deionized water should be used in place of the acid
leaching medium.
Total oil and grease analysis for four representative
samples. We are concerned that your waste may have an oil
and grease content above one percent because in your
original petition the filter press sludge had a maximum oil
and grease content of five percent. If the total oil and
grease content is greater than one percent, you must use the
oily Waste Extraction Procedure (OW1P, SW-846 Method 1330)
to analyze at least four representative samples for
leachable concentrations in lieu of the TCLP. When using
the OWEP, please substitute the TCLP for the extraction
procedure in Step 7.9 of the OWEP. Leachable nickel and
cyanide concentrations must also be quantified.
If total levels of oil and grease are less than one percent,
you must submit results of TCLP analyses for at least four
representative samples for the eight metals listed in 40 CFR
5261.24, nickel, and cyanide.
Total constituent and TCLP analysis data for all hazardous
organic constituents listed on 40 CFR Part 261, Appendix
VIII (including acetone, ethyl benzene, isophorone, 4-
methyl-2-pentanone, styrene, and xylene) which are likely to
be present in your waste. (Michelin initially identified
182 Appendix VIII hazardous constituents which could be
expected to be present or released during the facility's
operation, and provided total constituent analyses for these
Appendix VIII hazardous constituents.) We are especially
concerned about toluene, ethyl benzene, styrene, malaeic
anhydride, and thiuram (these were detected in samples
submitted in support of your original petition).
We recognize that the Appendix VIII list presents a number
of analytical problems for sane constituents. For
analytical testing purposes, you must analyze the samples
for those compounds which can be accurately quantified using
appropriate SW-846 methods. It should be noted that SW-846
analytical test methods exist for all constituents listed in
40 CFR Part 264, Appendix IX. For any hazardous
constituents for which analytical results are not provided,
a rationale must be provided explaining why the constituent
is not expected to be present.
3
-------
In lieu of analytical testing, you may present mass balance
arguments that demonstrate that constituents cannot be
present in the waste at levels of concern.
You should submit the above requested process information
and any other information you believe to be pertinent to our
office as soon as possible. Please submit the sampling and
analysis information, along with the appropriate QA/QC
information, to our office within to days after the planned
modifications have been implemented. Following implementation of
the planned modifications, we suggest that you treat the waste as
hazardous until we have made a decision regarding the status of
your exclusion. This should be viewed as a "precautionary measure
in case our evaluation of your new waste data results in a
decision that your original exclusion is no longer applicable to
the waste being generated.
If Michel in decides not to implement any of the proposed
changes to the process (or if these process changes are delayed),
you must still provide further sampling/analysis data to
demonstrate that the change in filter press has not adversely
affected the waste. Therefore, we may accept the TCLP data you
have already submitted (provided they are from representative
samples with total oil and grease levels of less than one
percent). However, even in this case, you need to supplement the
existing data to include total constituent and TCLP analyses such
that all of the above requested analyses are provided for at
least four representative samples.
If you have any questions about this correspondence, please
feel free to contact Narendra Chaudhari of my staff at (202) 382-
4770.
Sincerely,
Robert Kayser, Chief
Delisting Section
Enclosure
cc: Narendra Chaudhari, EPA HQ
Jim Kent, EPA HQ
Doug McCurry, EPA Region IV
James Scarbrough, EPA legion 2V
Sarah Bennett, SAZC
4
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-------
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-------
UNHID STATES ENVIRONMENTAL PROTECTION AGENCY 9441 *1991 (025
FfB I 2 1991
ttEMOFflNQPM
SUBJECT: Applicability of the TC to Mixed Waste
FROM: Sylvia K. Lowrance, Director
Office of Solid Waste
TO:	Regional Waste Management Division Directors
Regions I - X
Purpose
The Environmental Protection Agency (EPA) promulgated the
Toxicity Characteristic (TC) rule on March 29, 1990 (55 FR
11798). That rule will bring a large number of waste generators,
including mixed waste handlers, under Subtitle C regulation for
the first time. However, the preamble to the TC rule does not "
discuss mixed waste. Regional staff have indicated that there is
some confusion regarding the applicability of the TC to this
category of waste, and have requested a clarification statement
on the issue. The purpose of this memorandum is to clarify the
applicability of the TC to mixed waste in authorized and
unauthorized States, as well as the Federal regulatory status of
those wastes.
Background
Mixed wastes are defined as wastes which contain both a
radioactive component subject to the Atomic Energy Act ((AEA)
i.e., source, special nuclear, or by-product material) and a
hazardous component subject to the Resource Conservation and
Recovery Act (RCRA). Up until 1986, the applicability of RCRA to
mixed waste was unclear, in part because of uncertainty about the
effect of the exclusion in RCRA Section 1004(27) (the definition
of solid waste) for AEA-regulated materials, and because of
disagreements about the scope of the definition of "by-product
material."
-------
2 -
To clarify the applicability of RCRA to nixed waste, EPA
issued a clarification notice on July 3, 1986 (SI FR 24504). in
that notice, the Agency announced that the hazardous component of
mixed waste is subject to RCRA requirements and that the
radioactive portion of the vaste (source, special nuclear, and
by-product material) is subject to AEA. EPA also required States
which had obtained RCRA-base program authorization prior to the
July 3 notice to revise their programs to clarify the regulatory
status of mixed waste (i.e., to include the hazardous component
of mixed waste in their program definition of solid waste), and
to apply for EPA authorization of their revised program. The
Department of Energy (DOE) clarified the term "by-product
material" in an interpretative rule on May l, 1987 (52 FR 15937).
That rule stipulated that, in mixed wastes, only the actual
radionuclides are considered by-product material. DQE's
interpretative rule is consistent with EPA's earlier
clarification notice.
EPA's July 3, 1986 clarification notice described three
general regulatory scenarios for mixed waste based on the
authorization status of a State's hazardous waste program:
o In a State which is not authorized for the RCRA-base
program, mixed waste is subject to the Federal hazardous
waste management retirements, and EPA administers and
enforces the requirements for mixed waste until the State
receives mixed waste authorization.
o In a State with both RCRA-base program and mixed waste
authorization, mixed waste is subject to the hazardous
waste management requirements, and the State administers
and enforces its requirements for mixed waste (of course,
if the waste were newly listed or identified pursuant to
a Hazardous and Solid Waste Amendments (HSWA) provision,
and the State was not yet authorized for that listing or
characteristic, EPA would administer the requirements).
o In a State which is authorized for the RCRA-base program,
but not specifically authorized for mixed waste, this
waste is not subject to the Federal hazardous waste
requirements until the State revises its program and
receives authorization specifically for mixed waste. (A
State may, however, regulate mixed waste under State law
under any of these three scenarios).
The chart in Attachment 1 shows the regulatory scenarios for
mixed waste in authorized and unauthorized States. The section
below describes the applicability of the TC to mixed waste in
these regulatory scenarios.
-------
Applicability of the TC to Hixed Waste
The status of mixed waste that fails the toxicity
characteristic (i.e., the Toxicity Characteristic Leaching
Procedure) follows the scheme described above. Specifically, the
TC rule brings some additional mixed waste streams into the RCRA
Subtitle C system in States that are not authorized for the RCR&-
base program, and in States that are authorized for mixed wastes.
However, in States that are authorized only for the RCRA-base
program, mixed wastes that fail the TC will not be considered
hazardous under Federal regulations. Once those States become
authorized for mixed waste, then this waste will be subject to
the TC.
The Agency's position on the applicability of the TC to
mixed waste is consistent with an earlier determination on a
related issue regarding the land disposal restrictions program.
EPA determined that HSWA's land disposal restriction provisions
in Section 3004(d)-(h) do not apply to mixed wastes in States
with only RCRA-base program authorization (see Attachment 2,
Hixed Waste Position Paper, Issue 3). The basis for that
determination is that the land disposal restrictions apply to
"solid waste" which is hazardous. As mentioned above, mixed
waste is not a solid waste in a State with only RCRA-base program
authorization. Therefore, the land disposal restrictions do not
apply to mixed waste in a RCRA-base authorized State until the
State revises its program (i.e., defines this material as a solid
waste) and receives EPA authorization for mixed waste.
Similarly, the TC, which was also promulgated pursuant to
HSWA, does not apply to mixed waste in a State with RCRA-base
program authorization until the State revises its program and
receives authorization for mixed waste. This is because the TC
only applies to material included in the definition of "solid
"waste," which is part of the authorized RCRA-base program. As
noted above, the definition of "solid waste," upon which HSWA
requirements depend, is determined solely by State law in
authorized States. Therefore, in scenarios 1 and 2 described in
the background section above, new HSWA requirements such as the
land disposal restrictions and the TC would apply to mixed
wastes. In scenario 3, however, new HSWA requirements like the
TC would not apply to mixed wastes until the State becomes
authorized for these wastes.
Current Regulatory Status of Mixed Waste
Currently, mixed waste is regulated as a Subtitle C solid
and hazardous waste in 33 States and territories (24 States and
territories have received authorization for mixed waste, 9 States
and territories are unauthorized even for a RCRA-base program) .
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- 4 -
In these 33 States, mixed waste is subject to the TC (scenarios 1
and 2 above), and EPA administers and enforces the program for
toxicity characteristic mixed waste until the state receives
authorization for the TC program. In the remaining States and
territories, which have only RCBA-base program authorization
(scenario 3), mixed waste is not now a solid waste according to
the Federal hazardous waste management requirements, and this
waste is not subject to the TC. A list of States and territories
with mixed waste authorization as of January 31, 1991, is
provided in Attachment 3.
The effective date of the TC rule was September 25, 1990 for
large quantity generators and treatment, storage, and disposal
facilities and March 29, 1991 for small quantity generators. The
key compliance dates for the TC rule, including requirements for
Section 3010 notification, submission of permit applications
(Part A's and B*s), and permit modifications are summarized in
Attachment 4. These compliance dates apply to facilities which
handle toxicity characteristic mixed waste in States which have
mixed waste authorization and in States which have not yet
received RCRA-base program authorization.
In States which have only RCRA-base program authorization,
mixed waste is not subject to the Federal hazardous waste
regulations until the State becomes authorized for mixed waste.
Once a RCRA-base authorized State becomes authorized for mixed
waste, facilities in that State will be required to submit a
Part A permit application, amended Part A permit application, or
permit modification for TC wastes as well as other hazardous
waste no later than six months after the effective date of the
State's mixed waste authorization. In this type of situation, a
Section 3010 notice would not be required for newly regulated
generators and treatment, storage, and disposal facilities.
However, newly regulated generators and treatment, storage, and
, " disposal facilities are required to obtain an EPA identification
number, following the authorized State*s procedures.
If you have additional questions regarding this matter,
please feel free to contact Jared Flood of my staff at
FTS: 475-7066. If you have questions about other specific issues
related to the TC, please contact Steve Cochran of my staff at
FTS: 382-4769.
Attachments
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9441.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR I 9 !9?'
opuce o*
SOLID WASTE ANO EME1SENCV RESPONSE
Melanie K. Pierson
Assistant U.S. Attorney
U.S. Department of Justice
Southern District of California
United States Courthouse
940 Front Street, Room 5-N-19
San Diego, California 92189
Dear Ms. Pierson:
This responds to your February 26, 1991 letter to
Ms. Becky Cuthbertson regarding the regulatory status of solder
dross generated by the periodic skimming of molten solder baths
used in the production of printed circuit boards to remove
contaminants acquired through use of the molten solder baths.
Your specific question concerns whether this solder dross meets
the description of a "by-product" or a "spent material" in the
context of the hazardous waste regulations.
Although it is not specifically defined, the term "dross" is
used as an example of a by-product in the January 4, 1985 Federal
Register preamble to the current definition of solid waste (see
50 FR 625). Further, there is an example in EPA's "Guidance
Manual on the RCRA Regulation of Recycled Hazardous Wastes"
(March, 1986) in which solder drosses generated in soldering
integrated circuits to printed circuit boards are determined to
not be solid wastes because they are identified as
"characteristic by-products that are reclaimed."
Typically, a "dross" is generated prior to using a metal or
alloy by melting the metal or alloy and skimming off the
contaminants and oxides that have developed since the metal or
alloy was refined. In the soldering of integrated circuits to
printed circuit boards (as in the example given in the guidance
manual), the dross is generated as a by-product (of the solder)
when the solder is melted during its use. However, although the
generator may claim that a secondary material is a "dross" (and
the material may, in fact, appear to be a "dross"), that does not
automatically mean that the material is a by-product rather than
a spent material.
The determining consideration in classifying a secondary
material is how the material is generated, not the term used to
describe it (e.g., "dross"). As a product that has been used in
the process, the solder skimmings, when removed (i.e., skimmed
Prmtea c
-------
off) from the process due to contamination of the molten solder
bath during its use in the process, would more clearly meet the
definition of a spent material than a by-product. Rather than
being a by-product of the solder itself, the skimmings are spent
materials from the use of the solder.
As you know, this regulatory interpretation reflects the
Federal program. You should also contact the appropriate State
regulatory agency to determine the regulatory status of the
solder dross under their program.
I hope this has helped to answer your questions. Should you
have any further questions, you can contact Mr. Mitch Kidvell, of
my staff, at (202) 475-85S1, or Ms. Jeannie Paige, of the EPA
Region IX office, at (415) 744-2073.
Sincerely,
David Bussard
Director
Characterization and Assessment
Division
cc: Jeannie Paige
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UNITED STATES ENVIRONMENTAL PROTECTION A&SNWi
9441.1991(04)
MAR 26 1991
John i. Ely
Enforcement Director
Virginia Department of Waste Management
101 North 14th Street
Richmond, Virginia 23219
Dear Mr. Ely:
At the request of Carlyle C. Ring, Vice President and
General Counsel of Atlantic Research Corporation, Z am sending
this letter to summarize the Agency's current position on the
"contained-in" interpretative policy. It is my understanding,
based upon Mr. Ring's letter, that there vas some question as to
whether the "contained-in" interpretative policy applies to all
environmental media or only to ground water. Mr. Ring's letter
also suggested that a letter from my Office would help resolve
this matter. I hope this letter will answer this question and
further clarify the policy. I have also enclosed, for your
information, a memorandum from Jonathan Cannon to Thomas Jorling
dated June 19, 1989. 1 hope that you will find these helpful.
The "contained-in" interpretation addresses environmental
media (i.e., ground water, soil, and sediment) contaminated with
RCRA listed hazardous waste. Our federal regulations at 40 CFR
Part 261.3 identify hazardous wastes. Among other things, these
regulations state that a solid waste mixed with a hazardous waste
is a hazardous waste. However, these regulations generally do
not specifically address environmental media, which are not solid
wastes, mixed with listed hazardous waste. The Agency's position
continues to be that mixtures of environmental media and listed
. hazardous waste (i.e., contaminated ground water, contaminated
soil, and contaminated sediments) must be managed as if they were
hazardous waste. This position is known as the "contained-in"
policy, EPA's application of the "contained-in" policy to
contaminated media was upheld by the D.C. Circuit Court of
Appeals in Chepjcaj	M»n3qi»PtsTvt« in?, v. ?,gT EPA# 869 F.2d
1526 (D.C. Cir. 1989).
Consistent with this approach, the Agency further interprets
the regulations to mean that environmental media contaminated
with listed hazardous waste must be managed as if they were
hazardous waste until the media no longer contain the listed
hazardous waste (i.e., until decontaminated), or are delisted.
Tn rtafp	t-ihe ftrrartrv has not iegwad anv definitive guidance aa to
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9441.1991(05)
f A \
I	S	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 22 |99I
Of PiCE Of
SOLIO WASTE AND EMERGENCY RESPONSE
Ms. Corinne A. Goldstein
Covington & Burling
1201 Pennsylvania Avenue, N.W.
Washington, D.C. 20044
Dear Ms. Goldstein:
This letter is in response to your correspondence to
Randolph Hill dated November 16, 1§90, and December 13, 1990,
concerning DuPont•s "chloride-ilmenite process." As you are
aware from telephone conversations with Mr. Hill and the brief
filed by the Agency with the U.S. Court of Appeals for the D.C.
Circuit in Solite Corp. v. EPA, the Agency continues to believe
that wastes from this process are appropriately classified as
mineral processing, not beneficiation wastes. This letter
specifically addresses DuPont*s proposed changes in the process
discussed in the November 16 and December 13 letters, and the
impact that these process changes would have on the Bevill status
of the new wastes produced.
The Agency*s determination that chloride process waste acids
(including DuPont*s chloride-ilmenite process waste acids) are a
processing waste was a one-time decision based on a "snapshot** of
the industrial processes in place at the time of the decisions.
It was, and remains impossible for us to address the Bevill
status of wastes from proposed changes in current processes. The
Agency clearly stated this in the September 1, 1989, Final Rule
, (54 36592}. Such new wastes, unless determined to be either a
beneficiation waste or among the 20 temporarily exempt mineral
processing wastes (which DuPont*s proposed wastes would not be),
would be non-exempt mineral processing wastes and would need to
be managed in accordance with RCRA Subtitle C if they are
characteristically hazardous.
If DuPont implements the changes it has proposed (or other
changes), the Agency will evaluate the resulting wastes to
determine if some portion is indeed a beneficiation waste. He
cannot, however, guarantee that a decision that these are
beneficiation instead of processing wastes would be made. Based
on process descriptions in your November and December letters,
Prvmd m RtijrM Pwrr*
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along with other information you provided in our November 20,
1990, meeting, the Agency already has some reservations as to
DuFont's ability to generate a waste only containing residues
from beneficiation. Operations producing combined beneficiation
and processing wastes are appropriately classified as processing
operations for purposes of determining whether or not they
produce wastes that are exempt mineral processing wastes.
If you have further questions concerning this matter, please
contact Bob Tonetti at (703) 308-8426.
SipcerelY. si /
'Director
Office of Solid Waste
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9441.1991(06)
¦Of
I	s	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\T	WASHINGTON. D.C. 20460
MAY 2 9
Mr. Philip s. Bell
Amerock Corporation
4000 Auburn St
P.O. Box 7018
Rockford, IL 61125-7018
Dear Mr. Bell:
199!
0**'CE Of
SOLID WASTE AND EMfc AGENCY RESPONSE
This is in response to your April S letter regarding the
regulatory status of certain electroplating wastes and associated
waste management activities. Our responses to your specific
questions follow:
1. Anode baas
a. When, and under what conditions, do they become a
hazardous waste?
The anode bags become a solid (and hazardous) waste when
they are removed from the plating bath. At this point, they are
considered to be a "spent material" that is reclaimed (i.e.,
washed to remove the cyanide solution) prior to reuse.
b. If they are washed and reused, are they hazardous waste
during the time between removal and washing (if the washing does
not occur in the same process tank)?
As described above, during this period, they are a "spent
material" and a hazardous waste.
c. If and when they become a hazardous waste, when one
washes the bags to remove the plating solution, must one have a
RCRA Part B permit, or can one perform "treatment while
accumulating" by meeting the requirements of 40 CFR 262.34 and 40
CFR 265 Subparts I and J?
Washing of the bags constitutes treatment of a hazardous
waste. However, a RCRA permit would not be required if this
treatment occurs in tanks or containers during the accumulation
period of not greater than 90 days and meets all of the
requirements of 262.34(a).
PmteaonR-
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d. If and when they become a hazardous waste, is the proper
waste code for them solely D003 for CN content or do they also
become a listed waste (such as F007) by virtue of some
application of the mixture rule? (The assumption is that there
are no hazardous characteristics other than reactivity due to
cyanide.)
The waste would be considered both D003 and F007 (spent
cyanide plating bath solution from electroplating operations).
This is because the anode bag is both reactive and contains (has
been soaked in) spent plating bath.
2. Filtered residues from cyanide plating baths
When a filtering apparatus which has been filtering a
cyanide plating bath is opened for cleaning, is the residue and
filter media (if it is to be discarded) solely D003 or a listed
waste code (F0077/F008?) in addition to the D003?
These wastes would be considered both DO03 and F008 (spent
plating bath residues from the bottom of plating baths from
electroplating operations where cyanides are used in the
process). While any F008 waste would contain some of the F007
plating solution from the tank in which it was generated, the
F008 listing is the more specific description; thus, use of the
F007 designation would not be appropriate.
3. A detergent cleaner and rinse prior to a cvanide plating bath
a. Was it USEPA's intent to include the Detergent cleaner
Solution (when spent) in the F00S listing?
The F009 listing applies to cyanide-containing cleaning and
stripping baths (i.e., "where cyanides are used in the process"
^ refers to the cleaning and/or stripping process). If the
deeming solutions are not cyanide-containing, the F009 listing
is not applicable.
Should you have any questions regarding these
interpretations, feel free to contact David Bussard, Director of
the Characterization and Assessment Division, at (202) 382-4637.
Sincerely,
Sylvia K. Lowrance
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united states environmental protection agency
may 30 iSSQ
9441.1991(07)
Mr. T. S. Ary
Director
Bureau of Mines
2403. E. St., N.W.
Washington, D.c. 20241
Dear Mr. Ary:
Thank you for your letter dated April 6, 1990, concerning
iron and steel slags, and their status in the upcoming Report to
Congress (RTC) on Mineral Processing Wastes. EPA appreciates the
contributions that the Bureau of Mines has made to the RTC to
date, and we would be pleased to meet with you to discuss issues
related to these slags.
Although the RTC has not been completed yet, based on the
information the Agency has collected to date on iron and' steel .
slags it is likely that the Agency will recommend that these
wastes remain within the Bevill exclusion — that is, we believe
these wastes will become permanently exempt from regulation as
hazardous waste under Subtitle C of the Resource Conservation and
Recovery Act (RCRA).
Iron and steel slags which are used in a manner constituting
disposal are currently considered "discarded* materials*1 and thus
meet the definition of solid wastes tinder Section 1004(27) of
, RCRA. SSS. *0 CFR § 261.2 or S3 Fed. Reg. 31,198 (Aug. 17,
1988) for details. EPA is further considering, however, whether
such slags are similar enough to virgin.aggregate that they
should not be classified as solid waste. EPA will address this
issue in greater detail in the upcoming Report to Congress, as
already promised in the final "Bevill Rule" (54 Fed. Reg. 36,615
(Sept. 1, 1989)). In any event, if these slag materials were to
continue to be exempt from Subtitle C regulation, I would expect
the use of slag materials would continue. Please let us know,
however, if the Bureau of Mines has reason to believe that
continued classification of these slags as solid wastes would
cause market disruptions and harm to the slag recycling industry.
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9441.1991(08)
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wastewater, but may subtract the amount of solvent that does not
flow into the headworks of the wastewater treatment system. In a
footnote to the preamble, EPA stated that the amount of solvent
volatilized may not be subtracted from the calculation. This
language was added to prevent facilities from qualifying for
the exemption by volatilizing their solvents, and thus causing
negative environmental impacts.
I appreciate very much the detailed information you have
provided, showing that the wastewater mixture entering the
headworks at NAS contains far less solvent than the 25 ppm
threshold described in the rule. However, according to the
information collected by EPA staff in our Region IV office and
at Headquarters, much of the solvent used at Pensacola NAS for
aircraft paint stripping volatilizes during use and is not
otherwise collected. Our current regulations do not allow me the
flexibility to permit a subtraction of the volatilized amount.
As a result, it appears that Pensacola NAS cannot qualify for the
exemption, unless the Navy can show that the solvents that do
not go to the wastewater treatment system are not otherwise
volatilized.
There is another important aspect to this issue. When the
25 ppm provision was promulgated, none of the solvents to which
it applies was considered a suspected carcinogen. Now, however,
methylene chloride is considered to be a probable human
carcinogen. Any reassessment of this regulatory provision would
necessarily reflect this new information and possibly further
restrict this wastewater exemption.
I realize that very little solvent goes to the wastewater
treatment system. The Navy has made an outstanding effort to
reduce the amount of such pollutants being managed as hazardous
wastes. I urge you to continue your efforts in this regard. We
will continue to work with the Navy as it addresses the next
steps for the Pensacola NAS.
Sincerely yours,
inistrator
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.,*0 tt,,
^ r% \
isuj
9441.1991(09)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
Dear Mr.
JUN 2 I 1991
solid waste AND EVE«CENC>' RES'ONSl
Mr. Basil G. Constantelos, Director
Environmental Affairs
Safety-Kleen
777 Big Timber Road
Elgin, Illingip (1^0123
:elos:
Thank you for your letter of April 17, 1991, requesting
comments on a position paper on spent absorbent materials.
We have completed reviewing your paper and have included a
number of comments in the enclosure to this letter for you to
consider, as this is a complex area of the Resource Conservation
and Recovery Act. Please note that these comments are of a
generic technical nature and are therefore not specific to a
given factual situation.
We appreciate the opportunity to review your position paper.
The Environmental Protection Agency is glad to help ensure the
safe and effective disposal of hazardous waste.
Sincere
urs,
SylVrarTC. Lowrance, Director
Office of Solid Waste
Enclosure
Printed on Recycles
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ENCLOSURE
The opening statement (basis) of the paper states that
absorbents used to collect used oil, fuels, or solvents may not
be disposed of in a sanitary landfill when they are generated by
a small or large generator. This is not entirely correct. Under
federal rules, a conditionally exempt small-quantity generator
(SQG producing less than 100 kg/mo.) in compliance with 40 CFR
261.5 may dispose of hazardous waste in a sanitary landfill if
that facility is permitted, licensed, or registered by the state
to manage municipal or industrial solid waste per 40 CFR 261.5.
In the discussion pertaining to mixtures of spent absorbent
and "F or U* listed hazardous waste, it says that these mixtures
must be shipped and manifested as "F or U" wastes. There is an
exception to this classification, however, for mixtures of listed
wastes that are listed only for a characteristic. If the listed
hazardous waste is mixed with contaminated absorbents (a solid
waste), and those mixtures no longer exhibit a hazardous
characteristic, the mixture rule exclusion in 40 CFR
261.3(a)(2)(iii) applies, and these mixtures are not classified
as listed "F or U" wastes and are not subject to further
regulation. Hie deliberate mixing of absorbent and hazardous
waste to render the mixture non-hazardous may, however, be
interpreted as "treatment" per 40 CFR 260.10 and may require a
permit and compliance with Part 268 land disposal restrictions.
The discussion of absorbents and non-listed waste mixtures
addresses mixtures involving flammable liquids. The discussion
on flammable liquids, test methods, and resulting classification
is hard to follow, A waste liquid or mixture containing a free
liquid phase (as defined by our paint filter liquids test-method
9095) is ignitable under the Resource Conservation and Recovery
Act (RCRA) if the waste (or liquid phase) has a flashpoint
<	140*F using the methods specified in 40 CFR 261.21(a) (1). If
the mixture has no free liquid phase, then it is considered a
solid. Solids that meet the criteria in $261.21(a)(2) concerning
:the ability to cause fire through friction, absorption of
moisture, or spontaneous chemical changes such that they ignite
and bum vigorously thereby creating a hazard are classified as
ignitable hazardous wastes. Zf a mixture of a characteristic
waste absorbent has a free liquid phase with a flashpoint
<	140*F, it is ignitable. If there is no free liquid phase,
then the qualitative criteria for solids apply? if the mixture
meets those criteria, it is classified as ignitable.
With respect to Department of Transportation (DOT)
classification of these materials, please note that the
definitions and criteria for hazardous materials under DOT are
often different from those of RCRA hazardous wastes. RCRA
hazardous *?astes are, in fact, a subset of DOT hazardous
materials. However, the DOT hazard classes do not directly
correspond to RCRA hazard characteristics. For example, DOT
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classifies materials as "flammable" if the liquid has a
flashpoint < 100°F, and classifies liquids with flashpoints
between 100° and 200°F as "combustible." EPA classifies
hazardous wastes as "ignitible" with a flashpoint < 140°F
Therefore, some EPA ignitibles may be DOT flammable, and some
may be DOT combustible, depending on flashpoint. You should
consult DOT to further clarify its nomenclature and criteria.
In that same discussion of absorbent mixtures, there is also
a reference to liquids containing TCLP constituents. The mixture
would be classified as TC hazardous if it exceeded the regulatory
levels in §261.24.
Zn the discussion on used oil, there also seems to be some
confusion. The basis for the statement that "used oil is assumed
to exhibit a characteristic of hazardous waste due to its use..."
is unclear. Such a blanket statement is not supported by
recently collected EPA data, which will be noticed and discussed
in an upcoming used oil proposal in September. Generators are
responsible for making a hazardous waste determination if they
plan to dispose of used oil. If the oil or oil/absorbent mixture
exhibits a hazardous characteristic, then disposal options depend
on the generator's status (i.e., conditionally exempt SQG waste
may be disposed of in municipal or industrial landfill that is
permitted, licensed, or registered by the state). If a used
oil/absorbent mixture is to be burned for energy recovery, then
40 CFR 266 Subpart £ applies.
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"i ngiV
UNITED STATES ENVIRONMENTAL PROTECTION AGEN
WASHINGTON, D.C. 20460
1991(10)
JUN 2 I 1991
OF* ICE Or
SOuiOWASTE and EMEBCENCV pESPONSE
Melanie K. Pierson
Assistant United States Attorney
Southern District of California
United States Court House
940 Front Street, Room 5-N-19
San Diego, California 92189
Dear Ms. Pierson:
This responds to your May 3, 1991 request for a regulatory
interpretation regarding the status of solder skimmings, based on
information supplied to you by Mr. Karl S. Lytz. In Mr. Lytz's
letter to you dated April 29, 1991, he presents more specific
information regarding the actual process used by a Fisher-Price
facility that generates solder skimmings. The principal
determination focuses on whether the solder skimmings are defined
as "spent materials" or "by-products." This determination is
based on hov the solder skimmings are generated.
As stated in our March 19, 1991 letter to you, EPA has
previously indicated in regulatory interpretations (including
Federal Register preamble discussions and guidance manuals) that
dross or skimmings are typically considered by-products.
However, because the terms "dross" and "skimmings" can refer to
secondary materials generated by a variety of processes, a more
studied assessment of hov a specific secondary material is
generated is necessary to determine its actual regulatory status.
In other words, the term used to describe a secondary material
(e.g., dross or skimmings) is not necessarily determinative of
^its regulatory status.
To the extent that a material has been used in a process,
and is subsequently removed due to contamination, the Agency
would consider the material to be "spent." The term "by-product"
refers to materials that result from a production process that
are not the intended product and are not fit for a desired end
use without substantial further processing (i.e., they are not
co-products), and are not otherwise classified as spent materials
or sludges. In very general terms, dross generated in the
production of solder is a by-product; dross generated in the use
of solder is a spent material. As stated in our March 19, 1991
letter to you, the Agency interprets "by-product" to also include
drosses (or skimmings) that are generated from solder that is
melted prior to use (which is analogous to the further refinement
Printed on Recycled P
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2
of a product). However, drosses generated from the solder during
or after its use are defined as spent materials.
In Kr. Lytz's letter, he describes the various steps in the
process that generates the solder dross. It appears that "dross"
is generated both as a by-product and as a spent material. In
the reservoir, which is used "... exclusively for melting
solder rods to produce molten solder for use in the bath," the
dross generated would meet the Agency's definition of a by-
product. However, the dross generated by slcimming the solder
bath and the wire tinning operations would'be considered spent
materials, because the solder has been used in these operations.
The basis of this differentiation is not a consideration of the
chemical composition of the material (e.g., whether it is
similar, or indeed identical, to the dross generated in the
reservoir), or in how the material became contaminated (e.g., by
oxidation with the air). The determining factor is that the
solder has been used, is contaminated, and is being removed from
the process. Athough Mr. Lytz states that the solder has not
been contaminated, but rather the oxides are "impurities" that
occur naturally through use (as opposed to being residual
contaminants from the parts that are soldered), the Agency would
nevertheless consider the oxides to be the contaminants that
cause the solder to be skimmed and removed from the process.
(The Agency notes that the entire solder bath is not considered
spent merely because the bath has been contaminated by the oxides
rather than the small portion that must be removed or skimmed
off. The "spent material" classification is only applicable to
those materials that are removed from the process, and are thus
"generated.")
Thus, all things being equal (i.e., the oxide contaminant),
the difference between the status of the reservoir dross and the
dross generated by the solder bath and the wire tinning
operations is whether or not the dross is skimmed from a used or
unused solder. For example, if the reservoir was to also receive
- ''previously used solder for remelting (e.g., solder returned from
the solder bath) then this dross, too, would be classified as a
spent material. To the extent that the different drosses can be
segregated and managed without mixing, they would be subject to
different regulatory requirements. As Mr. Lytz stated, 95% of
the dross is generated by skimming the reservoir; this relatively
large amount would not be subject to regulation as a hazardous
(or solid) waste. The other drosses, however, would be subject
to the applicable regulatory requirements as a hazardous waste.
In reference to the confusion raised by the Electrum letter
(i.e., the July 20, 1989 letter from Mr. Devereaux Barnes to Mr.
Jack Douglas of Electrum Recovery Works, Inc.)/ our focus in
making the regulatory interpretation was whether the dross met
the regulatory definition of a scrap metal. Insufficient
information was provided on how the dross was generated to make a
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determination of its status at the point of generation. (Indeed,
the status of the dross as a by-product vs. a spent material vas
never raised; had the same information been provided regarding
the generation of the dross, the Agency vould have determined
that the dross vas a spent material.) He took Mr. Douglas*
assessment that the "dross* vas a characteristic by-product at
face value vithout evaluating hov the material vas generated and
erroneously agreed vith this classification in a letter vritten
for the purpose of addressing his claim that the dross vas a
scrap metal (see the enclosed June 5, 1989 letter from Mr.
'Douglas to Mr. Straus and the May 22, 1989 letter from Ms.
Deborah S. Kinbum to Mr. Matt Straus).
Z hope this has helped to clarify the regulatory status of
the dross generated at the Fisher-Price facility. Generally, a
determination regarding the regulatory status of a specific
secondary material is made by the State regulatory agency or the
appropriate EPA Regional office because of the site-specific
factors that may varrant consideration. Hovever, this letter
presents the factors the Agency vould consider in making such a
determination. If you have any further questions regarding this
issue, you should contact Mitch Kidvell, of my staff, at (202)
475-8551. *
Enclosures
Sincerely,
David Sussard, Director
Characteristics and
Assessment Division
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UNITED STATES EHVIRONMEKTAL PROTECTION AGENCY
9441.1991(11)
JUN 28 1991
Mr. Rudy Leutzinger
Burns & McDonnell
P.O. Box 419173
Kansas City, MO 64141-6173
Dear Mr. Leutzinger:
This is in response to your April 10 letter to Steve Cochran
regarding the regulatory status of CCA treated wood when
disposed. Discarded wood and wood products that would be
hazardous only because they fail the Toxicity Characteristic for
the 14 hazardous constituents originally regulated through the EP
Toxicity Characteristic (i.e., D004-D017) are not hazardous
wastes, per 40 CFR 261.4(b)(9). When we promulgated the Toxicity
Characteristic, we modified the hazardous waste regulations to
replace references to the EP Toxicity Characteristic with
references to the Toxicity Characteristic. In the case of the
exclusion for wood, our rewording inadvertently narrowed the
scope of the exclusion to refer only to wood wastes that fail the
characteristic for arsenic (as opposed to failing the
characteristic for any of the 14 EP constituents). We are
currently writing a Federal Register notice to correct this
language.
Should you have any further questions regarding this issue,
please feel free to contact Dave Topping of my staff at (202)
382-7737.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. ! * *	9441.1991(12)
< •
MEMORANDUM	JUL 3 I 1991
SUBJECT: Response to Request for TC Rule Hazardous Waste
Determination
FROM: Sylvia K. Lowrance, Director
Office of Solid Waste
70:	Stephanie Wallace
Region 8, Montana Office
mis memorandum responds to your February 8, 1991 memorandum
in which you requested guidance on five questions related to pulp
and paper mill operations under the Toxicity Characteristic Rule.
The scenario was described as follows: a pulp and paper mill
generates wastewater in its bleach plant which, at the point of
departure from the unit (for our purposes, assumed to be the
plant outlet), fails the TC for chloroform. This wastewater is
diluted with other wastestreams prior to entering a clarifier.
At this point the diluted waste no longer exhibits a
characteristic. The non-TC-hazardous wastewater then passes
through a series of surface impoundments for aeration and
settling prior to discharge to a surface water under a NPDES
permit. The surface impoundments are designed to infiltrate
greater than 50% of the flow to groundwater. The following are
answers to your questions.
Q: To determine whether the facility is managing a TC waste, is
the appropriate sampling point at the outlet from the bleach
plant (prior to the point where it mixes with any other
wastestream) ?
A: Yes. The appropriate point to determine whether a material
is a solid waste, and if so, a hazardous waste, is at the
point of generation or prior to commingling (mixing) with
other wastestreams.
' ^Q: If the waste is TC hazardous at this point (that is, at the
outlet from the bleach plant, prior to the point where it
mixes with any other wastestream), but not when it enters
the first surface impoundment, would the surface
impoundments be regulated? Why or why not?
A: The answer to this question is no, unless TC waste is
generated in the impoundment. Whether a TC waste is
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
generated depends on both the influent and physicochemical
activity within the surface impoundment. For example, if a
non-TC hazardous influent is pumped into an impoundment
which contains other non-hazardous wastes, a hazardous waste
could result even if constituent levels in the influent are
below TC regulatory levels (for example, from concentration
of the various hazardous constituents). Another example is
where solids settling out of the non-hazardous influent
result in the generation of a hazardous sludge, again from
concentration of the trace hazardous constituents. In each
case, the impoundment would become subject to all applicable
Subtitle C requirements (see September 27, 1990, 55 FR
39410)• Furthermore, each surface impoundment in a series
of impoundments is treated separately for regulatory
purposes.
Q: Does the land ban allowance for dilution of toxic
characteristic wastes subject to a NPDES permit (providing
the treatment standard is not a method), allow mixing of the
bleach plant effluent with other dilute wastestreams before
treatment? (This is not an issue yet, but will be of
concern when treatment standards for TC wastes are
established. The preamble to the 3rd (Third Third) rule
indicates that EPA can apply LDRs at the point of generation
rather than at the point of disposal).
A: Yes. As discussed in the Third Third final rule (June 1,
1990, 55 ££ 22665), dilution is considered to be an
acceptable method of treatment for most non-toxic
characteristic wastes. For toxic characteristic wastes,
including TC wastes previously regulated under the EP,
dilution is not acceptable. However, there are two
exceptions to this. The one that applies here is for
characteristic wastes treated for purposes of CWA compliance
(such as for HPDES permitting requirements), provided there
is no specified method as the treatment standard. Dilution
of TC organics will be evaluated during development of
treatment standards.
.
Q: If it is determined that the surface impoundments are
regulated, would they be exempt from the minimum technology
requirements of RCRA 3004 (o) (1) (A) based on the exemption in
3005(j) (1) (3) for units which contain treated wastewater at
facilities subject to a CHA 402 (NOTES) pemit?
A: Yes. Surface impoundments that meet the conditions of RCRA
(HSWA) S 3005(j) (3) are exempt from the minimum
technological requirements of RCRA (HSWA) § 3004(o)(1)(A).
Section 3005(j)(3) applies to units containing treated waste
water during the secondary or subsequent phases of an
aggressive biological treatment facility (as opposed to anv
treatment facilitv).
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Q: Is the definition of "aggressive biological treatment" in
this case the same as that laid out in the recent petroleum
refinery listings?
A: Ho. The petroleum listing definition of "aggressive
biological treatment" applies specifically and only to
petroleum refinery waste surface impoundments (see 55 FR
46354, November 2, 1990). A general discussion of the term
can be found in footnotes 7, 8, and 9 on p. 46357 - 58.
Z hope we have answered your questions. Additional
information is attached should you need to reference it. If you
have further questions, please call Steve Cochran of my staff at
ITS 382-4769.
cc Regional Waste Management Division Directors
Regional RCRA Branch Chiefs
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ADDITIOHAL IOTORKATIOH OH HAZARDOUS WASTE DSTKRXZHATZOH
In a discussion on sampling points, the preamble of the TC
final rule (March 29, 1990, 55 IB 11830) reads as follows:
"The current rule requires that determination of whether a
waste is hazardous be made at the point of generation (i.e.,
when the waste becomes a solid waste). (A waste must be a
solid waste before it ean classified as hazardous waste
under 1CRA). EPA believes that determination of the
regulatory status of a waste at the point of generation
continues to be appropriate, especially since the Agency is
not developing a separate mismanagement scenario or set of
regulatory levels for wastewaters."
EPA developed a TC clarification notice which includes
examples of regulated surface impoundments managing newly
identified TC wastes (September 27, 1990, 55 £B 39409). The
following language on page 39410 may be applicable to the
first surface impoundment you describe in question 2: "A
[third] example is where a TC waste is generated within the
unit from non-hazardous wastewater on or after the TC
effective date. This could occur where the hazardous
constituents in the wastewater become concentrated, or if a
new TC sludge is formed by settling. Zn these examples,
once the TC waste is generated and stored or disposed of in
the unit, the unit is subject to subtitle C." The
additional surface impoundments would be regulated in the
following manner: if the first surface impoundment
generated a TC hazardous sludge or wastewater, and the
hazardous effluent was received in subsequent surface
impoundments, them the subsequent surface impoundments would
also be subject to subtitle C requirements (see 55 EE 11830,
and 55 39410).
The dilution prohibition exception is codified in 40 CFR
268.3(b) and reads as follows: "Dilution of wastes that are
hazardous only because they exhibit a characteristic in a
treatment system which treats wastes subsequently discharged
to a water of the United States pursuant to a permit issued
under section 402 of Clean Water Act (CHA) or which treats
wastes for purposes of pretreatment requirements under
section 30? of the CHA is not impermissible dilution for
purposes of this section unless a method has been specified
as the treatment standard in Section 268.42."
In order to qualify for the WWTO exemption, the device must
meet three criteria: 1) be part of a wastewater treatment
facility that is subject to regulation under either section
402 or 307(b) of the Clean Water Act; 2) receive, and treat
or store influent wastewaters or wastewater treatment
sludges which met the definition of a hazardous waste in 40
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
% •
CFR 261.3? and 3) meet the definition of tank or tank system
(see "wastewater treatment unit," 40 CFR 260.10).
Assuming that the first two criteria are met, an evaluation
needs to be made for the third condition. If the clarifier
meets the 40 CFR 260.10 definition of tank, then a
determination must be made on the conveyance structure (in
your letter, you marginally referenced the "means of
conveyance"). The 40 CFR 260.10 term "tank system" includes
the tank and its associated ancillary equipment and
containment system. Xn turn, "ancillary equipment" means:
"any device including, but not limited to, such devices as
piping, fittings, flanges, valves, and pumps, that is used
to distribute, meter, or control the flow of hazardous waste
from its point of generation to a storage or treatment
tank(s), between hazardous waste storage and treatment tanks
to a point of disposal on-site, or to a point of shipment
for disposal off-site (see "ancillary equipment,* 40 CFR
260.10).
The conveyance structure may or may not meet the definition
of ancillary equipment depending on whether it is designed
to distribute, meter, or control the hazardous waste flow
between the generation point and a storage or treatment tank
(which is designed to contain an accumulation of hazardous
waste). For example, a conveyance structure which is simply
a ditch constructed of dirt would not meet the definition.
Determining whether a given conveyance structure meets the
definition of ancillary equipment is necessarily a site-
specific judgement, dependent on the circumstances and facts
at the facility in question. The state or regional
authority reviews the facts in question to determine whether
a specific conveyance structure meets the terms of the
exemption.
Finally, if an exempt WWTB renders the wastewater non-
hazardous, the storage of the wastewater in the surface
impoundments would not be under RCRA Subtitle C regulation,
unless conditions described in the answer to your second
question occur (i.e., the surface impoundment generates a
hazardous wastewater or sludge).
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RCRA/SUPERFOND HOTLIKE MONTHLY SUMMARY
JULY 1991
9441.1991(13)
RCRA
* « -
1. Truck Transport of Wastewater for Purposes of Section 2613(a)(2)(ivXA)
A treatment, storage and disposal facility manages a wastewater which is a mixture
of a solid waste and trichloroethylene in dg minimis quantities as drfined in Section
2613(a)(2)(ivXA). If the facility transports the wastewater in trucks from an on-site
sump to its on-site NPDES-permitted wastewater treatment unit, does the waste still
qualify for the exemption torn the definition of hazardous waste under Section
2613(a)<2)Gv)?
Yes, the waste still qualifies for the exemption. Section 2613(aX2)Gv> does
not limit the means by which the wastewater may reach the wastewater
treatment unit in order to be eligible for die exemption from the definition erf
a hazardous waste. The exemption requires only that that the wastewater be
treated in a wastewater treatment unit at a facility subject to regulation under
either section 402 or section 307(b) of the Clean Water Act and the wastewater
must meet the <£e minimis levels established in paragraphs (A) through 
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9441.1991(14)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
AUGUST 1991
1. Regulatory Status of Off-Specification Circuit Printing Boards
Periodically, in a circuit board manufacturing process, individual circuit boards are
not considered to meet manufacturing specification standards. These units are
dismantled, and the materials are reclaimed for use in the construction of new
circuit boards. Assuming the circuit boards would exhibit a characteristic of 40 CFR
Subpart C would the dismantling and recycling of the boards be subject to RCRA
Subtitle C hazardous waste regulations?
No, reclamation of the off-specification circuit boards would not be subject to
the RCRA Subtitle C hazardous waste regulations because the circuit boards
are not hazardous wastes.
By definition, for a waste to be a hazardous waste, it must be a solid waste t40
CFR §2513). To determine whether a material is a solid waste when
reclaimed, it must first be determined whether the material is a spent
material, sludge, by-product, commercial chemical product or scrap metxl
(See 40 CFR 1261.2(c)(3).) An ur.used arcuit board is classified in the
chemical products category. Although the commercial in the chemical -
products category in Table 1 ot 40 CFR 5261.2(c)(3) is labeled "commercui
chemical products listed in 40 CFK tie 133," as explained in a Federal Regs w
notice published on April 11,19*5. • 50 Fg 14219) the status of commercui
chemical products not listed in 40 CFR §261 (Le, those that exhibit hazardous
wastes characteristics) is "the same as those feat are listed in Section 26L33."
These materials are normally solid wastes only if thrown away, and so are not
solid waste if reclaimed. Further, the Agency interprets commercial chemical
products to include all types of unused commercial products that exhibit
characteristics, whether or not they would commonly be considered chemicals
(eg., circuit boards, batteries, and other types of equipment).
Once it has been determined that the arcuit boards are commercial chemical
products, 40 CFR §2612(c)(3) indicates that they are not solid wastes when
they are to be reclaimed. Since thecircuit boards are not solid wastes, they are
not hazardous wastes and the reclamation is not subject to the RCRA Subtitle
C hazardous waste regulations. It should also be noted that the 40 CFR
§261.2(f) requirement (persons who raise a daim that a material is not a solid
waste document must meet the terms of the exemption) may be applicable.
Source:
Research:
Charlotte Mooney, 05W
Cynthia Hess
(202)260-6926
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9441.1991(15)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP to i3SI
0«tCE Of
SOLID WASTE ANOBMERCENC* RESPONSE
Ms. Mary m. White
Corporate Environmental Director
Quaker State Corporation
P.O. Box 989
oil City# Pennsylvania 16301
Dear Ms. White:
Thank you for your	letter of March 27, 1991, requesting a
delay in the imposition	of the toxicity characteristic (TC) rule
on oil filters, because	of its impact on the recycling of used
oil and oil filters.
The Environmental Protection Agency (EPA) has addressed
this issue in the enclosed used oil supplemental proposal
notice, which was published in the Federal Register on
September 23, 1991. The notice covers the used oil listing
alternatives and alternative standards for managing recycled
used oil. EPA vill issue the final used oil regulation by
May 1, 1992.
For the following reasons, IPA does not believe a TC
exemption for used o'il filters is needed at this time:
•	the available TC data related to used oil filters suggest
that crushed filters may not exhibit the TC; and
•	as 1 explained my October 30, 1990, memorandum to
Robert L. Duprey of EPA Region VIII, there are
existing exemptions for recycled used oil and recycled
used oil filters; no TC determination is necessary for
oil filters destined for recycling.
As discussed in the supplemental proposal (Appendix A
contains the pertinent portion of the proposal), analytical data
suggest that used oil filters devoid of free-flowing oil are
likely to be non-hazardous (i.e., they will pass the TC test).
In addition, the supplemental proposal requests comment on
specific issues on used oil filters, such as:
•	what methods (e.g., draining, crushing, dismantling,
centrifuging, and cleaning with solvent) could be
employed to remove used oil from oil filters;
.ttosw
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what criterion defines adequate "crushing";
•	should the "one-drop" approach be used to determine when
a used oil mixture ceases to become "oil-free" solid
waste; and
•	should oil filters containing insignificant quantities
of free-flowing oil be disposed of in municipal
landfills.
Depending on public comments, EPA may finalize standards for
managing used oil filters when finalizing the used oil
regulation.
If the used oil rule becomes final as proposed, used oil
collected from oil filters would be subject to §3014 used oil
management standards; crushed or oil-free filters would continue
to be managed under the RCRA scrap metal exemption, or may be
disposed of in municipal landfills, provided the State allows
such disposal. Zn the interim, EPA may issue a directive
discussing management alternatives for generators of used oil
filters who are unable to recycle drained and crushed filters
under the scrap metal exemption for economic or technical reasons
(e.g., reluctance of scrap metal handlers to accept oil filters).
If you have any further questions concerning the
supplemental notice, feel free to contact Ms. Rajni Joglekar
at (202) 260-3516. Thank you for your interest in the safe and
effective management of hazardous waste.
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UNITED STATES EHVIRONMEHTAL PROTECTtOH AGENCY
9441.1991
OCT 2 2 1991
Mr. Kevin S. Dunn
Project Manager
Environmental Policy Center
Lav companies Environmental Group
1828 L Street, N.W.
Suite 711
Washington, B.C. 20036
Dear Mr. Dunn:
Thank you for your letter of May 28, 1991 regarding the
regulatory-status of industrial equipment which formerly
contained a hazardous vaste. I apologize for the delay in
responding to your inquiry.
In your letter, you described a situation in which pumps
containing elemental mercury vere taken out of service and used
as containers for temporary storage, transportation and handling
of the mercury before its treatment and disposal. You asked
whether the pumps could be regulated as non-hazardous wastes if
the mercury were removed from the pumps in a manner consistent
with the requirements of 40 CfR 261.7 for empty containers.
Zt is our view that if the pumps meet the definition of
"container" in 40 CFR 260.10, they are exempt from regulation
' Under Subtitle C of the Resource Conservation and Recovery Act
(RCRA) after they are emptied in accordance with 40 CFR 261.7.
Section 260.10 defines "container" as "any portable device in
which a material is stored, transported, treated, disposed of, or
otherwise handled". If the pumps you describe are portable, they
may be managed as a non-hazardous waste under federal law.
Shis interpretation reflects the federal regulations
governing hazardous waste. States with authorized RCRA programs
may impose more stringent requirements. Such States also have
the authority to make regulatory determinations about the
materials which constitute hazardous wastes under their systems.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2
I hope this letter has addressed your concerns. If you have
any further questions, please contact Mitch Kidvell of ay staff
at (202) 260-8551.
Sincerely,
David Bussard, Director
Characterization and
Assessment Division
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9441.1991(17)
m 4 199!
MEMORANDUM
SUBJECT: Response to Region V Fuel-Blending Concerns
FROM: Sylvia X. Lovrance, Director
Office of Solid Waste (OS-300)
TO:	David A. Ullrich, Director
Waste Management Division (SH-12)
This memorandum responds to your September 24, 1991,
memorandum requesting Headquarters views on the regulatory
interpretations made by Region V specific to hazardous waste
fuel-blending facilities. Your memorandum raised three issues
which will be presented separately along with our reaction to the
Regional interpretation.
ISSUE l
A facility, in requesting a determination concerning RCRA
permit requirements, described its process as receiving waste
liquid and solid fuel stock, recycling the stock, and shipping
waste fuel to a kiln. The facility indicated that it considers
the fuel a recyclable material pursuant 40 CFR 261.6(a) (2) (ii)
and exempt from regulation.
MSMS&
~
We agree with the Region's interpretation that any unit that
meets the definition of a "tank'* or a "tank system" is subject to
regulation. Blending or other treatment to produce a hazardous
waste fuel is not exempt. In fact, the facility seems to have
misread 40 CFR 261.6(a)(2)(ii) which states recyclable materials
such as hazardous wastes burned in boilers and industrial
furnaces (BIF):	are not subject to the requirements of this
section [i.e. 261.6] but are regulated under Sections C through G
of Part 266 of this chapter and ... Parts 270 and 124." Thus,
these units are subject to permitting.
The facility's rebuttal of the Region's earlier
determination attempts to define the unit's purpose as different
from storage. The "purpose" of the unit is moot; if it^treating
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2
or storing hazardous waste, then it is regulated. The diagrammed
process, including grinders, filters, etc., appears to meet the
definition of a tank and its ancillary equipment. Zf the unit or
a component is not a tank or a tank system, or if it has
additional features that would potentially affect emissions or
releases to the environment, then it would be regulated under
Subpart X (miscellaneous units) or permit conditions may be added
based on the omnibus authority of Section 3005(c)(3) of RCRA, as
amended.
IS?VS 2
Considering the BIF rule, can a fuel-blending TSD accept
low-BTU (less than 5000 BTU/lb.) into its mixing program?
MSHEB
A marketer of hazardous waste fuel currently can, and has
previously been able to accept low BTU fuel. However, there are
certain factors which govern whether a BIF can accept waste fuel
originating from. low-BTO waste. Under the sham recycling policy
BIFs have not generally been allowed to burn hazardous waste fuel
that had a heating value of less than 5000 BTU/lb. A low-BTU
fuel (as generated) had to be processed to increase the heating
value to greater than 5000 BTU/lb. by a means other than blending
(e.g., decanting aqueous liquids) before it could be burned.
Now that the BIF rule has been promulgated, the BIFs can
burn low-BTU waste after they conduct compliance emission testing
with low-BTU waste and certify compliance under the new interim
status standards. See section 266.103(a)(6) (56 FR 7213, Feb.
21, 1991).
ISSUE 3
Will the unit processes used to increase the heating value
of low-Btu waste (i.e., phase separation, centrifugation, and air
stripping) require a RCSA permit for their operation?
MSHEE
The unit processes used to raise the Btu value would require
a permit for their operation. If the units do not meet the
definition of units for which minimum technology standards have
been established (e.g., tanks or tank systems), then the unit can
be permitted under Fart 264, Subpart X. The need for a permit
for these types of processing units comes from the language in
Section 261.6(a)(2) which separates recyclable materials used in
a manner constituting disposal or burned, including treatment
prior to being burned for energy recovery, from other recycling
activities like reclamation of a solvent in a distillation unit.
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3
If you have any question concerning our interpretation of
these fuel-blending issues, please call Sonya Sasseville (260-
3132) or Chester Oszman (260-4499) of my staff.
Attachment
ccj Hazardous Waste Division Director, Regions 1-4 & 6-10
Regional Subpart X Contacts
Regional Incineration Contacts
Sonya Sasseville, OSW
Chester Oszman, OSW
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9441.1991(18)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC - 9 1991
OFF ICE OF
SOLIO WASTE ANO EMERGENCY RESPONSE
Mr. James C. Brown
c/o American Electronics Association
1225 Eye St., N.W., Suite 950
Washington, D.C. 20005
Dear Mr. Brown:
Thank you for your letter of October 2, 1991, describing
your concerns about our recent interpretation of Resource
Conservation and Recovery Act (RCRA) regulations that apply to
solder dross generated in manufacturing printed circuit boards.
To briefly restate the issue, you are concerned about a
March 19, 1991 letter from David Bussard that classifies solder
"dross" generated by the use of solder in printed circuit board
manufacturing as a spent material under the RCRA hazardous waste
regulations (and thus, as a solid and hazardous waste). The
March 19 letter was based upon the information that ve had at the
time, and differentiates between spent materials and by-products.
As you noted in our October 16 meeting, previous EPA statements
about the status of solder dross and solder skimmings from
printed circuit board manufacturing were that skimmings and
drosses are by-products - and thus are not solid or hazardous
wastes when reclaimed, tinder the federal RCRA regulations (40 CFR
„261.2).
The term "dross" is frequently used by industry to refer to
an oxide layer that forms on the surface of molten metal,
regardless of whether the metal is a virgin metal being reshaped
into a different form, or is a metal in use (such as solder).
Previous statements, and an example in the January 4, 1985
Federal Register preamble, have generally referred to "drosses"
as by-products under the RCRA hazardous waste regulations.
Although some drosses are by-products under federal rules, the
language of the regulations and the circumstances of a material's
use, including whether the material becomes contaminated,
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2
determine how it is classified. For example, when circuit board
manufacturers have to change their solder baths due to
contamination, the material removed from the bath is a spent
material.
Zt appears that our imprecise use of the term "dross" and
previous statements that solder skimmings or drosses are "by-
products" may have led to widespread practices in the electronics
manufacturing industries, where the skimmings have been managed
as if they were by-products (and thus, neither solid nor
hazardous wastes when reclaimed).
We think it is important to obtain additional information.
We are currently in the process of gathering information to
determine how the solder drosses or skimmings generated in
printed circuit board manufacturing should be regulated, if at
all, under RCRA Subtitle C. That information will include the
levels of contamination in dross and skimmings as solders are
used in circuit board manufacturing as well as a broader look at
information bearing upon the handling of dross and skimmings
after removal from the solder bath. The information, as well as
the issues raised about classifying dross in the future under
RCRA, are also relevant in the broader context of revisions to
the definition of solid waste. He hope to publish an Advance
Notice of Proposed Rulemaking discussing these revisions by the
end of the year, to engage public debate on these important
questions. Many of the Issues you raised in your October 2
letter are part of larger questions, such as whether to use the
regulations as a tool to encourage safely conducted resource
recovery.
Therefore, until we have gathered more data on the
industry's practices (both at generator sites and recycling
facilities), we will continue to treat solder drosses generated
from soldering printed circuit boards as by-products, rather than
' "as spent materials. As a result, solder drosses from printed
circuit board manufacturing that are reclaimed would not have to
be managed as solid or hazardous wastes under RCRA regulations
(40 CFR 261.2). Please note that this letter relates only to the
federal hazardous waste regulations. States may have
requirements that are more stringent or broader in scope; thus,
you would need to contact individual states to determine their
requirements in a specific situation.
With respect to the particular solder drosses in question,
this letter is based on specific factual circumstances, including
your reliance on prior Agency statements. Thus, this letter has
no application to other industries or materials.
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3
ThanJc you once again for your interest in this natter. If
you have further questions please contact David Bussard of ny
Staff at (202) 260-4637.
Sincerely yours,
Don R. Clay
Assistant Administrator
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9441.1991(19)
RCRA/SUPERFOND HOTLINE MONTHLY SUMMARY
DECEMBER 1991
1. Reclaimed Spent Wood Preservative
Exclusion in 40 CFR Section 261.4(a)(9)
In the December 6,1990, Federal Renter (55
FR 50450), EPA promulgated hazardous waste
listings for three wastes generated from wood
preserving processes: F032. F034, andF035.
These listings include spent wood preserving
solutions which are often collected on drip pads,
reclaimed (usually by means of filtration or oil!
water separation), and reused again in wood
preserving processes. If a wood preserving facility
uses reclaimed spent preservative (F032. F034, or
F035) to treat wood products which are
ubsequently placed on the land, would the
reclaimed spent preservative be regulated as a
hazardous waste under the derived-from rule (40
CFR §261J (c)(2)) since it is derived from the
treatment (reclamation) of a listed waste?
No. Although in the general case, materials
reclaimed from hazardous wastes that are used in a
manner constituting disposal continue to be
rcguiaied as solid and. if hazardous, hazardous
wastes, an exclusion from regulation as solid and.
thus, as hazardous wastes was promulgated with
the new listings for reclaimed spent wood
preserving solutions that are reused for their
intended purpose.
Generally, the derived-from rule in 40 CFR
§261.3(c)(2) classifies any solid waste derived
from the treatment, storage, or disposal of a listed
hazardous waste as that hazardous waste. There is
in exception to this rule. In §261J(c)(2)(i). a
material that is reclaimed from a hazardous waste
and used beneficially, e.g., used as a product, is
no longer considered a solid waste, and thus is
not a hazardous waste. This exception does not
apply, however, when a reclaimed material is
used, burned for energy recovery, or used in a
manner constituting disposal. Because in this
case the wood products treated with the reclaimed
wood preserving solutions are placed on the land
(used in a manner constituting disposal), the
§261.3(c)(2)(i) exclusion would not apply to the
reclaimed preservatives or to die treated wood
products. Thus, the preservatives and the wood
products would be regulated as derived-from
listed hazardous wastes. In the December 6,
1990, final rule, however, the Agency stated that
"regulating reclaimed spent preservative and
products made with reclaimed spent preservative
was not and is not EPA's intent." To implement
this intent, an exclusion from the definition of
solid waste was promulgated under §261.4(a)(9).
which excludes from the definition of solid waste
those spent wood preserving solutions and waste
waters that have been reclaimed and will be
reused for their original intended purpose. Thus,
under 40 CFR §261.4(aX9), once spent wood
preserving solutions axe reclaimed and have been
returned to the process (Le^ the wot tank), the
reclaimed solutions used for their intended
purpose (wood preserving) axe not solid wastes
and thus not hazardous wastes.. Note that this
exclusion does not apply to the recycling process
(the recycling unit would be exempt-from
permitting under 1261.6(c)), or to any prior
management of die spent preservative. Also. no:e
that the wording of the §261.4(a)(9) exemption
was corrected in the July 1.1991. Federal
Rggjster notice. (56 ER 30192).
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Volume 5
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 5
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en* muriwct* i AL rKU7 fcCTlON AGENCY
0AT6 tic ¦ S^BC 2 i 084
9442.1984(01)
subject RCRA Regulatory Status of Contaminated Groundwater
p ROM	.
John Skinner, Director
I&LiX'V-v (-7^
Office of Solid Waste (WH-562)
T0 James Scarbrough, Chief
Residuals Management Branch, Region TV
The memo dated July 20, 1984, which you retransmitted
December 1, 1984, explores the regulatory status of contaminated
ground water. Actually, the issue is not whether groundwater
that contains Appendix VIII constituents is a hazardous waste,
because generators do not use Appendix VIII tio* identify hazardous
waste. Rather, EPA designates solid wastes that contain Appendix
VIII constituents as listed hazardous waste after considering
the criteria listed in 40 CFR 5261.11(a). Then a generator
identifies hazardous waste using the criteria listed in 40 CFR
§261.3(a) and the decision matrix of 40 CFR S262.ll.
Thus, to answer the question: "Is ground water contaminated
by hazardous waste considered to be hazardous waste?" one uses
the criteria in 5261.3 to see if the water was a solid waste,
and either derived from listed waste or hazardous by characteristics
identified in Subpart C. Note that 5261.3(c)(2) says that any
solid waste generated frcra the treatment, storage or disposal of
a hazardous waste is a hazardous waste, and 5261.3(d) says a
waste is no longer hazardous when it no longer exhibits the
characteristics of hazardous waste identified in Subpart C or
until a listed waste (or waste derived from listed waste) has
been excluded under the petitioning process.
Therefore a contaminated groundwater that is "collected"
and derived from listed waste or hazardous by characteristic
is a hazardous waste and subject to Subtitle C regulation.
However, the reauthorization bill allows underground injection
of contaminated ground water that has been treated to substantially
, "reduce the hazardous constituents.
Of*course, the implications on permitting, interim status
compliance order corrective actions, and treatment of ground
water will need to be studied. If you have any further questions,
do not hestitate to contact Irene Horner of my staff at 382-4804.
cc Hazardous Waste Branch Chiefs, Regions I-III and v-x
Gene Lucero, Enforcement
C PA Parat 13304 (!•». 1«74)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9442.1990(02)
NOV Biggo
Mr. Michael Paessun
Wadsworth/Alert Laboratories, Inc.
4101 Shuffel Dr. N.W.
North Canton, OH 44720
Re: Bias correction on TCLP
Dear Mr. Paessun:
Me are pleased to respond to your concerns regarding the
application of bias correction for the TCLP. This response will
supplement our initial responses to questions from your company
(communication with Mr. Marvin Stephens) and hopefully will cover
all of your concerns.
The issue of bias correction was covered in the TC final
rule of March 29, 1990 (55 FR 11875). A restatement of the
requirement to correct for bias and a description of the method
for bias correction was issued in the June 29, 1990 correction
notice (55 FR 26993), to clarify the intent as well as procedure.
He would also like to respond to your specific questions:
1.	The TCLP method does indeed apply to both the Toxicity
Characteristic program and the Land Disposal Restrictions
program. Any time the TCLP is required, any and all
requirements within the procedure must be met. Zt should be
noted that the limits set in the Land Disposal Restrictions
program were established based on data which was corrected
for bias.
2.	All TCLP analytical results are to be corrected for
bias, including those which fall below the treatment
standards. This is indeed the intent of spike recovery. In
some cases the method (or laboratory/analyst) may
underestimate the true concentration. It is for that reason
that it is critically important that the spike recovery
correction factor be applied when the results are less than
the treatment standards.
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3.	Data collected before the mandatory date would not be
subject to correction for analytical bias to comply with the
toxicity characteristic ruling. However, it should be noted
that the facility may be liable for proper disposal of any
waste which was improperly identified. After September 25,
any hazardous waste determinations should be based on the
TCLF with bias correction.
4.	If you wish to supply information on the impact of bias
correction on generators of hazardous waste, I suggest you
send this information to:
Steve Cochran
Chief, Characteristics Section
OS-331
401 M Street
Washington, DC 20460
I hope we have been responsive to your questions. If you
need additional information on the Toxicity Characteristic Rule,
please contact Steve Cochran at 382-4769 or contact Jeanne
Hankins at 382-4761 for questions on bias correction.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^2 1990(03)
NOV I 9 1990

RANDUM
SUBJECT: Request for US EPA Headquarters Assistance in Selection
of Non-US EPA Approved Methods for RCRA Subpart X Permits
FROM: David Bussard
Director
Characterization and Assessment Division (OS-330)
TO:	Terry L. Anderson
Chief
RCRA Implementation Branch
US EPA, Region VIII
This memo is in response to the request by Terry Anderson,
Chief of the RCRA Implementation Branch, Region VIII, for Office
of Solid Waste (OSW) headquarters guidance on appropriate
analytical methods for the analysis of the following eleven
compounds (with CAS Nos.), in air, from open burning/open
detonation, for which no approved USEPA methods apparently exist:
Cyanogen chloride	(506-77-4)
1,1-Diethylhydrazine (616-40-0)
1.1-Dimethylhydrazine	(57-14-7)
1.2-Dimethylhydrazine	(540-73-8)
Ethyleneimine	(151-56-4)
Hydrazine	(301-01-2)
Hydrogen cyanide	(74-90-8)
Methylhydrazine	(60-34-4)
Nitric oxide	(10102-43-9)
Toluene diisocyanate	(584-44-9)
o-Toluidine hydrochloride (95-53-4)
United Technologies advocates the use of Draeger tubes for these
analyses, while Region VIII advocates the use of supercritical
fluid chromatography (SFb).
From our experience, OSW agrees with the Region VIII position
that Draeger tubes are inappropriate for use in this application,
because they are prone to giving false negative responses.
However, it is also our opinion that SFC is inappropriate as well
for this application. SFC is am unproved technique for
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environmental analyses, and shows little promise of future
applicability, particularly for the above list of compounds.
Therefore, SFC has a low priority in OSW's methods development
program.
Toluene diisocyanate and o-toluidine hydrochloride (as o-
toluidine) can be determined by SW-846 Method 8270. They should
also be amenable to sample preparation by one of the methods listed
in the "Compendium of Methods for the Determination of Toxic
Organic Compounds in Ambient Air", EPA-600/4-84-041, and its
subsequent updates, originally issued in April, 1984 by EPA's
Atmospheric Research and Exposure Assessment laboratory in Research
Triangle Park, North Carolina. Methods for nitric oxide and other
gases in air may be available from the Office of Air Quality,
Planning and Standards (OAQPS) in Durham, North Carolina. OAQPS
has published a number of ambient air methods in the Federal
Register as a part of their regulations.
Other sources of applicable methodology for analysis or
monitoring of these compounds in ambient air include the
manufacturers of the compounds in question and the National
Institute for Occupational Safety and Health (NIOSH). The
manufacturers need to monitor the quality of their products through
assay methods, and also to monitor air exposure of their workers
to these compounds during the course of the manufacturing process.
Exposure monitoring methodology is a specialty of NIOSH, and they
publish many volumes of analytical methods. Manufacturers of the
compounds of concern should be found in the trade publication
"Chemical Sources", which is commonly used by chemical purchasers.
If we can be of further assistance, please feel free to call
Barry Lesnik of my staff at FTSt 382-7459.
cc: Chet Oszman
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9442.1990(04)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
NOV I I39D
OFFICE OF
SOUD WASTE AMD EMERGENCY RESPONSE
Mr. Michael C. Stroh
Trace Organics Supervisor
PDC Laboratories, Inc
P.O.Box 9071
Peoria, II 61614
Dear Mr. Stroh:
Here are my answers to the QC questions you raised in your
October 19, 1990 letter to me.
You indicated concerns raised recently with your data raised
during permit reviews. In the Environmental Protection Agency,
the responsibility for performing such reviews is a Regional one
not a Headquarters one. While I will offer my technical
observations on the matter shortly, I urge you to contact Region
V (Ms Valerie Jones, Quality Assurance Officer) for Official
guidance. I appreciate that PDC intends to comply with EPA's
intent with regard to QC issues, while offering competitive,
legally and scientifically defensible analytical services to your
clients.
Matrix spike recovery intends to furnish two important pieces
of information in the analytical process. First, it will assist
you in ascertaining and correcting for co-extracted artifacts which
attenuate the analytical procedure's quantitation — analytical
-bias compensation. Secondly, it will assist you in determining if
the particular analytical scheme is applicable to the specific set
of conditions presented by particular samples to your laboratory.
As you will see, my subsequent answers to your questions are
consequences of these two uses of matrix spike recovery data.
Your choice of, "performing a matrix spike on every waste's
TCLP extract" is within the scope of the June 29, 1990 TCLP rule.
As you are aware the similarity of samples is more than simply
being a TCLP leacheate, and more than being just a solid, liquid,
or sludge type waste, and probably quite process specific. Over
time your historical data might be marshalled to demonstrate that
various waste types really are identical with respect to matrix
spike recovery of a given analytical method. You have made the
most prudent choice for now.
Prinude*lUcycU4Pap*r
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The proper reporting of non-detected analities is of concern.
The Unit of detection will vary depending on the analytical matrix
as well as the cumulative effects of reagents, technique,
procedure, and materials. The matrix spike provides a means of
adjusting the level of detection, a compensation for analytical
bias. When it is applied, it may as you indicate, "force the waste
generator to either certify for that compound, or manage the waste
as hazardous." When faced with this situatation, you can, it seems
to me elect anomg several alternatives:
o Repeat the analysis
o Change the process, analyst, equipment handling,
cleaning, reagents, instrumental calibration
schedule
o Choose a different analytical scheme
The point being that one is much better off with a positive,
identified, measured, constituent than a non detect. If I confused
you when we talked, I hope it is clear now. Actually, the way that
you were operating is quite acceptable. But it would be incorrect
to substitute the QC check standard for the matrix spike.
Because the QC check standard provides different information
than the matrix spike, it is not possible to substitute one for
the other. The QC check standard, reports the degree of control
that exists in performing the analytical process within the
laboratory. On the other hand, the matrix spike reports the
adequacy of the methodology in estimating the true value in a given
set of samples. In those instances when the matrix spike
associated with a particular batch is below that expected in the
method, you need to correct the sample result or alter the process
or select a different method. If the QC check sample shows the
method to be in control, it seems to me, that you may need to use
a different method (assuring yourself that it too is in control) -
- hopefully one that has a better recovery.
I hope that my comments have been helpful. They are intended
' to be technical information only. Please seek approval from Region
V. Also feel free to call me with any further questions you may
have (201-382-4761).
Sincerely yours,

Charles Plost
Senior Chemist
Technical Assessment Branch
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9442.1990(05)
m
I ^77 I	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OCT 30 1990
OFFICE OF
SOLID WASTE AND EMERGE
tES'ONSE
*P!*L*
)RANDPM
SUBJECT:
FROM:
TO:
Regulatory De
Sylvia Lowra;
Office of Solid
f
Used Oil Filters
Robert L. Dupre^f, Director (8HWM-RI)
Hazardous Waste Management Division
SPA Region VIII
Thank you for your memorandum of August 30, 1990, requesting a
regulatory interpretation of the status of used oil filters under the
new Toxicity Characteristic (TC). In your memorandum, you inquired
about used oil filters that are crushed in vehicle maintenance shops,
where a certain portion of the residual used oil in the filter is
separated from the filter. The answers to the specific questions you
isked are listed below.
1.	The Toxicity Characteristic Leaching Procedure (TCLP) is
performed on used oil filters by crushing, cutting or grinding the
waste (filter plus contents) until the pieces are smaller than 1
centimeter in their narrowest dimension (and thus are capable of
passing through a 9.5 mm standard sieve). See Step Mo. 7.3 of the
TCLP. The surface area criterion referred to in Step 7.3 does not
apply to used oil filters. (Note: If the generator recycles both the
used oil and metal, you do not need to test because recycling of both
types of materials is exempted from hazardous waste regulation as
discussed below.)
2.	and 3. Assuming a used oil filter exhibits the TC, you had
inquired whether the act of crushing filters is regulated treatment
or exempt recycling. Generally, the types of used oil filter
crushers you described would not be regulated if the used oil was
being recycled (see 40 CFR 261.6 (a) (2) (iii) and (a) (3) (iii)). That
is, since the purpose of the crushing is to remove the used oil for
recycling, £re view the crushing to fall within the used oil recycling
exemption. The crushing may be performed on- or off-site, for profit
or not. The determining factor is whether the used oil will be
recycled. The filter may be shipped off-site for crushing under the
used oil exemption, providing the oil is collected for recycling.
Ihini • I j M	¦*	
FrwtKm mm	mWfm
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3
Finally, in the sales brochures you sent, there was mention of
an open container used to accumulate the used oil after the filter
was crushed. (Currently, used oil accumulation by generators is not
regulated if the used oil is recycled, but EPA did propose that such
containers be kept closed. See SO ££ 49252, November 29, 1985.)
Storage or accumulation of characteristically hazardous used oil is
regulated if the used oil is to be disposed of} in that case, the
containers must be closed except vhen adding or removing the used oil
(per 1265.173(a)).
Please contact Daryl Moore at (202) 475-8551 if you have any
additional questions on the applicability of the Federal hazardous
waste regulations with respect to used oil filters.
cc: Waste Management Division Directors, Regions I - VII and IX - X
Jeff Denit
RCRA/Superfund Hotline
Regional TC Contacts
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UNITED STATE5~EHV(R[DKMEHT&L' PROTECTION AGStCV' 9A42 1991(01)
!-
-------
In summary, the information you received at the Mississippi
Valley Conference regarding the use of the IP test versus the
TCLP with respect to leaded paint sandblasting waste was, as you
have also determined, inaccurate. The only circumstance that
exists where there is an option of using either the TCLP or the
EP is when measuring compliance with the treatment standards for
certain arsenic- and lead-containing hazardous waste.
As for the information you received from Mr. Jack Kollmer at
the November 9, 1990 luncheon, regarding the acceptance of the EP
Toxicity test for "one time operations" which includes bridge
paint removal, this was also inaccurate.
Of course, state and local agencies may have additional
regulations that differ. The appropriate EPA Regional office or
State and local regulatory agencies should be contacted for
additional assistance or clarification.
If you have further questions regarding the TC rule, please
contact Steve Cochran at (202) 475-8551.
Sincerely yours,
David Bussard, Director
Characterization and Assessment Division
ftp
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UNITED STATES ENYIRONMENTAL PROTECTION AGENCY
9442.1991(02)
FEB 2 2 199!
Mr. Herschel Cutler t
Institute of Scrap Recycling Industries, Inc.
1627 K Street, NW
Washington, DC 20006-1704
Dear Mr. Cutler:
I appreciate your providing us with the documentation of your
analyses of the fluff materials. We are returning the
documentation, per your request. Please note that in order to make
a copy for our records we were obliged to remove the binding. I
trust this will not be too great an inconvenience.
The comparison of the results between our contractor (MRI) and
your contractor (BCM) indicated a difference in some of the
results, as you had previously pointed out. BCM1s EP Tox results
were approximately 3-30 fold lower than those from MRI for lead
and approximately 2-10 fold lower for cadmium. The TCLP results •
were generally comparable, although BCM did have two significantly
lower lead values and one lower cadmium value.
The attached report describes the evaluation we conducted of
the analytical documentation from both BCM and MRI. I would like
to highlight those areas we thought were most noteworthy.
Since pH is one of the key factors effecting the leachability
of metals into an aqueous medium, we have carefully reviewed the
data provided by both laboratories with special attention to the
pH data.
For the EP Tox procedure, it is necessary to adjust the pH to
S.O +/• 0-2 with an acetic acid solution (see attachment for
details on procedure). MRI provided full documentation of the pH
adjustment step, including the pH values before and after each
adjustment. BCM did not provide documentation of the pH values
after adjustment for some of the samples. Therefore, it was
difficult to fully evaluate the impact of this step in a
comparative manner. Data from BCM indicates that the pH before
each adjustment was much higher than 5.0 +/- 0.2, and this may
indicate that overall, the pH was higher in the samples leached by
BCM than MRI. That may be one reason that the concentrations of
lead derived from the EP Tox test as performed by BCM were
significantly lower than MRI's. Also, during the on site review,
a discussion with BCM personnel indicated that, due to the large
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quantity of acid required and the time involved, a decision was
made to lower the pH to only 5.2. This is the upper limit of the
allowable pH range, and this factor may also help explain the lower
levels of lead found in the samples analyzed by BCM. (Details
provided in attached report.)
When using the TCLP procedure, a selection must he made
between two different extraction fluids. This selection is made
based on the pH of the material. In two cases MRI used extraction
fluid #2, whereas BCM used extraction fluid #1 in all cases. For
both of those samples where MRI used extraction fluid #2, MRI
reported a higher concentration of lead than did BCM. The use of
extraction fluid #2 for these samples had no apparent effect on the
concentration of cadmium. MRI provided data to support the use of
extraction fluid #2, while BCM provided no data to indicate which
fluid should be used. (See attached report.)
Relatively minor analytical anomalies were noted in some of
the data submitted by both laboratories. It is the opinion of the
reviewer that the anomalies would not make a major contribution to
the differences observed. However, these are also included in the
attached report.
He conclude that the data provided does not support the
contention that the TCU» is a more aggressive test than the EP Tox.
We are aware that laboratories do have more difficulty in using
the EP Tox, and we feel that this study emphasizes that
observation. Data from MRI show that the results are roughly
comparable between the EP Tox and the TCLP. We do not believe that
the documentation provided by BCM is adequate to support the
proposal that the two leaching procedures are not comparable.
We appreciate your participation in this comparison study.
We feel it has provided further clarification of our reason for
replacing the EP Tox with the TCLP. If you have any questions on
this evaluation, please contact Alec McBride on 382-4761.
Sincerely,
David Bussard
Director
Characterization and Assessment Division
cc: Alec McBride
Jeanne Hankins
Gail Hansen
Steve Cochran
John Sealera, OTS
Dan Reinhart, OTS
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review of data on fluff samples
This review covers all the data provided by both BCM and HRI.
The data was reviewed for internal consistency# calculation errors,
compliance with the method, and quality control measures.
BP TOX
PH DETERMINATION
After addition of the waste and the distilled water into the
extractor, the pH must be measured and then adjusted if it is
greater than 5.2. The pH must be monitored during the course of
the 24 hour extraction period according to the following schedule:
adjust the pH of the solution in 15-, 30-, or 60-minute
intervals, moving to the next longer interval if the pH
does not have to be adjusted more than 0.5 pH units.
*	continue the adjustment for at least 6 hours.
•	if, at the end of the 24 hour extraction period, the pH
of the solution is not below 5.2, and the maximum amount
of acid has not been added, the pH should be adjusted to
5.0 +/- 0.2, or until the maximum allocated amount of
acid is utilized, and the extraction continued for an
additional 4 hours, during which the pH should be
adjusted at 1 hour intervals.
Data forms provided by MRI allowed for simple and easy
determination of the pH adjustment process. The following
information was included: time and interval, pH before and after
adjustment, volume of acid added and cumulative amount, post 24
hour adjustment, and final volume of water added.
Data provided by BCM was difficult to comprehend. Only in
„some cases was the time and/or interval indicated. In those cases
* where the pH was provided, it was apparently the pH before
adjustment with the acetic acid solution. It was not possible to
determine what the pi was at the end of each adjustment or at the
end of the 24 hour period and whether the leaching period was
extended an additional 4 hours if the pH was greater than 5.2. It
was also unclear whether there was any addition of water at the end
of the leaching period.
It was noted that the volume of acid added by BCM was
approximately two fold greater than that added by MRI, which could
indicate a difference in concentration of the acetic acid reagent.
Otherwise, one would expect the BCM results to show greater
leaching. The incremental volumes themselves frequently differed
by approximately a factor of 10, most notedly at the initiation of
the leaching procedure. MRI in most cases adjusted the pH very
1
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close to 5.0, with two excursions below 4.8 (duplicates of sample
5,5 were adjusted to a pH of 4.71 and 4.45 initially). Since BCM
did not provide pH data after the addition of acid, it is not
possible to determine whether the adjustment procedure affected the
amount of leaching. Conversations between BCM personnel and the
on site observers from EPA indicated that the pH adjustment was
stopped at a pH of 5.2 due to the large volume of acid added and
the extended length of time for adjusting the pH. The pH
recordings (presumably before adjustment) which were documented by
BCM were much higher than 5.2. This might mean that the amount of
lead or cadmium extracted could be lower because of a higher
overall average pH during extraction.
In summary, there are several apparent inconsistencies. MRI
added smaller increments of acid, a smaller total volume of acid,
but, in those cases where it was possible to make a comparison with
BCM, MRI samples had a lower pH at the end of the 24 hour leaching
period. It should be noted, however, that in no case did data from
MRI or BCM show that the pH was less than 5.2 at the end of 24
hours. Therefore MRI continued the leaching procedure for an
additional 4 hours as per the method, which may have increased the
amount of lead and cadmium leached from the fluff. It was not
possible to determine if BCM had an additional 4 hour extraction
period.
TCLP
Extraction Fluid Selection
In order to determine the appropriate extraction fluid for
the TCLP, one must use the following procedure:
Weigh 5 g of the solid phase of the waste (particle size
1 mm diameter) into a 500 mL beaker or flask.
Add 96.5 mL of reagent water to the beaker, cover with
a watch glass and stir for 5 minutes.
Measure and record the pH. If the pH is less than 5.0
use extraction fluid #1.
• If the pH is greater than 5.0, add 3.0 mL 1.0 N HC1,
cover with a watch glass, heat to 50* C for 10 min. ? let
cool to room temperature and record the pH.
If the pH is now less than 5.0, use extraction fluid #1.
If the pH remains greater than 5.0, use extraction fluid
#2.
MRI provided information which detailed the pH values at each
step. Based on the pH, two of the samples were extracted with
fluid #2: samples 3,12 and 5,5. BCM used extraction fluid #1 for
2
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all samples, and did not provide any documentation of pH checks.
The lead analyses of these two samples revealed significant
differences in concentration, but the cadmium results were not
significantly different.
Sample 6,4 had a higher concentration of lead and a lower
concentration of cadmium when analyzed by BCM as compared to MRI.
No differences in procedure were noted that might have accounted
for this inconsistency.
In summary, the differences noted in the TCLF results for lead
analyses in samples 3,12 and 5,5 would appear to be due to the use
of different extraction fluids. Further information is needed to
determine whether the correct extraction fluid was selected by BCM.
The data does not indicate any variation in method for the
differences noted in sample 6,4.
ANALYSIS BY FLAME ATOMIC ABSORPTION SPECTROMETRY
MRI documented instrument drift in several instances when
using flame atomic absorption spectrometry (FAAS). Logbooks from
MRI describe the techniques used to compensate for the drift,
including 1) manually establishing the baseline from the strip
chart recorder and 2) subtracting the blank from the preceding 10
samples. The second practice is not recommended as it would tend
to inappropriately lower the concentration in the samples analyzed
first. Strip chart recordings would be needed to verify
concentrations under the first condition.
Examination of the BCM data also indicated possible instrument
draft. Several QC samples had to be reanalyzed before they met QC
limits. Also, several analytical runs were missing from the
package. No explanation was given for these anomalies. Other
observations include the following: Zn the initial calibration for
lead, BCM did not use the 25 mg/L sample to establish the
calibration curve. During the cadmium analysis, the auto-zero
_ »-• function was initiated after calibration. MRI had a high spike
recovery (approximately 10% higher than expected) for cadmium in
sample 6,4. Reanalysis confirmed the high recovery.
In summary, the data from MRI may be biased low for cadmium
in IP Tox, based on the technique for compensating for baseline
drift. Cadmium results for the TCLP leachate of sample 6,4 by MRI
may be biased high. However, the effects of these biases on the
results would be relatively minor, probably no more than +/~ 10%.
Further information would be needed to understand what effect the
anomalies found in the BCM data would have on the bias of any
results.
3
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GRAVIMETRIC DATA
Both the EP Tox and the TCLP require the use of a 100 g
sample which must be weighed out before commencing the procedure.
BCM provided data on the weight determination of seven samples.
Several errors were identified (6 of 7). Although these errors
would have only a nominal effect on the overall accuracy of the
results it indicates a potential weakness in the quality
assurance system. The following data compares the results
calculated by BCM and the EPA reviewer:
Results for all other weight determinations were not provided by
BCM nor KRI.
SAMPLE WO
BCM
100.23
100.31
100.35
100.85
100.38
100.16
100.32
SPA
99.40
99.73
100.35
100.70
100.08
99.55
100.73
2,5
2,5
2,4
2.4
2,12
2,12
3.5
4
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9442.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
I 9 1991
omct of
SOLID WASTE ANO EMERGENCY RESPONSE
Ms. Kelly S. Swanson
Quality Assurance Officer
Analytical Technologies, Inc.
11 East Olive Road
Fensacola, FL 32514
Dear Ms. Swanson:
I would like to clarify the issue of when to add the
matrix spike in the TCLF procedure.
Because the concentration of the contaminant in the sample
is completely unknown, a matrix spike, i.e., a predetermined
quantity of certain analytes is to be added to each.sample matrix
prior to sample extraction/preparation. This is done to monitor
the performance of the analytical method as well as the sample
preparation method and to estimate the extent to which matrix
bias or interferences reduce the measured value of the
contaminant.
Section 8.2.3 emphasizes monitoring the analytical procedure
as opposed to the leaching procedure. It is to be emphasized
that the spike monitors the analytical and preparation
procedures, i.e., analytical method encompasses both the
preparative and determinative steps.
Thank you for your inquiry about spike recovery. 1 am
available to discuss this further, should you wish. My phone
-number is 202-382-7458.
cc
Alec McBride
Jeanne Hankins
Joe Freedman, OGC
Hugh Davis, OWFE •
Steve Cochran
RCRA-Hotline
TAB-Hotline
Sincerely yours
Charles Piost, Acting Quality
Assurance Officer

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i £5 \
f 25S I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
9442.1991(04)
0**.C6 Of
S0i.«0 WASTE AND EMEIGEMCV AES»ONSE
March 25, 1991
Mr. Richard S. Leonard
Quality Assurance Director
National Environmental Testing, Inc.
Woodland Falls Corporate Parle
220 Lake Drive East
Suite 301
Cherry Hill, NJ 08002
Dear Mr. Leonard:
The purpose o£ this letter is to clarify some of the
discussion in my letter of August 14, 1990 to you (copy enclosed)
which was sent in response to your letter of August 1, 1990.
Specifically, I would like to revise the response to question
number 4. The original question and the revised response are as
follows:
Question 4: Our clients complain that when we dilute a
sample (e.g. oil or solvent matrix) to obtain
results that meet quality control
requirements, that the data so obtained are
"useless" because of the high reporting
limit. How do we generate analytical data
for compliance decisions when dilution must
be performed?
Answer: First I want to clarify that, at least with
respect to used oil that is destined either
for recycling or to be blended as fuel, there
is no need on the part of the generator to
run a TCLP since these wastes are eligible
for the used oil exemption (see 40 CFR
261.6(a)(2)(iii) and (a)(3)(iii). In the
case of oily waste that is to be disposed or
* solvent wastes, it is required that
generators determine if their waste is
hazardous using either knowledge of their
waste and/or the process that generated it or
by testing. If they choose to test, then
they must use Method 1311 (TCLP). The Agency
is aware that running the TCLP on matrices
involving oily wastes and organic liquid
Pmttdon RecyciedP
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wastes nay result in labs being unable to
. determine conclusively that the waste is or
is not hazardous. In those cases, the
generator must use his/her knowledge to make
this determination. Where no additional
information or knowledge is available, it
would probably be prudent for the generator
to manage those wastes as hazardous wastes.
Please note that in the case of liquid
organic wastes, it is possible that these
wastes may already be hazardous by virtue of
a hazardous waste listing (e.g., spent
solvents, hazardous wastes codes F001 -F005),
in which case the hazardous waste
determination with respect to the TC becomes
much less critical (e.g., you would be
determining if additional wastes codes
applied to the waste instead of making the
critical hazardous waste determination). I
would also add that the Agency is aware of
analytical problems associated with oily and
organic liquid wastes and is investigating
ways to solve them.
I would like to apologize for any misunderstanding or
confusion which may have resulted from my earlier response, and I
hope this revised response addresses your concerns. If you have
any additional questions related to this or other TC/TCLP issues,
please feel free to call Steve Cochran at (202) 382-4770.
Sincerely yours,
J&jL (r*+. 7JLn4M'
Alec McBride, Chief
Technical Assessment Branch
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
m 27 1991
9442,1991(05)
Aaron H. Goldberg, Esq.
Beveridge and Diamond, P.C.
Suite 700
1350 I Street, N. W.
Washington, D. c. 20005
Dear Mr. Goldberg;
Thank you for your letter of January 25, 1991 concerning our
methods for ignitable liquids.
In defining an ignitable liquid hazardous waste under RCRA,
the Agency's regulations state that flash point should be
determined by either one of two specified methods, or by any
other method which might be approved by the Administrator. Only
one test method needs to be applied. The choice of the method
should be based on the applicability of the method to the
material being tested. In this case, one might consider
viscosity, among other things, in making the appropriate choice.
Z hope that this has clarified the intent. If you need
further assistance, please call Charles Plost of my staff at
(202) 382-7458.
,	Sincerely yours,
David Bussard, Director
Characterization and Assessment Division
cc Steve Cochran
Joe Freedman, OGC
Joe Xn>	1 a
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MAY 9 199]
9442.1991(06)
Nicolas H. Roelofs, Ph.D.
Nevada Environmental Laboratory
1030 Matley Lane
Reno, Nevada 89502
Dear Dr. Roelofs:
I am writing in response to your letter of May 1, 1991, to
David Bussard regarding the differentiation and equivalency of
Methods 8240 and Method 8260.
As you are aware, both methods are determinative procedures
for the analysis of volatile organics by gas chromatography/mass
spectrometry. The two methods are very similar and differ
primarily in the gas chromatographic column used to effect
separation. Method 8240 utilizes packed columns, where Method
8260 utilizes open tubular capillary columns.
The two types of gas chromatographic columns both provide
separation of analytes targeted for analysis, but are not
technically equivalent in their separation ability. Zt is Agency
policy to allow the substitution of equivalent or superior
materials within the analytical procedures of SW-846 unless
otherwise specified in regulations. For example, Method 8240
, Section 4.12.2 allows the substitution of equivalent packings.
Furthermore, Method 8000 Section 4.2 permits other packed or
capillary columns to be used provided the performance test
requirements of Section 8.6 have been met. Therefore, capillary
columns (with or without cryogenic cooling) may be substituted
for the packed column of Method 8240, if the ability to generate
acceptable accuracy and precision by Method 8000 Section 8.6 has
been demonstrated.
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We are aware that the delay in promulgating the methods of
the first update package has added further complications
regarding the utilization of Method 8260, which has not been
promulgated in its final form. He are expediting the final
promulgation of the methods contained in the first update package
to remedy this situation as soon as possible. If you have any
questions on this issue, please contact John Austin at (202) 382-
4761.
Sincerely,
Alec McBride, Chief
Technical Assessment Branch
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9442.1991(07)
Mr. Timothy J. Anderson
Corporate Senior Project Engineer
Environmental Affairs
Rayovac Corporation
601 Rayovac Drive
P.O. BOX 4960
Madison, wi 53711-0960
Dear Mr. Anderson:
Z aa writing in response to your letter of May 15, 1991
concerning your particle size reduction procedure for TCU» sample
preparation of dry cell batteries.
Your idea of using liquid nitrogen to freeze the samples
before grinding is very interesting. Freezing at those
temperatures would certainly tend to make the sample easier to
crush afterwards.
However, the TCLP states that one must collect a
representative sample of the waste as generated for analysis. We
have no way of knowing whether this type of freezing will alter
or affect the sample's physical or chemical composition (and
therefore its leaching potential) in some way. Since the
generator is ultimately responsible for making the determination
that a representative sample is collected for analysis, we cannot
make an up-front determination that this type of freezing is an
acceptable step in crushing batteries.
Zf you have any further questions, please call me at (202)
475-6722.
Sincerely yours,
Sail Hansen
Health Scientist
Methods Section (OS-331)
cc: Dave Bussard
Alec McBride
John Austin
Carrie Wehling, 06C
ECRA/Superfund Hotline
MICE Line
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UNITED STATES ESVIROKMENTAL PROTECTIOK AGENCY	9442.1991(08)
JJN 13 1991
Ms. Elaine McPherson
Technical Sales Representative
IT Corporation
17605 Fabrica Way
Cerritos, CA 90701
Dear Ms. McPherson:
I am writing in reference to your letter of April 11, 1991
concerning the handling of TCLP extractions as they apply to oily
wastes.
We do not recommend performing the extract on the oily waste
that passes through the filter as Margo Jackisch of SAIC
suggested to you. First of all, the TCLP determines release
potential in two steps, the first of which I will discuss here as
it specifically applies to your situation. The initial
filtration step separates, th
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2
generation of the waste to make a hazard determination or resort
to an alternative analytical method to get an answer. This has
been necessary with volatile organics. At this time, the Agency
is conducting studies of an automated headspace analysis
methodology coupled with isotope dilution mass spectrometry in
order to achieve greater analytical sensitivity for all TC
volatile analytes, including vinyl chloride. We suggest the use
of this approach.. Currently, only a working draft method (copy
enclosed) is available. Pending the outcome of Agency studies,
the draft method will toe revised and proposed for inclusion in
SW-846.
For further assistance, please call the MICE (Methods
Information Comiiunications Exchange-) at (703) 821-4789. Calls
are recorded on an answering machine and, for the majority of
questions, responses are provided within 24 hours. I hope this
information has sufficiently addressed your questions.
Sincerely yours,
Gail Hansen
Environmental Health Scientist
Methods Section (OS-331)
cc: David Bussard
Alec KcSride
Steve Cochran
Mike Petruska
John Austin
Cail HanBCR-*-^
Leon Lazarus, Region II
Hugh Davis, OWPE
RCRA/Superfund Hotline
MICE Line
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UNITED MAiU CNViKOrtMtNTAL PKOlfcCl »QN AOtNtT
9442.1991(09)
JUN I 9 1991	'
Esther L. Harper
Chen-Bio corporation
3.40 last Ryan Road
Oak Creek, WI 53154-4599
Dear Ms. Harper:
I am writing in response to your letter of June 12, 1991, in
which you request written confirmation of our phone conservation
regarding surrogate recovery.
In judging the validity of a data set, surrogate analytes are
used as indicators of the procedure's ability to recover the actual >
analytes of interest. Surrogates are used to demonstrate correct
sample preparation and the absence of matrix effects impacting the
recovery of the actual analytes of interest. The use of surrogates
is an integral part of many of the Agency's methods for the
measurement of organic analyte levels. The omission of surrogates
from an analytical procedure in which they are called for is a
deviation from the suggested or required analytical method.
It is frequently observed in the review of analytical data
that dilutions needed to achieve quantitation of the analytes in
a sample results in levels of surrogates which are no. longer
measurable. The omission or absence of measurable levels of
surrogates provides one less tool for use in the evaluation process
for the assessment of data useability. However, the absence of
-surrogate data does not in itself invalidate the analysis. If the
analysis still indicates that analytes are present at or above
regulatory action levels, then the lack of surrogate recovery data
would have little bearing on the use of the data. In the case of
no detectable analytes, then there is no assurance that the
individual sample was amenable to the preparative procedure.
Sincerely,
John Austin
Acting Chief
Methods Section
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9442.1991(10)
JUL 3 1991
Mr. Theodore W. Lund
Vice President
C/P Utility Services Company, Inc.
119 Sanford St.
Hamden, CT 06514
Dear Mr. Lund:
This letter is in response to your May 20, 1991 letter to
Mr. Alec McBride of my staff in which you requested information
and responses to questions concerning the Toxicity Characteristic
Leaching Procedure (TCLP) and lead paint removal debris.
Q: a. TCLP as a lead test method, is it applicable to paint
residues?
A: The Toxicity Characteristic (TC) rule requires waste
generators to determine whether constituent levels in their
waste sample extract, or leachate, exceed specified levels.
This determination can be based either on their knowledge of
the processes from which the waste was generated or by
application of the TCLP. The TCLP is not a test method
specifically for lead-containing waste, however, solid waste
containing hazardous constituents, such as lead, must be
tested with the TCLP unless the generator has enough other
knowledge to determine whether the waste is hazardous.
Q: b. What kind of sampling protocol should be used on drums,
roll offs and containers of abrasive mixtures?
A: It is important that you collect samples from drums, roll
offs, and containers of abrasive mixtures that are
representative of the waste. EPA has general sources of
guidance with respect to the development of a sampling plan.
These include "Petitions to Delist Hazardous Waste - A
Guidance Manual" (EPA/503-SW-85-003, April 1985) which
discusses the concept of representative sampling (section
7.1) and sampling techniques for various sampling
situations, such as how you would sample a waste contained
1 iSavEsSSn * llcappxicimie	, 9
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EPA realizes that sampling is a complex procedure and the
representativeness of the sample is critical to the accuracy
of the waste characterization. Therefore, we strongly
recommend that you contact the EPA Regional Office for your
area and the state and local regulatory agencies for
additional information or clarification on the appropriate
sampling protocol for your specific situations.
Q: c. Can on-site stabilization be done for these special
bridge projects throughout a state without establishing a
TSD facility?
A: Yes. Based on the above scenario and under the federal
hazardous waste regulations, on-site stabilization can be
conducted without establishing a TSD facility. EPA allows
for limited on-site accumulation or storage by a generator,
regardless of whether the hazardous waste is treated or not
treated, without the need of a permit or interim status (90
days for generators of 1000 kg/mo or more of total hazardous
waste and 180 (270 if waste will be transported 200 miles or
more from site of generation) days for generators of more
than 100 but less than 1000 kg/mo of total hazardous waste)
(see 55 £8 10168, March 24, 1986). In addition, generators
(in this case C/P Utility Services would be the generator)
must comply with all applicable Subtitle C requirements.
For example, on-site hazardous waste stabilization or
treatment processes must be conducted in accumulation tanks
or containers in conformance with the requirements of §
262.34 and Subparts J or I of Part 265. Generators not in
compliance with the above-prescribed requirements must
comply with all applicable RCRA requirements as a TSD
facility.
Q: d. Is it allowable to inject a percentage of iron shot into
a mineral abrasive to mask the lead in a subsequent TCLP
test?
A: The hazardous waste regulations do not restrict the use of
ingredients for the purpose of preventing waste from
exhibiting a hazardous characteristic. In fact, this could
be a desirable process change to make the waste less
hazardous. However, in this case, we understand that
introducing iron to the abrasive only temporarily prevents
lead from leaching from the waste, so it "masks" the lead,
but does not really change the character of the waste. If
your clients choose to do this, they should be aware of two
points:
2
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1)	If the waste passes the TCLP initially, but then
fails later prior to disposal, the waste is hazardous,
subject to all applicable hazardous waste rules.
2)	Zf the waste passes the TCLP and is disposed of as
non-hazardous waste, the generator may, nonetheless, be
held liable under CERCLA for any environmental damages
caused by release of the lead into the environment.
Q: e. Can the State DOT choose a central collection point to
accumulate waste from several projects?
A: Yes. If the State DOT determines that it is necessary that
a central collection point to accumulate waste from several
projects be established (e.g., in order to eliminate
transportation or traffic impediments), and the waste is
hazardous, prior to movement of the waste from each site
(i.e., "several projects") to a central collection point,
generators are required under the Federal hazardous waste
regulations to prepare a manifest. In addition, a
transporter must not transport hazardous waste without
having received an EPA identification number from the EPA
Regional Administrator. Furthermore, a transporter must
store manifested shipments of hazardous waste in containers
meeting the requirements of § 262.30 at the transfer
facility (i.e., "a central collection point to accumulate
waste") for a period of ten days or less in order to avoid
regulation as a TSD facility for storage of those wastes
(see 40 CFR 262.20, 263.11-.12).
I hope the responses to your questions are of assistance.
Of course, state and local agencies may have regulations that are
more stringent and would thus, as a practical matter, supersede
the Federal regulations. Furthermore, the answers to the
' "questions you raised are likely to vary from site to site and
from state to state depending on the particular situation and the
particular state's regulations. Therefore, I suggest that you
contact the state waste management agency where specific paint
removal activities are planned for relevant requirements and
regulatory interpretations. In addition, you may want to contact
the local EPA regional office, particularly if you plan on
activities within states which do not have approved hazardous
waste management programs.
3
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If you have any further questions, please contact
Daryl Moore of my staff at (202) 475-6721.
Sincerely yours,
David A. Bussard
Director
Characterization and Assessment Division
cc: Carrie Wehling, OGC
John Austin
Gail Hansen
RCRA/Superfund Hotline
MICE Line
4
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9442.1991(11)
UMTtD STATES ENVIF . .MEMTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL - 9 1991
^ ~ C;
50«-2	3- "o-l
Mr. Craig S. Campbell
Regulatory Analyst
Health and Environmental Affairs Department
American Petroleum Institute
1220 L Street, N.W.
Washington, D.C. 20005
Dear Mr. Campbell:
In response to a request made during a recent meeting with
Mr. Jim Greene of Mobil Corporation, we are providing you with the
following information on the methodologies employed in our 1989-
1990 used oil sampling activities.
To fill data gaps in the pre-1985 generated used oil
characterization data and to provide source-specific waste
characterizations using improved analytical techniques, EPA
initiated a sampling and analysis program in 1989. To accomplish
this, the Agency stratified the used oil universe into limited
categories based on the source and application of the used oil.
Seven used oil categories identified include: automotive crankcase
oils; diesel engine crankcase oils from trucks and buses, heavy
equipment, and railroads; hydraulic oils and fluids; metalworking
oils and fluids; electrical insulating oil; natural gas-fired
engine oil; and aircraft and marine engine oils.
The Agency developed sampling strategy by conducting
literature research, data base searches, and telephone interviews
with industry, State, and local officials, as well as telephone
book listings. Each facility identified as a used oil generator
was defined as a unit selected on a random basis in one of the used
oil categories noted above.
To use available funds effectively by focussing on the
analysis rather than the national representation of used oil
sample, the sampling activities were undertaken in the Washington,
D.C. area, unless samples of used oil from a specific segment could
not be obtained there. The sampling program was not intended to
characterize variations in used oil based on geographical location,
since it is assumed that no significant differences in constituent
concentrations are attributable to geographic area.
friMcrf m XteycUa P.
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When possible, samples of "as generated" used oil and facility
storage tanks or containers were taken. This allowed EPA to
determine "as-generated' constituent concentrations and the extent
of adulteration endemic to the generator.
The Agency developed field procedures to sample numbering and
labeling, equipment use and decontamination, sample protocols, and
sample containerization and preservation, as veil as documentation
of sampling activities. Chain of custody forms accompanied each
shipment of samples from the field to the laboratory.
The analytical program vas designed to characterize used oils
with respect to the compositional concentration of the constituents
of concern and with respect to the Toxicity Characteristic (TC).
In order to do this, the Toxicity Characteristic Leaching Procedure
(TCLP) was applied to used oil samples, and after filtration, the
liquid phase (filtrate) of the samples were analyzed for selected
constituents of concern using analytical methods from SW-846, "Test
Methods for Evaluating Solid Waste (Physical/Chemical Methods),
Third Edition," as noted in the table on the next page.
For volatile organic contaminants, the Agency found that the
traditional purge and trap GC/MS method (Method 8240) did not
provide detection limits that were sufficiently low. As an
alternative, the Agency has modified an existing headspace
screening method (Method 3810) to include isotope dilution. This
modified method includes the addition of several standard isotopes
that correspond to each of the target analytes. For semi-volatile
organics analyses, the Agency had similar difficulties. The
existing SW-846 methods were adequate for analyzing most samples,
but the used oil matrix required dilutions that yielded
unacceptable detection limits. To improve the detection levels,
the Agency utilized a specific ion monitoring (SIM) option on the
GC/MS. Instead of scanning the sample for a full spectrum of semi-
volatile compounds, the Agency found that analytes with lower
concentration could be easily detected using SIM.
Attachment 1 is a copy of the Sampling and Analysis Plan for
-the Characterization of Used Oil, and Attachment 2 is the table of
SW-846 Methods employed to characterize used oil. The results of
the sampling and analysis effort wili be publicly available at the
time of publication of the used oil proposed rule. Thank you for
your interest in EPA*s used oil program.
David Bussard, Director,
Characterization and Assessment Division
Attachments
2
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9442.1991(12)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MB 301991
MEMORRKDtm
SUBJECT: Lead Paint Removal Debris and the TCUP Procedure
FROM: David A. Bussard, Director
Characterization and Assessment Division
Office of Solid Haste (OS-330)
TO:	Toxicity Characteristic (TC) Rule Regional Contacts
Regions I - X
Since the promulgation of the TC rule (March 29, 1990),
there have been a number of generator and state inquiries
regarding the applicability of the TC rule (i.e., Toxicity
Characteristic Leaching Procedure (TCLP)) to lead-paint removal
debris. Specifically, questions have been raised regarding the
regulatory status of lead-paint removal debris that are generated
with a mineral abrasive which includes an additive which "masks"
(intentionally or not) the lead in a subsequent TCLP test, tie
anticipate that you will be receiving similar inquiries regarding
the regulatory status of the above-mentioned waste.
In summary, there are two scenarios that may exist regarding
the addition of agents or additives to mineral abrasives that are
used for lead paint abatement projects:
1.	Agents or additives that are mixed with the mineral
abrasive prior to the abatement process (i.e., before a
waste is generated) for purposes of preventing waste from
exhibiting a hazardous characteristic.
2.	Agents or additives that are mixed with the mineral
abrasive subsequent to the abatement process (i.e., after a
waste is generated) for purposes of preventing waste from
exhibiting a hazardous characteristic.
The purpose'of this memorandum and the attachment is to
provide you with a copy of a letter that responds to these and
other questions regarding the applicability of the TC rule and
hazardous waste regulations to lead-paint removal debris.
-------
Should you have any questions regarding the information in
the attachment, please contact Daryl Hoore of sty staff on
FTS 475-6721 or (202) 475-6721.
Attachment
cc: RCRA Branch Chiefs - Regions I - X
Nancy Brown (OWPE)
Frank McAllister (PSPD)
RCRA Hotline
3&u
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9442.1991(13)
OCT 0 199!
Dr. Irving K. Kipnis
Gascoyne Laboratories, Inc.
2101 Van Oerman St.
Holabird Industrial Park
Baltimore, MD 21224-6697
Dear Dr. Kipnis:
I am writing in response to your letter of September 13,
1991 requesting an exemption from the particle size reduction
step in the Toxicity Characteristic Leaching Procedure (TCLP).
The RCRA hazardous waste regulations allow a generator to
use his/her knowledge of a waste (which could include previous
testing data on wastes known to be very similar) or the processes
that generated a waste to determine if it should be regulated as
a hazardous waste. We do not require you to test. If you decide
to test for the Toxicity Characteristic, however, you must use
the TCLP (Method 1311). At this time, the particle size
reduction step is included in the TCLP, and laboratories are
required to follow the steps in the method. Because TCLP does
not explicitly describe how to reduce the particle size of all
materials, a laboratory analyst must use his/her best
professional judgement for determining an appropriate method.
This might include cutting, crushing or grinding. The
responsibility lies with the generator to make that
determination.
In addition, the TCLP states that one must collect a
representative sample of the waste as generated for analysis. If
you scrub your subsamples prior to TCLP testing, then you may not
S!JkI ?? a Representative sample. We have no way of knowing
whether the cleaning procedure will alter or affect the sample's
physical or chemical composition (and therefore its 1 ^arhjrtti
potential) in some way. Since tha ganarator irultiiiuiLe*^
responsible for making the riFtprmi nation.that, a representative
samp-le -is-collccted Xuij analgia,. we cannot make an up-front
determination that your proposed method is an acceptable or
appropriate step.
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If you have any additional
call me at (202} 260-4761.
cc: Alec McBride
Dave Topping
David Bussard
Carrie Wehling, OGC
RCRA/Superfund Hotline
MICE Line
2
questions, please feel free to
Sincerely yours,
Gail Hansen
Chief,
Methods Section (OS-331)
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	ttKOHMENTAL PROTECTION ACEHCY	9442.1991d6)
OCT 29 1991
Mr. Michael Miller
Laboratory Manager
Betz Analytical Services
P.O. Box 4300
9669 Grogans Mill Rd.
The Woodlands, TX 77380
Dear Mr. Miller:
1 as writing in reference to your letter of October 8f 1991, .
to Alec McBride, concerning the handling of ?CLF extractions as
they apply to-liquid wastes, including oils and solvent-based
products.
It is important to keep in mind that EPA does not require
:esting to determine whether a waste is hazardous; the generator
may use other information (such as knowledge of the process by
which the waste was generated) in making that determination.
Also, certain oily material destined for recycling, is exempt
(under Section 261.6(a)) from hazardous waste management
requirements.
Liquid hazardous wastes are subject to hazardous waste
management requirements regardless of whether they are destined
for landfill disposal. As a result, there are many reasons why a
generator or transporter would and should want to test the waste
that they manage. For example, a generator may need to determine
what types of storage, handling or transport requirements are
applicable to the waste. The generator may also need to test the
waste to determine compliance with the RCRA Land Disposal
Restrictions program, under which wastes are subject to
requirements for treatment by specified technologies prior to
land disposal.
Given these considerations, if the generator still wishes to
test his/her waste for the Toxicity Characteristic (TC)
determination, then the TCLP must be followed. Once the fluid to
be analyzed has been obtained (from either the initial filtration
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2
step or the leaching procedure), the laboratory may use any
appropriate determinative step for the analysis. If the methods
currently in SW-846 do not achieve the required detection limits,
then other methods should be used. This has often been necessary
with volatile organics for oily matrices. At this time, the
Agency is conducting studies of an automated headspace analysis
methodology coupled with isotope dilution mass spectrometry in
order to achieve greater analytical sensitivity for all TC
volatile analytes. We suggest the use of this approach be
considered. Currently, only a working draft method (copy
enclosed) is available. Pending the outcome of Agency studies,
the draft method will be revised and proposed for inclusion in
SW-846.
For further assistance, please call the MICE (Methods
Information Communications Exchange) at (703) 821-4789. Calls
are recorded on an answering machine and, for the majority of
questions, responses are provided within 24 hours. I hope this
information has sufficiently addressed your questions.
cc: David Bussard
Alec McBride
Dave Topping
Carrie Wehling, OGC
RCSA/Superfund Hotline
MICE Line
Sincerely yours
Gail Kansen
Chief,
Methods Section (OS-331)
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UM1CU ilAlU CnilKUnMEMAI. rAW t CWiiU f* AWCftwl
9442.1991(15)
BLWP132.91
i
December 17, 1991
Ms. Sharon Meves
Quality Programs Coordinator
WMI Environmental Monitoring Laboratories, Inc.
2100 Cleanvater Drive
Geneva, Illinois 60134
Dear Ms. Meves:
I am writing to you in response to your inquiry of November
18, 1991, concerning the handling and analysis of samples
containing volatile organic compounds. You do not mention any
specific matrix in your letter, but the tone of it indicates to us
that your questions refer to aqueous samples. My responses are
also limited to samples regulated under the Resource Conservation
and Recovery Act, and represent the point of view of the Office of
Solid Waste.
In general, aqueous samples should be hermetically sealed in
volatile organic vials at the time of sampling, and must not be
opened prior to analysis to preserve their integrity. The vials
should be completely filled at the time of sampling, so that when
the septum cap is fitted and sealed, and the vial inverted, no
.headspace is visible. At the time of analysis, the aliquot to be
analyzed should be taken from the vial with a gas-tight syringe
inserted directly through the septum of the vial. Only one
analytical sample can be taken from each vial. If these guidelines
are not followed, the validity of the data generated from the
samples is suspect.
The following is the response to your specific questions:
1) The sample should exhibit no headspace "at the time of
sampling" as I have previously mentioned. However, due
to differing solubility and diffusion properties of gases
in aqueous matrices at different* temperatures, it is
possible for the sample to generate some headspace during
storage. This he«dro»miqfi 11 appear in the form of micro
bubblefe, aod. 5hc
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2) The presence of a macro bubble in a sample vial generally
indicates either improper sampling technique or a source
of gas evolution within the sample. The latter case is
usually accompanied by a buildup of pressure within the
vial, (e.g. carbonate containing samples preserved with
acid). Tom Bellar of the Environmental Monitoring
Systems Laboratory in Cincinnati (EMSL-Ci) (unpublished
data) states from a study that he did several years ago
that "pea-sized** bubbles (i.e. bubbles not exceeding 1/4
inch or 6 asm in diameter) did not adversely affect
volatiles data. These bubbles were generally encountered
in wastewater samples, which are more susceptible to
variations in gas solubility than are groundwater
samples.
3} There is no reason to "flag** data from acceptable
samples. However, finite volatiles concentrations (i.e.
values above detection limits) from samples containing
excessive headspace should either be identified as
minimum values or discarded and new samples should be
taken. Non-detectable results are invalid.
If you have any further questions, please call me at 202-260-
7459.
Sincerely yours,
Barry Lesnik
Chemist
Office of Solid Waste-Methods
Section
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9442.1991(16)
Commanding Officer
Department of the Navy
Naval Weapons Support Center (PM-4)
Crane, Indiana 47522-5000
On December 11, 1990 and April 18, 1991 you sent a letters
(#8026 - Ser 50222/U5224, - Ser PM4/U5471) to our office
requesting that the Navy be exempted from the provisions of the
Toxicity Characteristic teaching Procedure (TCLP) when
determining if munitions items (DOT Class C, Hazard Class 1.4),
which are being processed, through an incinerator for disposal,
exhibit toxic characteristics. This letter responds to your
specific concerns. I want to apologize for not responding sooner
to your initial letter.
Under the existing regulations, persons who generate solid
waste are not specifically required to test their waste to
determine whether they exhibit the Toxicity Characteristic or any
other characteristic. Instead, solid waste generators are
required to make a determination as to whether or not their waste
are hazardous (see 40 CFR 262.11). This determination may be
made by either applying knowledge of the waste, the raw
materials, and the processes used in its generation or by
testing.
In your initial letter you stated that, "the TCLP
requirement to reduce particle size for toxicity determination
should not be applicable because of the inherently unsafe
' " procedure of crushing, cutting or grinding of munitions items."
The Agency recognizes that the particle size reduction
requirement (step. 7.3 - TCLP) could create an inherently unsafe
situation when testing these items. Therefore, we suggest that
determinations for these items be made by using knowledge of the
process or any other available data that characterizes the
properties of the above prescribed waste (e.g., EP Toxicity
results).
On January 11, 1991, our office called Mr. Keith Sims, and
on January 14, 1991 we spoke with Mr. J. Lawson, both of your
office, regarding the Navy's request for exemption from the TCLP.
In our phone conversations, we explained that the TC rule does
not require generators to test in order to make a hazardous waste
determination, as described above. Based on their knowledge of
the process, if they thin* tnoftefctMNaftove munitions items would
-------
fail the TCLP-extract analysis for lead or dinitrotoluene, then
these wastes could be declared as hazardous, and no testing would
be necessary. However, these wastes would have to be aanaged and
disposed of according to Subtitle C requirements. Both Mr. Sins
and Mr. Lawson acknowledged that they understood our explanation
and requested that we send you the above clarification in
writing.
Of course, State and local agencies nay have additional
regulations that differ. The appropriate EPA Regional office or
State and local regulatory agencies should be contacted for
additional assistance or clarification.
If you have further questions regarding the TC rule, please
contact Daryl Moore at (202) 475-8551.
Sincerely yours,
Sylvia K. Lovrance, Director
Office of Solid Waste
cc: Mr. J. D. Lynch (PM-4)
Mr. G. S. Edwards (5022)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9442.1991(17)
Mr. Nathan Fishback
Assistant U.S. Attorney
Root 330
517 E. Wisconsin Avenue
Milwaukee, Wisconsin S3202
Dear Mr. Fishback:
This letter is to follow up on a discussion with Mr. Richard
Ross of your office in which he requested a written clarification
of the applicability of certain analytical methods for conducting
testing under the toxicity characteristic regulation.
The Technical Assessment Branch in EPA's Office of Solid
Waste is responsible for developing and promulgating analytical
methods for EPA*s hazardous waste program, including the
Extraction Procedure (EP) leaching test. Until September 25,
1990, when changes to the toxicity characteristic (TC) became
effective, the testing protocol for determining compliance with
the TC was the EP test. The EP test was described in Appendix II
to 40 CFR Part 261. See 40 CFR Part 261, Appendix IX (Superceded
test) (1990). Appendix II described the various steps of the
leaching procedures itself and then stated that the test methods
to be used for analyzing the 14 compounds were those specified
in "Test Methods for the Evaluation of Solid Waste, Physical/
Chemical Methods1*, Known as SW-846.
Until June 21, 1990, the methods specified in SW-846 for
, arsenic, selenium, and mercury were Atomic Absorption, Furnace
Technique (methods 7060 and 7740 for arsenic and selenium,
respectively); Atomic Absorption, Gaseous Hydride (methods 7061
and 7740 for arsenic and selenium, respectively); and Manual,
Cold Vapor Technique (methods 7470 and 7471 for mercury). On
June 21, 1990, the Agency also promulgated method 6010
(Inductively Coupled Plasma Atomic Emission Spectroscopy) for
arsenic and selenium. Sfoe Agency has not promulgated an Atomic
Absorption, Direct Aspiration Method for analyzing arsenic,
selenium, or mercury.
-------
If you have any questions on this information, please call
1 FTS 260-4761.
me on FTS 260-4761.
Sincerely,
Alexander McBride, Chief
Technical Assessment Branch
2
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9442.1991(18)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC I 9 I SSI
OPPICE OP
SOLID waste and emergency response
Honorable Slade Gorton
United States Senate
Washington, O.C. 20510
Dear Senator Gorton:
Thank you for your letter of November 3, 1991, regarding
Chuck Burr's concerns about the disposal of used automobile
antifreeze.
My staff contacted Mr. Burr to discuss his concerns
regarding a recent revision to our toxicity test and to the
regulations that identify wastes as hazardous. Mr. Burr
indicated that there is a lack of guidance for businesses in
managing their antifreeze. We supplied his with information
about the current regulations and exemptions regarding the
disposal of antifreeze. I have also enclosed some guidance
documents that the Environmental Protection Agency (EPA) has
developed for small businesses to make it easier to comply
with the Resource Conservation and Recovery Act.
Zt should be noted that EPA does not regulate household-
generated antifreeze. In the case of antifreeze generated by
businesses, EPA regulates only antifreeze that fails the revised
' toxicity test. It may be of interest to you that we have
received some information from used automotive antifreeze
recyclers and the used antifreeze collection industry, indicating
that used antifreeze may, in some cases, fail the revised
toxicity test and therefore be a hazardous waste.
In addition, EPA allows businesses that generate less than
100 kg/month (about 30 gallons) of hazardous waste to manage
their wastes without complying with the EPA hazardous waste
regulation. We are considering further special exemptions so
that small business owners can comply more easily. We expect
to propose this concept within the next few months.
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UNITED STATES iHVIRQNMEMTAL PROTECTION AGENCY
9443.1991(01)
SEP 6 199!
Ms. DeAnna H. Senegal
AnalytiKEM Inc.
2925 Richmond Avenue
Houston, TX 77098
Dear Ms. Senegal,
I am writing in response to your letter of June 28,
1991 requesting clarification on the determination of the
ignitability characteristic. The characteristic, as
defined in 40 CFR S261.21, is applicable to both solid
and liquid vastes; however, test methods are currently
not available for solid waste. Because standardized,
approved methods are not available, the characteristic
determination for solids (e.g., determining whether
solids will cause vigorous and persistent fires through
friction, absorption of moisture, or spontaneous chemical
changes, as listed in the regulations) has to depend upon
_ 	 _ ....
solid materials may be helpful for determining if any of
the detectable compounds are known to be ignitable.
Please note that meeting anv (not all) of the properties
specified in the definition of ignitability qualifies a
waste as characteristically ignitable.
There are no specific definitions of "liquid* (i.e..
5%, 10%) in the ASTM method 0-93 (Standard Test Method
for Flash Point by Pensky-Martens Closed Tester) but the
types of materials that may be tested axe specified in
the method as "fuel oils, lube oils, suspensions of
solids, liquids that tend to form a surface film under
test conditions, and other liquids of similar vis-
cosities'*. You are correct to note that results obtained
from applying the test outside of the specifications
fe.cr.. paddle does not turn freely) do not provide proof
for a characteristic determination. However, if you are
assured that the paddle moves freely, then you may accept
the determined flashpoint as reliable.
ipAiuuuiiLy are1 "AOo ustiu lAttfCAM-
UI&5SlaSh«tXMt.4s.used..asi*n~j£ai£id»E~o£.
-------
ignitability. As stated in the 1990 0-93 method, "flash
point measures tendency of the sample to form a flammable
mixture with air under controlled laboratory conditions.
It is only one of a number of properties which must be
considered in assessing the overall flanmability hazard
of a material".
Regarding your question about how the results should
appear to clients if the procedures are not followed as
written, specific notations according to any deviation
from the method should be cited in the client's report.
If you have any further questions, please call me
at (202) 260—4761.
Sincerely yours,
Gail Hansen
Chief,
Methods Section
(OS-331)
cc: Alec McBride	—
Dave Topping
John Austin
David Bussard
Hark Badalamente, OGC
RCRA/Superfund Hotline
MICE Line
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9443.1991(02)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
NOVEMBER 1991
3. Removal of Toxicity Characteristic
Wastes from a Surface
impoundment
A generator produced a solid waste and
disposed of his waste in an on-site surface
impoundment. Afar the September 2$, 1990,
effective date of the toxicity characteristic (TC) No, hoc under the following circumstances.
rule, the waste would meet the definition of a The generator may remove the waste from the
newfy-identified TC warn (40 CFR §26124). surface impoundment prior to the effective
If he chooses to remove the waste from Ms date of the TC rule and the unit will not be
surface impoundment and dispose of it off~site, regulated as a subtitle C unit. EPA has also
would his surface impoundment be a regulated clarified that die Agency would not normally
unit under Subtitle C ofRCRA?	consider die one-time removal of waste from a
una on or ate the TC effective date to bring
die mat into die hazardous waste management
system 
-------
Volume 6
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
V olume 6
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UNITED states environmental protection agency
9444.1990(05)
Mr. James B. MacRae, Jr.
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
Hew Executive Office Building
Room 3019
Washington, D.C. 20503
Dear Mr. MacRae:
The purpose of this letter is to summarize the Agency's
response to issues raised in OMB1s review of the petroleum
refinery sludge hazardous waste listing regulation. Since
receiving your letter on September 6, 1990 the Agency has spent
considerable time reviewing the issues raised, re-analyzing the
data that support the rule, and developing written responses, the
most recent of which we sent to you oji October 5. Both the
Deputy Administrator and I have spent significant amounts of time
personally on this matter? we have both been briefed by staff on
the issues, we have formulated the Agency*s response, and we have
met with you or talked personally on the phone. As late as the
morning of October 16 EPA and OMB staff were engaged in detailed
discussions on the text of the preamble. X am sure you will
agree that the Agency has been quite responsive to your concerns.
As you know, the fundamental purpose of this regulation is
to complete the work begun in 1980 when the Agency listed the
first group of primary wastewater treatment sludges from
petroleum refining. A major weakness in the original listing was
that it failed to capture all of the primary sludges generated at
petroleum refineries. This final listing regulation simply
completes RCRA coverage of the these primary wastewater treatment
sludges, all of which have the potential to present significant
risks to human health when mismanaged. Z therefore strongly
encourage you to complete your review of this important
regulation, tour speedy action is particularly important since
the Agency is now under order of the U.S. District Court for the
.District of Columbia to promulgate this rule by October 22, 1990.
~
-------
Following is a summary of the Agency's responses to your
concerns in the order presented in your letter.
EPA»s Decision to List Is Based on Arbitrary Distinctions Between
W»ste Types
Your September 6 letter raised two concerns about the scope
of the listing determination. Your first concern is that the
preaable fails to document the distinction between primary
separation and biological separation sludges and thus calls into
question the Agency's rationale for listing.the former but not
the latter. You provide data to support your conclusion that the
levels of hazardous constituents in the two types of sludges are
similar enough to justify the listing of both. Your second
concern is that the listing determination fails to account for
. the variability in levels of hazardous constituents in the
primary sludges and thus over-regulates.
With respect to your first concern, the Agency has never
intended to include biological sludges in this listing nor have
we published any documents suggesting that we were considering
such an action. Our intent has always been simply to regulate
the primary sludges that were not captured by the 1980 listings.
Since biological sludges were not within the scope of the
rulemaking, we have never undertaken a major sampling effort and
therefore have only limited data. This limited data and our
engineering judgment lead us to believe that biological sludges
contain significantly lower levels of many hazardous constituents
than primary sludges and thus pose less of a risk to human health
and the environment. In attempting to re-create the figures
shown in the table on page 4 of your letter, we realized that
your figures for the concentration of hazardous constituents in
biological treatment sludges include data from some units that
would be regulated as primary treatment units under this listing.
Your figures therefore overstate the concentration of hazardous
constituents in aggressive biological treatment sludges and do
^not by themselves provide a rationale for listing biological
' treatment sludges. In our October 5 letter we transmitted new
preamble language and data that more clearly explain why the
Agency cannot justify the listing of biological sludges at this
time.
Your letter also states that the levels of hazardous
constituents in primary sludges vary by orders of magnitude
across facilities and between units and	til© listing is over-
inclusive. The Agency's data do not support this conclusion.
While it is true that individual constituent concentrations vary,
virtually every sample of primary separation sludge collected by
the Agency contains one or more hazardous constituents several
orders of magnitude above the applicable health-based levels.
2
-------
Thus, notwithstanding variation among constituent concentrations,
these data clearly demonstrate that all primary sludges have the
potential to pose a risk to human health.
Selective application of the Factors for Consideration in
6 2fii.ll 
-------
proven to yield long-term benefits. The Agency nonetheless
agrees that the existence of drinking water regulations for some
of the hazardous constituents of primary separation sludge is
relevant to the quantitative benefits calculation. However,
drinking water regulations do not exist for all of the hazardous
constituents, most notably the polynuclear aromatic hydrocarbons
that are common in the petroleum sludges at issue here. The
Agency did not therefore invest its limited analytical resources
in a further refinement of the benefits analysis to measure the
exact impact of drinking water regulations. We did provide in
our October 5 letter additional language for the preamble and the
Regulatory Impact Analysis (RIA) that qualitatively addresses
this limitation in the analysis.
Contaminant taste and odor would be an unreliable approach
to protection of private well users. The concentration threshold
at which people taste and smell contaminants varies, and in the
case of benzene, the threshold is several times higher than the
drinking water regulatory level. Such an approach would
obviously not be effective for contaminants that have neither
taste nor odor.
The Agency also does not dispute the fact that treatment of
contaminated groundwater is less costly in the short term than
full implementation of RCRA Subtitle C. We are not convinced
however, that the long-term costs to society would indeed be
lower, given the mandates of both RCRA and CERCLA to clean up
contamination.and the essentially unquantifiable value of an
uncontaminated natural resource. The policy and legal
implications of implementing a treatment approach are profound,
and would require the Agency to undertake a comprehensive re-
thinking of the BCRA and CERCLA programs. We do not believe that
it is appropriate to undertake such an effort at this time or in
the context of this individual rulemaking. We would welcome the
opportunity to discuss the environmental implications of relying
on groundwater treatment instead of prevention and remediation
later this fall as we begin to prepare for the reauthorization of
RCRA.
Other Appropriate Considerations
1) Alternative Means of Achieving Equivalent Risk -
Reduction Benefits at Less Cost
You suggest that EPA should have given further consideration
to a range of alternatives for the regulation of primary
separation sludge. Examples given include a & minimis approach,
a Subtitle "D" or	approach, and the more novel idea of
regulating only when contamination in drinking water wells has
actually been detected and the refinery has failed to provide
either treatment or alternative water supply. Your letter goes
on to state that full implementation of Subtitle C dampens
4
3^3
-------
pollution prevention incentives by regulating all of the sludges
to the sane degree of stringency regardless of their level of
toxicity.
Based on further analysis, we have found first that
petroleum refinery primary wastewater treatment sludges are
unlikely to qualify for a ¦$& minimis exemption from Subtitle C
regulation. Since 1980 the industry has been unable to lower
constituent levels to meet even the hazardous waste delisting
levels, so we do not consider a minimis approach to be viable.
Second, we do not have statutory authority to develop or enforce
Subtitle D regulations for this industry at this time, nor are we
aware of the legal authority under which your final regulatory
alternative could be implemented. We therefore did not pursue
analysis of these options in our RIA.
The Agency could consider pursuing a concentration-based
listing or tailoring existing Subtitle C requirements to this
particular industry in hopes of reducing the costs of compliance.
However, neither approach is likely to produce dramatic savings
in this industry. The toxicity and mobility of these sludges
would probably prevent the Agency from establishing
concentrations that would allow substantial volumes to escape
regulation. It would also be difficult to justify significant
deviation from established Subtitle C engineering standards.
Both approaches would require a new data collection and analysis
effort as well as a re-proposal of the rule. We do not think it
is appropriate to consider a fundamental change in our regulatory
approach for petroleum refining waste at this late stage in the
process, particularly when the standards for newly listed sludges
would vary in approach from standards that apply to virtually
identical sludges that have been listed since 1980. We do
believe, however, that both concentration-based listings and
tailored standards are worthy of consideration in the future for
those wastestreams where it is appropriate. There are policy,
legal, and resource issues to be evaluated before the Agency can
fully implement either approach. We would be happy to discuss
these issues with you at your convenience.
-»•
We do not agree with your statement that listing discourages
pollution prevention. Our experience has been that listing under
Subtitle C creates a strong incentive to reduce waste volume, to
improve the efficiency of wastewater treatment systems, and to
recycle and re-use waste materials. Based on this experience and
information provided to us by the refining industry, we would
expect the same incentives to exist for these petroleum sludge
listings.
5
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2)	Upper-Bound Excess Lifetime Cancer Risk is Within
EPA's Acceptable Risk Range
Your letter indicates that the excess cancer risks presented
by primary treatment sludge are within the 10"4 to 10*'
"acceptable" range. Your letter fails to point out that OMB used
average upper-bound cancer risks to the exposed population to
document this statement as opposed to the cancer risks posed to
the maximally exposed individuals (MEI's) at individual
refineries. Historically, EPA has set standards to protect
against MEI cancer risk levels in the 10"* to 10"6 range.
3)	Costs Exceed Benefits by at Least an Order of
Magnitude
EPA is aware that the projected costs of complying with the
petroleum refinery sludge listing exceed the benefits we have
been able to quantify. It is extremely difficult to quantify the
health and environmental benefits of prevention regulations and
we would welcome any advice OMB may have on improving our
techniques for benefits estimation. We provided in the
attachments to our October 5 letter a discussion of the factors
that have caused us to under-estimate benefits. These include
exposure pathways not analyzed, constituents not included in the
analysis, and future populations not accounted for. We believe
that the incentives to reduce waste volumes and upgrade
wastewater treatment systems, the closing of a long-standing gap
in RCRA regulatory coverage, and the consistency with previous
listing decisions are all factors in addition to the cost/benefit
ratio that must be considered in this final regulatory decision.
In closing, I would like to say that EPA appreciates the
time and effort that you and your staff have devoted to the
review of this regulation. You have pointed out some issues
which required fuller discussion in the preamble and have raised
broad policy issues that clearly merit further consideration as
we look to the future of the hazardous waste program. However,
given the existence of a gap for 10 years in RCRA regulatory
coverage of primary separation sludges and the court order
requiring the Administrator to take final action on this rule by
October 22, the Agency finds there is a compelling need to
complete our work on the petroleum refinery sludge listing and
promulgate this final rule.
Sincerely,
Don R. Clay
Assistant Administrator
cc: F. Henry Habicht, II
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9444.1991(01)
RCRA/SOPERFOHD HOTLINE MONTHLY SUMMARY
FEBRUARY 1991
1* Fgtrolemn Refaerv Wastewater Treatment Sluri^p
A petroleum refinery produces large volumes of process and oily cooline
th^Tn18": lto diSChargeil't0 ** i^s r*™* owned treatment works,
^wastewater undergoes treatment to meet applicable Clean Water Act discharge
limits. At various points throughout die wastewater treatment process thefadiiw
November 2,1990 Federal R^stg (55 FR 46354), promulgated two new petroleum
refinery wastewater treatment sludge listings, F037 and F038. After May 2,1991 the
which/.,he	sludges willed tote
st^eC^Sts?	™d *"*" ^ to RCRA
In developing the new listings, EPA concluded flat sludges resulting from
vanous petroleum refinery wastewater treatment sources contain
levels of hazardous constituents as those generated in Dissolved Air Rotation
(DAF) units and American Petroleum institute (APD separators, which are
already designated as K048 and K051, respectively. Consequently, the
Agency promulgated the nonspecific source F037 and F038 waste listings to
ensure that regulatory coverage was extended to all petroleum floats and
sludge resulting from primary wastewater treatment that are not covered
under more unit-speafic K designations. (55 Jg 46356)
To determine the applicability of the FQ37 and F038 listings, the facility must
ascertain the origin of the wastewater treatment sludges. Petroleum refinery
process and oily cooling wastewaters are generally treated in two phases:
primary treatment and secondary (biological) treatment Primary wastewater
treatment in the petroleum refining industry covers only the two initial stages
of treatment which are designed tousephykcal and chemical processes to
separate oil water and solids from the wastewater stream.
Specifically, the F037 listing desaiption is assigned to sludges resulting from
the first stage of primary treatment where gravitational oil/water/solids
separation is performed. The F038 designation pertains to floats and sludges
that arise from the second stage of primary treatment in which physical and
chemical processes are employed to separate emulsified oil/water/solids
from refinery wastewaters. (55 FR 46363) PLEASE NOTE- sludges resulting
from secondary wastewater treatment, which are distinguished by die active
biological degradation phase that follows primary treatment, ate not covered
by the new petroleum refinery sludge rule. f
-------
A final consideration when determining the scope of the FQ37 and FD38
listings are the exemptions for sludges generated from specific situations.
These indude (1) sludges generated from stormwater units that do not
receive dry weather flow; (2) sludges Cor floats) generated from aggressive
biological treatment units; and (3) sludges resulting from specific wastewater
treatment units already designated as K048 and/or KQ51. (55 £E 46358) The
exemptions ensure that only sludges and floats resulting from previously
unregulated activities or activities within the scope of the new listings (ie.,
only primary treatment) are identified as hazardous under the KB7 and HB8
waste codes.
Source: John Austin, OSW	(202)382-4789
Research: Stephen Buchanan
-------
*
UHr»-«> STATES ENVIRONMENTAL PROTECTION AGENCY 9444.1991(02)
>-\'30-c\\
Gaynor Dawson
vice President
ICF Kaiser Engineers
601 Williams Blvd., 4th Floor
Richland, WA
Dear Mr. Dawson:
I am writing to respond to your August 17, 1990 letter
requesting clarification of the circumstances under which lead
shielding for radioactive waste is a solid waste under RCRA.
In your letter, you refer to the June 26, 1987 correspondence
between the Director of the Office of Solid Waste, Marcia
Williams, and Terry Husseman, Chair of the Northwest Interstate
Compact Committee, which states in part: "...lead whose primary
use is shielding in low-level waste disposal operations is not
subject to Federal hazardous waste regulations when placed on
the land as part of its normal commercial use.* This policy is
unchanged.
Most recently, this policy was echoed in the October 4,
1989 Agency guidance to NEC licensees, "Guidance on the
Definition and Identification of Commercial Mixed Low-level
Radioactive and Hazardous Waste and Answers to Anticipated
Questions." In question 6, on page 4 of the guidance, the issue
is raised: "Are lead containers whose primary use is for
shielding in disposal operations, hazardous waste under RCRA?"
The first paragraph of the response follows:
No. While lead containers and lead container liners
may exhibit the hazardous characteristic for lead,
those containers whose primary use is for shielding in
low-level waste disposal operations are not
considered hazardous wastes and thus, are not subject
to the hazardous waste rules. These same containers
and liners if disposed of or discarded would be
considered wastes and if they exhibit the hazardous
characteristic, would be subject to the hazardous
waste rules„
In summary, your statement that "... lead containers or
container liners [are] not solid wastes when the radioactive
waste [is] disposed because the lead shielding continue[s] to
fulfill this intended use as shielding" is a correct
interpretation of Agency policy. While the lead shielding is
not a solid wactta, wa racQTnmariil rhar ir hp marmrnmpwilflrprt
pr ior to i disposal! in or oyt		tee pggvcftte fchq 	shielding
-------
UNI. ' J STATES ENVIRONMENTAL. PROTECTION AGENCY
from leaching. When this is done, the environment will be
protected from radiation by the lead shielding, and from the
leaching of lead by the macroencapsulation of the entire waste
package. Please note that this macroencapsulation is not
required by the land disposal restrictions, but represents best
management practice. Of course, if the shielding is no longer
serving its intended use as a commercial product and is
discarded, and exhibits a characteristic, it is a solid waste
and must meet all Subtitle C requirements, including
macroencapsulation before being placed in or on the ground.
Your letter asks several questions regarding lead
shielding, some of which were discussed over the phone with Rod
Larang of your staff. The first question asks if lead shielding
for radioactive wastes is a solid waste when it is disposed
under certain conditions.
The first condition is when the shielding is part of an
object being disposed, and while necessary for radiation
protection during waste handling prior to its disposal in or on
the land, is not necessary for radiation protection after the
object has been placed in or on the land. Since the shielding
is not necessary for radiation protection once the object has
been disposed, it becomes a solid waste upon disposal, and
therefore must meet all applicable treatment standards.
The second condition concerns lead shielding that is part
of a disposed waste package and is necessary for radiation
protection after the object has been buried. Here, the lead
shielding is fulfilling its intended use as a commercial
product, and is not considered a solid waste.
The third condition involves the introduction of shielding
, during the packaging of radioactive waste in preparation for its
disposal. As the lead shielding is necessary only during waste
handling in this example, once the shielding is disposed, it
becomes a solid waste.
The fourth condition concerns the introduction of shielding
during the packaging of the radioactive waste for disposal; the
shielding being necessary for radiation protection after the
waste package has been buried. Here the shielding is not a
solid waste as long as it is fulfilling its intended use as a
commercial product.
Que&Liuii two reada. coi&yikMySi	a flclid" waste	
witefl ftuacfea gari disposal, m xuaimjectiiu 40 lea
-------
UMJTeD STATES ENVIRONMENTAL PROTECTION AGENCY
treatment standards (i.e., encapsulation for D0O8 waste lead
shielding), or are these standards inapplicable because the
shielding is not a solid waste until disposal is completed?"
As indicated above, if the lead shielding itself is discarded
and is no longer fulfilling its intended use as a commercial
product, it is a solid waste, and is subject to all applicable
treatment standards.
Question three describes a situation where a waste package
with nonencapsulated shielding disposed in the past is retrieved
in the future in order to treat the waste. In this case, as
long as the shielding is fulfilling its intended use, it is not
a solid waste. Once the shielding is discarded, however, the
shielding becomes a solid waste, as it would no longer be
serving the function for which it was intended. As the land
disposal restrictions apply prospectively, it is important to
know when the shielding was discarded. If it was discarded
before the applicable effective land disposal restrictions date
for the RCRA hazardous waste, the land disposal restrictions
would not apply until it was dug up.
Question four in your letter provides two more examples of
the use of lead shielding: radioactive materials passing through
a lead pipe, and nonradioactive materials being protected from
a radioactive environment by lead. To respond to the subparts
of question four, first, the abandonment of buried lead-lined
piping which transported radioactive materials and the
radioactively contaminated lead-shielded phone cable constitutes
disposal of a solid waste. See 40 CFR 261.2 for the definition
of solid waste. This lead would be subject to treatment
standards under the Land Disposal Restrictions program. Lead
contaminated with radioactivity must be macroencapsulated before
disposal (55 FR 22628). The piping and cables are wastes once
, "abandoned; redisposing the waste elsewhere would not affect its
status as a solid, waste. Again, because the land disposal
restrictions apply prospectively, if the material was abandoned
before th» land disposal restrictions effective date for the
hazardous waste(s), the land ban would not apply unless the
material wa» dug up. Liability for the improper disposal of
hazardous waste would occur immediately upon such disposal.
Violations of the land disposal prohibitions may result in the
issuance of an order assessing a civil penalty for any past or
current violation, requiring compliance immediately or within
a specified time period, or both. (RCRA section 3008 (a)(1)).
To reiterate, HSWA requires hazardous wastes to meet promulgated
treatment stanoaros gnar	~ Failing Lu xueeu
these stjandards 4s a violation ot jhswa.
-------
UNiTfeD STATES EMVIROHMEHTAL PROTECTION AGENCY
Question 5 of your letter asks if, under Section 6001 of
RCRA, federal agencies are immune from regulation by authorized
states. Section 6001 of RCRA spells out clearly that any part
of the Federal government engaging in waste disposal operations
is subject to all federal, state, interstate, and local
requirements. Moreover, Executive Order 12088 states that the
Federal government will comply with all environmental statutes
and regulations, including the environmental statutes and
regulations of authorized states. Thus, under Section 6001 of
RCRA, Federal agencies are not immune from regulation by
authorized states.
We hope that this letter answers your concerns regarding
the circumstances under which lead shielding for radioactive
wastes is or is not a solid waste under RCRA. If you have
further questions on this matter, please contact me.
Sincerely,
Richard Kinch, Chief
Waste Treatment Branch
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9444.1991(03)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
MAY 1991
1. Comparative Definitions of F001 and F002
Tetrachloroethylene, trichloroethylene, methylene chloride, and 1,1,1-
trichioroethylene are listed in the definitions of both F001 and F002 in 40 CFR 26131.
The listing for F001 reads "the following spent halogenated solvents used in
degreasing...", while the F002 listing begins with "the following spent halogenated
solvents...". Although F001 applies specifically to solvents used in degreasing
according to die December 31,1985 Federal Register, the F001-F005 listings cover
only those solvents used for their solvent properties. A solvent used in degreasing
is considered to be used for its solvent properties. (50 FR 53316) Thus, a solvent,
which is listed in both F001 and F002 (e.g., methylene chloride) and is used in
degreasing, could be both F001 and F002. Would such a spent solvent be
appropriately classified as F001, F002, or both?
It was not the intent of the Agency to apply both listings to a solvent
constituent which is listed in both F001 and F002. The waste code that the
spent solvent receives depends on the type of degreasing involved. Page 6
of the "listing of Hazardous Waste (40 CFR 26131 and 26132); Identification
and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001" (also
known as the Background Listings Document) clarifies the intent of the F001
listing as opposed to other spent solvents. Specifically, the F001 listing is
appropriate when tetrachloroethylene, trichloroethylene, methylene chloride,
and 1,1,1-trichlo roe thane are used in large-scale industrial degreasing
operations [eg., cold cleaning, vapor degreasing (open top and
conveyorized), and fabric scouring]. Alternatively, tetrachloroethylene,
trichloroethylene, methylene chloride, and 1,1,1-trichloroetnane used in
equipment cleaning or in smaller scale degreasing operations involving repair
work (that do not employ industrial degreasing processes as described
above), such as industrial maintenance and repair, commercial service and
repair, and consumer-performed maintenance and repair, receive the F002
listing.
Source: Ron Josephson, OSW	(202) 475-6715
Research: Peter LeToumeau
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UNITED STATES ENYiRONMEHTAL PROTECTION AGENCY
AUG 3 0 1991
9444.1991(04)
MEMORAKDPM
SUBJECT: Residual Materials Contaminated with Trace Solvents
FROM: Sylvia K. Lowrance, Director
Office of Solid Haste
TOj	Robert L. Duprey, Director
Hazardous Waste Management Division
EPA Region VIII
This memorandum is in response to your requests for guidance
on trace solvent issues dated December 20, 1990 and February 11,
1991. In the particular case cited, a facility degreases metal
parts in an FOOl-listed solvent, air dries the parts, and then
blasts the parts. Some of the blasting grit has been found to
contain solvent constituents. According to your first memo, a
conflict between Region VIII and the Utah Department of Health
has arisen on interpreting the scope of the listing regulations.
The conflict appears to be centered on whether previous
Headquarters memoranda are valid and applicable to this
situation.
Upon review of the specific situation and your initial
response, research into previous Headquarters correspondence, and
discussions with your staff, we concur with the memorandum sent
&y Terry Anderson to James Wickemeyer on October 29, 1990 (i.e.,
' the blasting grit generated by the facility in question does not
meet the F001 spent solvent listing description). This letter is
consistent with previous Headquarters interpretations as to the
scope of the spent solvent listings or the mixture rule, which
state traces of solvents left on equipment after cleaning are not
spent and therefore do not meet the listing description. Such
wastes may be hazardous because they exhibit one of the
characteristics of hazardous waste described in 40 CFR 261
Subpart c (particularly the toxicity characteristic of §261.24).
If solvents "are used for cleaning in excess of amounts
needed for that purpose, however, the excess solvent residues
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could be spent, and therefore listed hazardous waste. No set
quantity has been established for excess amounts of solvents
which would cause the residual in question to be subject to
regulation. The nature of facility operations will dictate
whether the amount of solvent released, inadvertently or
deliberately, would cause the waste in question to meet the
listing description. The applicability of such an interpretation
would depend on the nature of the operation, the quantities of
solvents used and disposed in the operation, and the manner in
which they are used/disposed.
Please note that some state agencies have the authority to
interpret Federal regulations more strictly than EPA, if desired.
In this particular case, such an interpretation may ease the
regulatory flexibility of State agency personnel.
Thank you for your memorandum. Zf you have any additional
questions on this topic please do not hesitate to call me or have
your staff contact Ron Josephson at FTS 260-4770.
cc: (w/incoming) Ken Gigliello, OWPE (OS-520)
Hazardous Waste Division Directors, Regions X - VII, IX, X
2
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9444.1991(05)
UNITED STATES ENVflONMENTAL PROTECTION AGENCY
November 26, 1991
Mr. James C.R. Lee, P.E., Ph.D.
Environmental Engineer.
tWT _
v£it^u CiU|
APO San Francisco 96343-0061
Dear Mr. Lee:
Thank you for your letter of June 21, 1991. Please accept
W apology for the delay in answering your letter, which was
referred to our branch from the Kansas City regional office.
In response to your first question, discarded wastewater at
a corrosion control facility is considered a solid waste. (40 CFR
261.2). Whether a solid waste is also a hazardous waste depends
on whether the solid waste contains any listed hazardous waste or
exhibits any hazardous waste characteristics.
Methylene Chloride is listed in 40 CFR 261.31 as a hazardous
waste. Unfortunately, the information you provide about the way
in which the methylene chloride is used is not enough to allow me
to say, conclusively, whether the waste you describe is
hazardous. Methylene chloride is listed as both an F001 and F002
hazardous waste. I refer you to the following paragraphs:
40 CFR 261.3 Hazardous wastes from non-specific sources
E001.. .the following spent halogenated solvents used in
tfaorc&sixig: Tetrachloroethylene, trichloroethylene,
¦ethylene chloride, 1,1,1 -trichloroethane, carbon
'tetrachloride, and chlorinated fluorocarbons; all spent
solvents Te+nwmm /w aMi yfrf Jji de greasing	f^^gr
before use, ft total of tea percent or more (by volume)
of one or more of the above halogenated solvents or
those solvents listed in F002, F004, and F005; and
still bottoms from the recovery of these spent
solvent and spent solvent mixtures.
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united states environmental protection agency
-2-
We appreciate the input and cooperation of the Navy and
Department of Defense in resolving this issue and look forward to
your continued support in securing passage of the Administration
ill •
Sincerely,
Don R. Clay
Assistant Administrator
cc: Jacqueline Schafer
Department of Navy
Robert Grady
OKB
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9444.1991(06}
RCRA/SUFERFUHD HOTLINE MONTHLY SUMMARY
NOVEMBER 1991
or cave" (emphasis added). Spillage and
drippage are also forms of land disposal, albeit
improper and illegal. Since spills and drips of
hazardous waste which have collected in the soil
are normally land disposed wastes, water that has
percolated through soils contaminated with more
than one listed hazardous waste for which Pan
268 treatment standards are in effect is normally
multisource Ieachaxe, is defined in 40 CFR §261J1 P039,
as Ieachaxe resulting from the disposal ef more
than one hazardous waste listed in 40 CFR Part
26 J, Subpart D, which is also a restricted warn
under the Land Disposal Restrictions program in
Part 268. Rainwater has percolated through soils
contaminated with spills of several different listed
hazardous wastes. Could the resulting
contaminated water now receive the F0S9 waste
code?
1. Multisource Leachate (F039) Waste
Coda as it Applies to Contamination
From Spills
The hazardous waste code F039, known as
The January 31.1991. Federal Register (56 FR
3865) states that in order to determine whether a
waste meets the criteria of F039, it is necessary to
first df if lining that the waste mggff the definition
ofleachare. This definition, found in 40 CFR
§260.10, is "any liquid, including any suspended
components in die liquid, that has percolated
through or drained from hazardous waste." The
preamble of the January 31,1991, notice also
clarifies that only liquids that have percolated
through land disposed wastes ("land disposal"
having die meaning of RCRA Section 3004(k)) are
considered to be leacham for the purposes of
making this determination The definition of land
disposal in Section 3004(k) states that land
disposal "shall be deemed to include, but dm
Iiirited to any placement of such hazardous waste
in a landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome
formation, salt bed formation, or underground mine
331
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4^"er'\
9451.1991(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\motr
*S<	WASHINGTON, D.C. 20460
MAR I 3 1991
OFFICE OF
SOLID WASTE ANO EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Clarific^t±pn/]< QG Requirements and Liabilities
FROM: Sylvi
Office o
TO:	Jeffrey Zelikson, Director
Hazardous Waste Management Division (9H-1)
This memorandum is written in response to your February
20, 1991, request for clarification of the regulatory
requirements and potential liabilities of small quantity
generators pertaining to the use of hazardous waste manifests to
assist you in responding to William Apger.
The practice in question is a situation in which hazardous
waste is transported to a permitted (or interim status) storage
facility, accompanied by a hazardous waste manifest; a small
quantity generator has initiated the shipment, and has contracted
with the storage facility to clean up and remove the waste from
the generator's property. Once the waste reaches the storage
facility, the manifest is signed and returned to the generator.
The waste is later sent to another designated facility for final
treatment and disposal, and is accompanied by a second manifest
on which the storage facility is named as the generator. The
requestor asks if this practice conforms to the legal
requirements imposed under RCRA, if obtaining and following
recordkeeping requirements for the first manifest is sufficient,
and if the generator should request copies of the manifest
initiated by the owner/operator of the storage facility when the
waste is shipped to the second facility.
Small quantity generators who generate between 100 and 1000
kg of hazardous waste per month, as well as generators of more
than 1000 kg per month, are required to comply with regulations
pertaining to the manifest. If the generator, the transporter,
and the storage facility in the scenario presented each use the
uniform hazardous waste manifest during handling of the waste,
completing the required signatures (the generator, transporter,
and storage facility before a copy is returned to the generator
in accordance with 40 CFR 262 Subpart 1) and maintaining the
required records, then the generator would appear to be in
:ompliance with the Federal regulations. Note that
conditionally-exempt small quantity generators, i.e., generators
' *' ^	Prin$m)an Recydma
-------
of less than 100 kg of hazardous waste in any given month, are
exempt from the manifest provisions.
As you are aware, States are allowed to impose regulations
which are either more stringent or broader in scope than the
Federal regulations; therefore, the generator should also check
with the State in which his facility is located.
The letter which you provided with your request for
assistance also states that the storage facility would, upon
request, furnish the generator with copies of the manifests which
are prepared at the storage facility for the subsequent
transportation of the waste to the ultimate treatment and
disposal facility. If the generator is requesting such copies
because of a concern about potential future liability, a request
for copies of these manifests could be regarded as a prudent
practice. As you know, the generator retains potential liability
under Superfund for future mismanagement of hazardous waste even
after it has left his site and is out of his possession.
Please contact me if you need further clarification on this
or other issues.
•/
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9451.1991(02)
rcra/superfuhd hotline monthly sumnm
MARCH 1991
1. Amendments to Fart 262 Hazardous Waste Determination and Recordkeeping
Requirements of Part 262 and 268
The Land Disposal Restrictions (I^R) Third Third final rule (June 1,1990.55 FR
22520} revised the waste identification requirements of 40 CFR 262.11. Prior to the
revision, section 262.11 set out an after/or scheme where, if the generator
determined that a waste was listed in Part 261, Subpart D, he or she need not
determine whether the waste exhibited a charactsistic under Part 261, Subpart C
With the promulgation of the Third Third rule, the Agency amended section 262.11
to indicate that generators must determine whether listed wastes also exhibit any-
hazardous waste characteristics for purposes of compliance with IDH.
A generator is required to develop and maintain records for hazardous waste under
two regulatory programs, LDR (Fart 268) and generator standards (Part 262). How
does the amended language of 40 CFR 262.11(c) affect the paperwork assooated
with these two regulatory programs?
The amended language erf section 262.11(c) does not affect the generator
paperwork required in Part 262. When a generator determines that a solid
waste meets a Part 261, Subpart D hazardous waste listing, he/she is not
lu'Sj
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/
required to determine whether the listed waste exhibits any characteristics for
purposes of filling out Part 262 paperwork such as generator notification
forms (8700-12) and biennial reports. (However, the generator may elect to
determine whether the waste exhibits a characteristic for his/her own
information or for other reasons.) On the other hand, the paperwork of Part
268 must reflect the amended language of section 262.11(c) which states that
for the purposes of compliance with Part 268 a generator must determine if a
listed waste is also characteristically hazardous. (Emphasis added.)
The general principal of the section 262.11 waste identification modification is
that if both the treatment standard for a listed waste and the treatment
standard for a characteristic waste are in effect for a common constituent, then
the treatment standard for the listed waste applies because it is more specific
If, however, the treatment standard for the listed waste does not specifically
address the characteristic^), the waste codes for both the listed waste and the
characteristic waste(s) should be included on the notification paperwork of
section 268.7. (see 55 FR 22659) In the Third Third technical amendment rule
(January 31,1991,56 FR 3864), the Agency provided an example of this seconc
scenario. K062 is listed for toxicity as well as for the characteristic of
corrosivity. Because the K062 treatment standard does not specifically
address the characteristic of corrosivity, both K062 and D002 must be indudec
in the section 268.7 paperwork. (56 F£ 3872)
There is also a variation of the principle illustrated above If the most specific
treatment standard is subject to a national capacity variance or a case-by-case
extension and thus is not yet in effect, then the treatment standard for the
most specific waste code that is in effect must be met The January 31,1991,
Federal Register also provides an example of this situation. During the K048
variance period from August 8,1990, until November 8,1990, K048 was
subject to the treatment standards for EP toxic chromium and lead (D007 and
D008) since the treatment standards for these two characteristics were in
effect After the variance expired for K048, section 268.7 notification for the
KD48 treatment standard would only apply because the listing treatment
standard is more waste specific than the two characteristic waste treatment
standards. (56 EE 3873)
In conclusion, die amended language at 40 CFR262.11(0 was intended for
compliance with LDR treatment standards. The generator recordkeeping and
repealing requirements of Part 262 remain unaffected.
Source: Rhonda Craig, OSW	(202) 382-7926
Becky Cuthbertson, OSW	(202)475-9715
Research: Cynthia Hess
2HI
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9451.1991(03)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR I 6 199!
*ICE Of
SOLID WASTE AND EMERGENCY RESPONSE
Mr. Michael H. Oberg
Chief Operating Officer
United Marketing International, Inc.
P.O. Box 989
Everett, WA 98206-0989
Dear Mr. Oberg:
Thank you for your letter dated February 19, 1991 concerning
the Toxicity Characteristic (TC) rule and its relationship to
used oil filter disposal as outlined in a October 30, 1990
memorandum to Mr. Robert Duprey in EPA's Region 8 office.
The TC rule was effective in all states on September 25,
1990, regardless of the state's RCRA authorization status. The
TC will be implemented and enforced by EPA's Regional Offices
until such time as states are authorized to implement and enforce
the TC. Please note that the compliance date for generators of
small quantities (from 100 to 1000 kg of total hazardous waste in
a calendar month) of TC-hazardous wastes was March 29, 1991.
Small quantity generators (SQGs) were required to begin managing
their TC-hazardous waste in accordance with all applicable
hazardous waste regulations on that date. Of particular concern
to the Agency is the proper management (e.g., storage, treatment,
transportation and disposal) of these wastes.
As a point of clarification, I would also note that under
the TC rule, generators are not specifically required to test
their waste. The regulations allow generators to use their
knowledge of the waste and/or the process that generated it to
determine if it is hazardous. They are, however, required to be
correct in their determination.
The Agency intends to fully enforce this rule. The Agency's
enforcement policy clearly is designed to identify and prosecute
violators and to deny any economic benefit resulting from
violations. Civil and criminal penalties are also available as
enforcement tools.
Finally, the Office of Solid Waste appreciates the
information you provided pertaining to recently completed studies
of used oil filters conducted by the University of Northern Iowa.
This study addresses the Agency's recommended best operating
practice contained in the October 30, 1990 memorandum which
suggested both draining and crushing of the oil filter to ensure
34^
Printed on Recycled Papet
-------
maximum removal of the oil. Of course, as discussed earlier,
each hazardous waste generator is ultimately responsible for
making their own determination as to whether their waste is
hazardous under the TC rule for any waste stream generated.
I hope this letter clarifies the nature of the Agency's
implementation of the TC rule. If you have any additional
questions, please feel free to contact Mr. Steve Cochran of my
staff at (202) 382-4770 for general TC questions and Mr. Hugh
Davis in the Office of Waste Programs Enforcement at (202) 475-
9867, if you have TC enforcement questions.
Director
Office of Solid Waste
3H°
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9452.1991(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL 26 1991
Brian Engel
U.S. Pollution Control
515 West Greens Road, Suite 500
Houston, TX 77067
•jee.cf OP
SOmD WAS'S as.OI%'£"CI5iC BtS'ONSI
Dear Mr. Sngel:
Thank you for your letter of June 10, 1991, which requested
clarification on some of the instructions for completing the
Uniform Hazardous Haste Manifest. Specifically, you described a
situation in which waste is transfered from rail to highway on
its way to the designated facility. You asked whether an agent
of the generator, acting in the generator's behalf, would be
allowed to choose the highway transporter from among a group of
pre-approved transporters at the point of transfer from rail to
highway. You proposed this procedure as an option to replace the
current practice in which the highway transporter chosen by the
generator and listed on the manifest is replaced by another pre-
approved transporter, thereby requiring that the manifest be
altered en route, making the document difficult to read.
Although your option has merit from the point of neatness
and legibility of the manifest, I do not believe that it fits in
with the functional purpose of the manifest which is to track the
movement of the waste from the point of generation to the point
of disposal. If the generator leaves the Transporter #2 block on
the manifest empty when the waste is transported from his site,
there would be no indication that the generator knew how the
waste would get from the rail to the facility. That could
presumably be addressed by the generator's indication on the
manifest of a limited number by the rail transporter to the
designated facility. He still however, consider the generator
' responsible for knowing who is transporting the waste, so we
would require that the generator be notified before the waste was
transferred to one of the approved final transporters and that
the selection (and approval by the generator) is noted on the
manifest.
This procedure might better reflect the actual situation at
the time the generator signs the manifest than the current
requirements. It would, however, require at least as much.space
on the manifest as the current procedure of putting down the most
likely transporter and then modifying the manifest if necessary,
and would require the same step of communication with the
generator before making the notation of the actual transporter on
the manifest. For that reason, we think the existing
requirements are sufficient.
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We appreciate your making a helpful suggestion. At some
point we would like to reexamine the manifest forms and a variety
of issues that arise in their use, but we are unable to commit
our resources to that at the moment. We will keep your
suggestion on file for reconsideration if we get the opportunity
to complete a reexamination of the manifest forms. For now, we
cannot approve the approach you recommend.
Sincerely
Sylvia K. Lowrance, Director
Office of Solid Waste
2
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9453.1990(03)
RCRA/SUPERFDKD HOTLINE MONTHLY SUMMARY
OCTOBER 1990
Clarification of Section 262.34(a) Accumulation Time for Excess of
55-GalIon Limit in Satellite Accumulation Areas
The owner/operator of a manufacturing company maintains a
generator satellite accumulation area pursuant to Section 26234(c). The
operator lias exceeded the 55-gallon accumulation limit and according
to Section 26234(c)(2), has three days to remove this waste from the
satellite area and manage it either in a 90-day storage area as a large
quantity generator in compliance with Section 26234(a), manage the
waste at an on-site permitted unit, or ship the waste off-site. Does the
90-day accumulation time for large quantity generators in Section
26234(a) begin at the time the 55-gallon limit is exceeded or after the
three-day transition period in Section 26234(c)?
Clarification of Section 26234(a) Accumulation Time for Excess of
55-Gallon Limit in Satellite Accumulation Areas (Cont'd)
The owner/operator has up to a 93-day accumulation time for the
excess waste generated at the satellite accumulation area (90-day
clock in Section 26234(a), plus up to three days for waste transfer).
The March 24,1986 Federal Register, which clarifies small quantity
generator provisions, states "...as soon as the 55-gallon limit has
been exceeded in any satellite area, any excess waste is subject to all
applicable RCRA requirements within three days. This means that
the 180/270 day on site accumulation provision for 100-1000 kg/mo.
generators applies to any excess waste three days after the 55-gallon
limit has been exceeded." (51 EE 10162). If the generator chose to
remove the waste from the satellite area before the three-day
transfer provision expired, he would subject the waste to the 90-day
clock provisions. For example, if the above operator chose to move
his excess waste from the satellite am after just one day, the 90-day
accumulation time in Section 26234 would begin as the waste
entered the 90-day accumulation area, not after three days. The
generator has chosen not to utilize the other two days that were
available for transfer.
Source:	Emily Roth, OSW (202) 382-4627
Research: Mic LeBel, GEC
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9453.1991(01)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
JUKI 1991
2. Withdrawal of an Interim St»m< Part A Permit Application
A generator is treating hazardous waste that exhibit a toxicity characteristic on-site
in its 90-day accumulation tanks. Prior to the effective date of the Toxicity
Characteristic rule, he/she filed a Part A application for 40 CFR Part 265 Interim
Status. The generator subsequently discovered that a permit is not required for
treatment in accumulation tanks provided that the tanks areoperated smdym^
compliance with all applicable standards referenced in 40 CFR26234. (51FR10168)
What procedures should be followed for the Part A permit application to be
withdrawn? Would the generator be subject to interim status standards until the
application is withdrawn?
In an internal 1983 memorandum, EPA clarified the protective filer
procedures for withdrawal of a Part A application. The memorandum stated
that filings for facilities which have not been regulated under interim status
standards should be returned to the owner or operator, preferably after EPA
has (1) obtained written confirmation that the facility was not subject to the
permitting requirements, and (2) possibly conducted an investigation to
verify the data.
Such a facility is not subject to the Part 265 standards until the application is
withdrawn. Section 3005(e) of RCRA states that the interim status standards
apply to any person who owns or operates a facility required to have a permit
under that section. If the facility, in fact, has not managed hazardous waste in
a manner that would subject it to regulations, then the Part 265 standards
would not be applicable, even if a Part A permit application had been
mistakenly submitted (as in the case of protective fillers). Thus, the generator
would not have to operate or close in accordance with interim status
standards.
Source: Wayne Roepe/OSW	(202) 475-7245 *
Research: Amy Norgren
C7
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9453.1991(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SEP 2 0 1991
Mr. Thomas McCarley
Hazardous Technical Information Services
Directorate of Technical Operations
Defense Logistics Agency
Defense General Supply Center
Richmond, Virginia 23297-5000
Dear Mr. McCarley:
This letter is in response to a July 24, 1991 inquiry from
Mr. Allen J. Osborne of your office about the treatment of
hazardous wastes by large quantity generators under the Resource
Conservation and Recovery Act (RCRA).
Mr. Osborne cited a March 24, 1986 Federal Register notice
(51 FR 10168) which promulgated final regulations for generators
of between 100 and 1000 kilograms of hazardous waste per month
(small quantity generators). In that notice, the Environmental
Protection Agency (EPA) stated that generators could treat
hazardous wastes on-site in accumulation tanlcs or containers
without a RCRA permit if the treatment were in conformance with
the requirements of 40 CFR Part 262.34 (accumulation time), and
with Subparts Z and J of 40 CFR Part 265 (standards for
containers and tank systems). Mr. Osborne apparently desired
clarification that large quantity generators were included in
this statement. Be also asked which kinds of hazardous wastes
could be treated by different categories of generators.
The Agency has not restricted treatment of any hazardous
waste to large or small quantity generators. However, all
generators who choose to treat their wastes in accumulation tanks
or containers must comply strictly with the requirements of 40
CFR Part 262.34 and with Subparts I and J of 40 CFR Part 265.
For example, the tank or container in which the treatment occurs
must be marked with the'date the accumulation period began. The
tank or container must be completely emptied every 90 days (or
every 180 or 270 days for small quantity generators). If these
requirements are met, no RCRA permit is required for large or
small quantity generators. Treatment other than that conducted
in tanks or containers (e.g., incineration, land treatment, or
treatment in surface impoundments) would continue to require a
permit.
^H%
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In addition, 40 CFR Part 268.7(a)(4) states that generators
who treat wastes in accumulation tanks or containers to meet
applicable land disposal restrictions (LDRs) must prepare a waste
analysis plan. Treatment of hazardous waste must also not
violate the dilution prohibition standards of 40 CFR 268.3.
The interpretation in this letter reflects the Federal
regulations governing hazardous waste. States with authorized
RCRA programs may impose more stringent requirements.
I hope this letter has addressed your concerns. If you have
any further questions, please contact Hitch Kidvell of my staff
at (202) 260-«|||e-.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste
2
3H1
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9455/1991(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCV
WASHINGTON, D.C. 20460 ,
pEB 5 mi
office of
SOLID waste AND emergency BESPONSi
Thomas E. Linson
Hazardous Haste Management Branch Chief
Indiana Department of Environmental Management
105 South Meridian Street
P.O. Box €015
Indianapolis, Indiana 46206-6015
Dear Mr. Linson:
This letter responds to your January 4, 1991 request for a
regulatory interpretation regarding the export of hazardous
wastes utilized for precious metals reclamation. Specifically,
you question whether Federal regulations require compliance with
40 CFR Part 262 Subpart E (which regulates hazardous waste
exports) when a precious metal-bearing sludge is exported for
reclamation. You request this interpretation because the export
requirements of Part 262 Subpart E are not specifically
referenced in either section 261.6(a)(2) or 266.70. However, as
Mr. Glenn Stemard of U.S. EPA's Region V office has indicated,
the preamble to the August 8, 1986 rulemaking (51 PR 28664),
which promulgated the export requirements for hazardous wastes,
implies that the export requirements do, in fact, apply to any
generator required to prepare a manifest under Subpart B of Part
262.
Mr. Stemard is correct. The export requirements of Part
262 Subpart E are applicable for precious metal-bearing sludges
that are exported for reclamation. EPA agrees that a specific
reference to Part 262 Subpart E in section 266.70 would clarify
this requirement and we will keep this in mind during any future
, -xule changes. As the preamble to the August 8, 1986 rulemaking
discusses in depth (while not specifically referring to hazardous
wastes used for precious metals recovery), the determining factor
in applying the export requirements is whether or not the
transportation of a particular hazardous waste requires a
hazardous waste manifest. (Indeed, the preamble actually
explains the Agency's position that the export requirements
applies only to hazardous wastes which require a manifest, rather
than to may hazardous waste, which is how some of the commenters
on the proposal to this rulemaking interpreted Section 3017 of
RCRA.)
Therefore, in the absence of any specific exemption from the
export requirements for a hazardous waste that requires a
manifest, the export requirements apply. Hazardous wastes which
Printad on Recycled Pat
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2
are subject to Part 266 Subpart F are not specifically exempt
from the export requirements.
I hope this clarifies the applicability of the export
requirements for the situation you must resolve. If you have any
further questions, you may contact Mike Fetruska, Chief of the
Regulatory Development Branch, at (202) 475-8551.
Director
Office of Solid Waste
35|
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y*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9455.1991 (02)
WASHINGTON, D.C. 20460
MAY 1 6 199!
Mark J. Schuiz
0"ICE OF
SOUO WASTE AND EMERGENCY RESPONSE
President
Pharmaceutical Services, Inc.
Browning-Ferris Industries
757 N. Eidridge
Houston, Texas 77079
Dear Mr. Schuiz:
This responds to your February 22,1991 letter to David Bussard requesting a
determination regarding the regulatory status of pharmaceutical products that are
returned by the dispensers of these products to the manufacturers, wholesalers, or to a
third-party service company that will facilitate the processing, crediting, and, if needed,
appropriate disposal of the returned products. Currently, such products are returned
directly to the manufacturer or wholesaler, who credits the dispenser for the products
and determines whether the products are to be reused, reclaimed, or appropriately
disposed. BFI Pharmaceutical Services, Inc. (BFI-Pharm) intends to provide this reverse
distribution service to the pharmaceutical industry.
As I understand your letter, pharmaceutical products may be returned for many
reasons, including, among others: 1) an oversuppfy at the dispenser, 2) expiration of the
recommended shelf life, 3) a recall has been initiated by the manufacturer, 4) the
product was received as a result of a shipping error, and 5) the product has been
damaged You state that, in general, the dispensers of the pharmaceutical products do
not know whether the returned products will be reused, reclaimed, sold overseas, or
disposed (ie, they are not able to determine whether these materials are solid wastes).
Because the dispensers receive credit for the returned products (either because the
products actually have real value to manufacturer or because such credits are part of a
competitive marketing approach), the products have a monetary value to the dispensers
' and they would not normally assume such materials to be wastes.
Under our current regulations, such returned products are not considered solid
wastes until a determination is made to discard these materials. The returned products
themselves (being "commercial chemical products" under our classification system) are
considered more product-like than waste-like (until a determination is made to dispose
of them) because recycling by use/reuse is generally a viable option. If the underlying
assumption is that the returned products will be recycled, until the manufacturer or
wholesaler determines otherwise (assuming that this determination is beyond the ability
of the dispenser), then those products managed within the reverse distribution system
are not solid wastes until the manufacturer or wholesaler makes the determination to
dispose of them. Ibis view is based on our understanding that the system is established
as a means to facilitate the recycling of reusable pharmaceutical products, rather than a
•*.$>
Pnrrmd on Fiecycted f>3
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waste management system. We will be interested to learn if your data, which will be
computerized, will support this assumption. At the current time there does not appear
to be any reason for EPA to change its policy regarding this type of reverse distribution
system simply because a third-party service company is involved rather than the
manufacturers themselves.
I would like briefly to bring to your attention two issues that bear generally upon
reverse distribution systems, although neither appear to be of concern in the BFI-Phann
situation. First, EPA does not intend for hazardous waste brokers to use a reverse
distribution system to relieve generators of the responsibility for making determinations
about the discarding of materials as wastes. It remains the generator's responsibility to
properly identify secondary materials. Second, a reverse distribution system cannot be
used as a waste management service to customers/generators without the applicable
regulatory controls on waste management being in place. Of course, as I discussed
above with respect to the BFI-Pharm situation, to the extent that the materials involved
are unused commercial products with a reasonable expectation of being reveled in some
way when returned, the materials are not considered as wastes until a determination has
been to discard thaw*
This interpretation is based on the current set of Federal RCRA regulations.
However, as you know, authorized States may regulate or interpret the regulations
differently, and State requirements are the applicable standards in authorized States.
You should contact the appropriate State regulatory agencies for a more definitive
regulatory determination for their respective jurisdictions.
I hope this has sufficiently answered your questions. Should you have any further
questions regarding EPA's policies, you may contact David Bussard at (202) 382-4637.
Office of Solid Waste
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9455.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC I 0 199!
0*etCE O*
SOLID WASTE AND EMERGENCY response
Jack Whalen
Hamanna Alloys Corporation
441 Lexington Avenue
Hew York, NY 10017
Dear Mr. Khalens
Thank you for your letter of October 31, 1991 to Mike
Petruska in which you inquired about the regulation of recovered
lead and lead alloys from used batteries and other suitable
sources, and the export of these components to other countries.
There are potentially numerous regulations applicable to recovery
of lead and lead alloys from batteries, depending on the
particular situation. Based on your letter I will list the major
ones here; however, please note that this list may not be
exhaustive: 40 CFR Parts 124, 260.10, 260.30(c), 261.1(c)(6),
261.2(c), 261.3(a)(2)(i), 261.6(a)(3)(iv), 261.22, 262.34, 263,
264.1(g)(6), 265.1(c)(10), 266 Subpart 6, 266.80(a),
266.80(b)(l)-(4), 268.7(a)(4), and 270. Because analysis of the
appropriate regulatory scheme is material-specific, 1 cannot
address lead and lead alloy recovery from "other suitable
sources."
Hazardous waste export regulations are found at 40 CFR Part
262 Subpart E. The governmental notification process is
generally as follows. The exporter notifies EPA*s Office of
Waste Programs Enforcement in writing of his/her intent to
export. This notification must contain certain information (see
the regulations cited above). EPA then sends the written
notification to the U.S. State Department, which then cables it
, " to the government of the receiving country. The receiving
country then cables the State Department with its consent or
rejection, and includes conditions for acceptance, if any. The
State Department forwards the cable to EPA, and EPA forwards it
to the exporter. Upon the exporter's receipt, this document is
called the EPA Acknowledgement of Consent (AOC). She exporter
must attach a copy of the AOC to the manifest accompanying the
shipment, and must forward a copy to the U.S. Customs Service (a
manifest may be obtained from your state if it has its own, or
from any source if it does not). Transit countries, if any, are
also notified within this process; however, if a transit country
refuses the shipment it is the exporter's responsibility to make
other arrangements.
pH
@ Pmml or Recycled Pap*
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2
Under the terms of separate bilateral agreements with Canada
and Mexico, this process is slightly different. For exports to
Canada, EPA deals directly with its counterpart, Environment
Canada, and the U.S. State Department and other diplomatic
entities do not become involved. The consent process is "tacit"
instead of written? that is, Canada has 30 days to accept or
refuse a shipment after which, if no acknowledgement is made, the
shipment may commence. For exports to Mexico, EPA deals directly
with its counterpart, SEDUE, but copies of all relevant documents
are forwarded to the State Department and normal diplomatic
entities.
As you may be aware, President Bush signed the Basel
Convention on the Transboundary Movement of Hazardous Wastes on
March 22, 1990. This may have additional implications for
hazardous waste exports depending on whether the U.S. formally
ratifies Basel, and on what form the implementing legislation
takes.
Sincerely,
!vid Bussard, Director
laracterization and
Assessment Division
Enclosure
3S5
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Volume 7
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 7
35k
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J**01**,
9461.1990(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCV
f	WASHINGTON, D.C. 20460
OCT 3 0 1990
c"
Office of
TO:	David Ullrich, Acting Director
Waste Management Division (5H-12)
Thank you for your memorandum of July 19, 1990, requesting an interpretation of
the regulations pertaining to "transfer facilities" in relation to designated facilities and
permitted and interim status facilities.
The first issue you raise concerns whether a permitted or interim status treatment
and storage facility can function as a transfer facility and temporarily store hazardous
waste destined for another facility (the designated facility) for processing. The answer to
this question depends on whether the transfer facility is also the "designated facility"
indicated on the manifest A permitted or interim status facility that has not been
designated on the manifest as the "designated facility" mav serve as a transfer facility for
shipments of waste awaiting further transportation to the designated facility. The
limiting conditions are the definition of "transfer facility," itself (Section 260.10) and the
provisions of Section 263.12, Len storage not to exceed 10 days, and containers must
meet DOT requirements. A permitted or interim status treatment and storage facility
'that is the "designated facility" for a particular shipment of waste cannot function as a
transfer facility with respect to that waste. "Designated facility" is defined in 260.10 as a
hazardous waste treatment, storage, or disposal facility that is permitted or has interim
status, that is regulated under 40 CFR 261.6(c)(2) or Subpart F of 40 CFR Pan 266, or
another facility allowed by the receiving State to accept such waste and that has been
designated on the manifest by the generator pursuant to 40 CFR 26220, [See 55 FR
2353, January 23, 1990 for recent EPA statement on the designated facility issue.]
The term "transfer facility" is defined in 40 CFR 260.10 as "any transportation
related facility including loading docks, parking areas, storage areas and other similar
areas where shipments of hazardous waste are held during the normal course of trans-
portation," The key part of this definition is the phrase "during the normal course of
transportation." Arrival of a manifested shipment of wiste at the "designated facility"
constitutes completion of the transportation phase, suc« that the transfer facility
provisions will no longer apply. That is, the manifested shipment cannot be stored for
Primtd m	¦' - <<
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10 days or less under 40 GFR 263.12 once it arrives at the designated facility. This issue
is discussed in the attached letter dated August 31, 1988 from Sylvia Lowrance, Director
of the Office of Solid Waste, to Richard Svanda, of the Minnesota Pollution Control
Agency.
The second issue you address is the consolidation of wastes by a transporter at a
transfer facility. Wastes are routinely combined at transfer facilities; often
containerized waste is transferred to a tanker truck. However, you are correct that the
December 31,1980 Federal Register as well as subsequent notices on the topic of
transportation do not place any additional requirements on transporters that consolidate
wastes at transfer facilities.
There are no EPA Federal standards or requirements that apply specifically to
transfer facilities other than the storage time limitation of 10 days and other provisions
of 263.12. There have not been any new policy or guidance documents on the topic of
transfer facilities since the regulations were promulgated. However, you should note
that transporters who store hazardous waste at transfer facilities must comply with all
applicable requirements of the transporter regulations of Part 263 (e.g., Subpart C,
Hazardous Waste discharges).
Under certain circumstances, transporters are required to comply with the
requirements that apply to generators of hazardous waste. A transporter who mixes
hazardous wastes of different Department of Transportation (DOT) shipping
descriptions by consolidating them into a single container must comply with 40 CFR Part
262, Standards Applicable to Generators of Hazardous Waste (40 CFR 263.10(c)(2)).
The Agency does not intend to encourage transporters to combine wastes of different
DOT descriptions. On the contrary, the imposition of the generator requirements
should provide sufficient cause for the transporter to avoid such waste combinations
whenever possible. The transporter who mixes hazardous wastes of different DOT
descriptions is obligated to remanifest the waste. For example, a change in the DOT
"proper shipping name" or hazard class would require the completion of a new manifest.
The act of combining wastes may also result in changes in containers. Therefore,
the container designations on the manifest would need to be changed as well In a
, -Situation involving only one or two minor changes, such as container changes, the
original manifest could be marked to reflect the changes. In other cases such as the
situation mentioned above involving a change in shipping description, a new manifest
would have to be initiated. In any case, whether a new manifest is initiated or not, lh£
waste mav only be delivered to the designated receiving facility as indicated on the
original manifest bv the original generator of the waste. In other words, transporters
would not be able to combine waste (resulting in a DOT description change), and
remanifest the waste to a designated facility that was not indicated on the original
manifest by the original generator as the designated facility.
In regard to the compatibility of wastes being mixed, I refer you to the document
entitled "A Method for Determining the Compatibility of Hazardous Wastes," order
number 600/2-80/076, available from EPA's Office of Research and Development ((513)
2

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569-7562). An individual consolidating wastes in containers should also refer to
Appendix V of 40 CFR Part 264. This appendix groups materials according to their
potential incompatibility.
With respect to your questions regarding notification, several issues require
clarification. Under Subpart D of 40 CFR 266, facilities which qualify as marketers or
burners are required to notify the Agency of their hazardous waste fuel activities, even if
they had previously obtained an EPA identification number. See 40 CFR 26634(b) and
26635(b), respectively. Marketers are defined as generators who market hazardous
waste fuel directly to a burner, persons who receive hazardous waste from generators
and produce, process, or blend hazardous waste fuel, and persons who distribute but do
not process or blend hazardous waste fueL If the service centers fall into any of these
categories, they are considered marketers of hazardous waste fuel and are required to
renotify to identify their hazardous waste fuel activities.
	You are correct that the EPA identification number is location-specific. Under 40
CFR 263.11, a transporter is prohibited from transporting hazardous wastes without
having received an EPA identification number. Currently, this number is assigned to the
transportation company as a whole; all of the individual transporters (trucks) in a given
shipping company have the same EPA ID number, the number that the transportation
company was issued and which is issued to the company's headquarters location.
Your final question concerns the identification number that should appear on the
manifest accompanying the waste at the transfer facility. Regardless of whether the
transfer facility is acting as a transfer facility or a regulated storage facility, the
identification numbers appearing on the manifest would be the EPA identification
numbers associated with the generator of the waste, all the transporters who transport
the waste, and the designated facility.
In the situation you describe, in which one company transports waste to and from
a transfer facility it operates, and the waste remains under the control of the transporter,
no separate EPA ID number need be entered on the manifest specific to the transfer
facility. However, you should note that waste must remain under the control of a
transporter as designated on the manifest while at a transfer facility. As described in
' detail in the regulations, a transporter may only deliver wastes to: (1) the designated
facility listed on the manifest, (2) an alternate designated facility, (3) the next designated
transporter or, (4) a place outside the United States designated by the generator (40
CFR 263.21). Until the signature of the designated facility or subsequent transporter is
obtained, the waste is considered to be in the custody of the transporter who last signed
the manifest (45 £B 12739; February 26,1980).
As mentioned briefly above, transporters must comply with the generator
standards of 40 CFR Part 262 when they mix wastes of different DOT descriptions (40
CFR 263.10(c)(2)). They must remanifest the waste to accurately refleci the
composition of the waste. Although they may indicate on the manifest in box 15 the
name of the original generator(s) of the combined waste, they must represent themselves
as the generator of the new waste. Although by creating or generating a new waste they
3
35
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have taken on some of the generator requirements, the transporter should continue to
manifest the waste to the designated facility as indicated on the original manifest by the
original generator.
I realize that this letter contains an abundance of information. If you would like to
discuss any of the topics further, please have your staff contact Emily Roth of my staff at
FTS 382-3098.
Attachment
4
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9461.iyyn.Ui)
RCRA/STJPERFOHD HOTLINE MONTHLY SUMMARY
NOVEMBER 1991
Transfer Facility as Central Collection
Point
A company generates small quantities of
hazardous waste ax several separate field
locations. The company does generate more than
100 kilograms of hazardous waste per month at
each separate field location. May the company-
use a transfer facility as a central collection point
to consolidate waste from these field locations?
Yes. A company may consolidate waste from
several locations or generation sites at a central
point provided that certain requirements are met.
First, each generation site must have an EPA
Identification No. and meet all applicable
requirements under 40 CFR Part 262. In
addition, each shipment of hazardous waste mu>t
be accompanied by a hazardous waste manifcM
"J the transporter must also have an EPA
ificationNo.
The transfer facility provision under §263 \2
may be applied to a situation such as this one
under the following conditions. According to
§260.10. a transfer facility is defined as "any
transportation-related facility including loading
docks, parking areas, storage areas and other
similar areas where shipments of hazardous * jmc
are held during the normal course of
transportation.'' The transfer facility is the
place where transporters consolidate shipments
or transfer shipments to different vehicles in
order to redirect them; this activity usually
takes place over a short period of (45 FR
86966; December 31.1980) Section 263.12
allows a transporter to store manifested
shipments of hazardous waste at a transfer
facility for up to 10 days without obtaining a
permit. During this time the hazardous waste
must be held in containers which meet
Department of Transportation (DOT)
packaging requirements. As long as the central
collection point meets the definition of a
transfer facility, the company may use it to
consolidate shipments of hazardous waste from
different generation locations. Note that if a
transporter mixes hazardous wastes of different
DOT shipping descriptions. §263.10(c)
requires compliance with 40 CFR Part 262.
Standards Applicable to Generators of
Hazardous Waste.
3U
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9472.1991(01)
NOTE
SUBJECT: Location Standards for Hazardous Waste Management Facilities
TO.	Bob Knox
You recently requested information on our hazardous waste facility siting
requirements in response to a request by Gordon Binder, who is concerned about
potential environmental equity issues in the siting process. The following is a summary
of our current siting requirements and an overview of new standards that are being
developed. Both current standards and those under development are based on technical
suitability of a site; economic or other factors are not considered. Historically,
hazardous waste units have been associated with industrial manufacturing plants. The
siting of these plants is controlled by local zoning requirements.
EPA currently has limited regulatory restrictions for the siting of hazardous waste
treatment, storage, and disposal facilities (TSDFs). These siting restrictions are based on
the sensitivity of the environment; they restrict TSDFs from locating in 100-year
floodplains and areas prone to severe earthquake damage in certain parts of the western
United States.
The Agency, however, is currently developing more restrictive siting criteria for
TSDFs. These more restrictive criteria will also be based on the sensitivity of the
environment. Certain very environmentally sensitive locations will be subject to absolute
siting prohibitions. New and expanding TSDFs will be prohibited from siting in
wetlands, in historic migration zones of rivers and coastal waterways, and directly over
active seismic faults. The proposed location standards will also place additional
conditions and restrictions on TSDFs in unstable areas, areas susceptible to earthquake
.-damage anywhere in the United States, karst terrane (limestone areas prone to sinkhole
development), hydrogeologically complex areas, and areas over high-resource-value
ground waters (e.g. drinking water areas). Additional requirements in these sensitive
locations include either technical or health-based demonstrations by the owner or
operator of the TSDF. Technical demonstrations would generally involve engineered
modifications to the environment or to the unit that would mitigate against the location-
specific hazard.
EPA is not alone in recognizing the need for TSDF location standards in certain
sensitive locations. To date, 38 states have either proposed or promulgated location
standards that are more stringent than the Agency's current siting standards. Some of
the States' siting standards are even more stringent than what the Agency is proposing.
For example, the State of South Carolina also requires TSDF siting setbacks from
schools and waterways.
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The specific location selected for a TSDF is a local decision. However, because
EPA regulations are based on the technical suitability of a site and not on economic or
other factors, they ensure that the selected TSDF site is protective of the environment
Furthermore, the EPA and State permitting process ensures public participation in
establishing the conditions for the TSDF, including its location, design and operation.
Jeff Denit
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9476.1991(01)
**2-1991

Mil
SUBJECT: Closure Standards for Hazardous Haste Land Treatment
Units
FROM: Devereaux Barnes, Director
Permits and State Programs Division
Office of Solid Waste (OS-340)
TO:	Doug McCurry, Chief
Waste Engineering Section
RCRA Branch, Region IV
You previously raised a series of questions regarding the
closure of hazardous waste land treatment units to my staff and to
the ORD laboratory in Ada (RSKERL-Ada). These are important
questions since many land treatment facilities are beginning to
close in response to the November 8, 1990 prohibition of the land
disposal of the petroleum refining wastes (K048-52). After
consulting with RSKERL-ADA, as well as internally, we are providing
you with the answers you sought. It is important to keep in mind
that of the four major types of land disposal units, the land
treatment unit is the most difficult for which to define generic
technical closure procedures. This is due to the fact that the
characteristics of the soils affecting the closure are by nature
site-specific, and that the wastes are to be transformed, degraded,
or immobilized during the closure process by the soil, biologic,
and climatic conditions unique to each site. With this constraint
in mind, we have addressed your questions as specifically as
possible:
1. Q. Is soil sampling required during closure/post closure?
A. Section 265.280(d)(1) requires that during the closure
period the owner or operator of an interim status land
treatment facility continue unsaturated zone monitoring
in a r-nner and frequency specified in the closure plan,
at+mtm to |tiV
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2
90 days after the last application of waste to the
treatment zone. Unsaturated zone monitoring consists of
both soil-pore liquid monitoring and analysis of soil
cores (see Sections 265.278(a) and (b)).
In addition, Section 265.280(f) requires that during the
post-closure care period the owner or operator of an
interim status land treatment unit must continue soil-
core monitoring [soil sampling] in the manner and
frequency specified in the post-closure plan.
Similarly, permitted units must continue unsaturated zone
monitoring during closure and post-closure care periods,
as specified in the permit (see Sections 264.280(a)(7)
and (c)(7)).
Given the language of Sections 264.280 and 265.280, we
expect that in most cases unsaturated zone monitoring
(particularly soil-core) will be necessary during the
closure and post-closure care periods of a land treatment
unit. There are, however, limited instances where soil-
core monitoring may not be required by the closure and/or
post-closure plan. For example, in the case where the
treatment zone is removed as a part of clean closure,
soil-core monitoring may be suspended at the completion
of the closure period. (See. Sections 264.112(e);
264.280(c); 265.280(d) and (f)(1)).
2. Q. At what intervals and for how long?
A. General guidance pertaining to soil sampling intervals
and duration during land treatment site closure/post-
closure is provided in several land treatment guidance
documents:
Guidance Manual on Hazardous Waste Land Treatment
Closure/Post-Closure (OSWER Directive 9476.00-9)
Permit Guidance Manual on Unsaturated Zone
Monitoring for Hazardous Haste Land Treatment Units
(EPA/53 O-SW-86-040)
RCRA Guidance Document : Land Treatment (NTXS-PB-
155065)
Permit Guidance Manual on Hazardous Haste Land
Treatment Demonstrations (July, 1986)
Although the guidance provides a general framework for
soil sampling, the geographic, spatial, and temporal
variabilities between different land treatment units (as
well as within any individual unit) necessitate that
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3
site-specific considerations be evaluated when
establishing the sampling intervals and duration required
during closure/post closure of a given land treatment
unit.
Data from the reconnaissance survey is used, as the
primary basis for establishing site-specific sampling
requirements. If this survey reveals that the facility
has been veil managed, with no apparent significant
buildup or downward migration of hazardous constituents,
the general guidance provided in the above-referenced
guidance documents can be used to establish soil sampling
intervals and duration. He recommended that, at a
minimum, samples should be collected quarterly during the
closure period and during the first year of the post-
closure period. Periods between sampling events may be
gradually extended after the first year of post-closure.
If data from the reconnaissance survey reveals an
apparent significant buildup and/or downward migration
of hazardous constituents, the general guidance alone
will not be sufficient to establish soil sampling
intervals and duration, tinder such a scenario, soil pore
liquid samples should continue to be collected as
recommended in the Permit Guidance Manual on Unsaturated
Zone Monitoring for Hazardous Haste Land Treatment Units
(EPA/S30—SH—86-040). The soil pore liquid monitoring
should continue until there is no longer potential for
vertical migration of fast-moving hazardous constituents
from the waste-soil matrix. Additionally, it is
important to collect soil cores downward through the
treatment zone into the unsaturated zone for analysis at
selected intervals along the core in order to determine
the extent of degradation and immobilization within the
treatment zone, as well as the migration of less mobile
waste constituents into the unsaturated zone. Under this
scenario, actual degradation rate data under the closure
conditions may be deemed important. If such is the case,
sampling intervals should be shorter than specified in
the guidance.
Two recent land treatment research studies, sponsored by
RSKERL-Ada, provide useful guidance because they involve
a determination of degradation rates under field
conditions. These studies used the following sampling
schedule: 0, 2, 4, and 8 weeks, and continued at 4-week
intervals throughout the study. Under a closure
scenario, the sampling schedule should use these same
intervals, or other type of appropriate sampling
interval, until a minimum of 6 data points are obtained
or until an asymptotic constituent level is approached.
Any time degradation rates are to be calculated, a
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4
minimum of 3 replicate sample analyses are recommended
for each sampling date in order to establish a 95%
confidence interval for the degradation rates and half-
llves of the waste and its constituents. After you
determine that degradation is proceeding at an acceptable
rate and that downward migration is not occurring,
quarterly sampling (as recommended in the general
guidance) can be initiated.
3.	Q. Does EPA recognize approved methods for determining
degradation rates?
A. There are no EPA-approved methods for determining
degradation rates, although methods for determining
degradation rates are discussed in the Permit Guidance
Manual on Hazardous Waste land Treatment Demonstrations
(LTD). These are based on methods used in the land
treatment research program at RSKERL-Ada and documented
in the lab's publications. (See Attachment)
The need and approach for determining degradation rates
will depend to a great degree on the results of the
reconnaissance survey discussed under Question 2. Under
the well-managed scenario, we can see little need to
undertake this task unless the final loading rate is
significantly greater than that used during normal
operation. Under the poorly managed scenario, we would
consider this task a necessity. The actual approach for
determining degradation rates would vary somewhat
depending on the degree of the problem as well as waste
and site-specific characteristics. In addition to the
treatability study approach discussed in the LTD Guidance
Manual, the RSKERL-Ada publication Mobility and
Degradation of Residues at Hazardous Waste Land Treatment
Sites at Closure (See Attachment) specifically provides
information pertaining to the quantitative evaluation of
mobility and persistence of organic and inorganic waste
constituents which have accumulated in soil treatment
systems under various closure scenarios.
4.	Q. Can continued operations under closure last indefinitely?
At what concentration is closure complete? At what
concentration, degradation rate, or point in time does
operational closure cease and a RCRA cap become a
requirement?
A. As Sections 264.113 and 265.113 layout, closure is
ejected to be completed within 180 days after receiving
the final volume of hazardous waste, but a longer period
may be approved if the owner or operator can demonstrate
that closure activities will, necessarily, take longer
them 180 days (see Sections 264.113(b) (1) (i) and
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5
265.113(b) (1) (i)). In the case of a land treatment unit,
more than 180 days may be required to maximize
degradation, transformation, or immobilization of
hazardous constituents within the treatment zone. This
period cannot be defined by regulation in that each site
will require a time period specific to that site. The
duration of the closure period is primarily dependent on
the waste loading rate at closure as well as the
potential waste degradation rate. Each owner or operator
should, however, be able to estimate that time in
advance, based on the treatment data already established
during operation. For the large majority of well-managed
land treatment units, the duration of the closure period
will vary between 90 and 360 days.
Because land treatment closure is a continuing process
rather than a set of distinct engineering procedures (as
in landfill closure), the concentrations of hazardous
constituents remaining in the treatment zone after
closure may vary and will continue to change during the
post-closure care period. Post-closure care at a land
treatment facility is different from practices at other
closed or closing land disposal facilities in that active
management will frequently continue to enhance
degradation and transformation and sustain
immobilization. Complete degradation of organics to
background levels before closure has been completed is
not necessarily required. Concentrations of organics
should, however, be to the point that the application of
a final cover and the reduced level of active site
management will prevent the post-closure escape of
hazardous constituents from the treatment zone.
Similarly inorganics should be immobilized during closure
to provide the same level of protection over the long
term.
Zn the case where closure activities fail to immobilize
or degrade hazardous constituents, an impermeable cap
may be required or clean closure may be appropriate.
(Changes to the closure plan will require approval by
the Regional Administrator (Sections 264.112(c) and
265.112(c)). The determination of the rate of
immobilization and degradation is site specific; however,
escape of constituents from the treatment zone at
concentrations above health-based levels indicates that
the rate of immobilization or degradation is
unacceptable.
5. Q. What closure standards are required where migration of
hazardous constituents has occurred?
h. The general closure performance standard remains the same
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6
whether or not migration of hazardous constituents has
occurred. That is, the owner or operator must close the
facility in a manner that minimizes the need for further
maintenance; and that controls, minimizes, or eliminates
to the extent necessary to protect human health and the
environment, the post-closure escape of hazardous waste,
hazardous constituents, leachate, contaminated run-off,
or hazardous waste decomposition products to the ground
or surface water or to the atmosphere. (Sections 264.111
and 265.111).
Where hazardous constituents have migrated beyond the
treatment zone above health-based levels, successful
immobilization, degradation, or transformation during
closure may be subject to question. In this case
additional closure and post-closure activities may be
required that go beyond disking, adding soil amendments,
and installation of a vegetative cover. Obviously, the
additional activities will vary from site to site;
however, some of these activities may include, but are
not limited to, removal of some or all of the treatment
zone and installation of a low permeability cap. In
addition, cleanup of the contaminated media, e.g.,
ground-water removal and treatment, may be appropriate.
Cleanup of these media is a corrective action decision.
Whatever program of additional activities is selected,
it must be consistent with the goals specified in the
general closure performance standard.
6. Q. What closure standards are required where ground-water
contamination exists but where levels of contaminants
are within the ACL*s established by the permit?
A. At units where ground-water contamination exists but
where that contamination is below the established ACL,
corrective action under Section 264.100 may not be
required. The decision as to whether ground-water
cleanup is required is site-specific, generally based on
the principles described in EFA's proposed corrective
action rule (55 J£B 30798}. At the same time, the closure
standard to be applied remains the same (see previous
discussion).
Furthermore, having an ACL does not negate the treatment
demonstration requirement of Section 264.272. Zf it is
found during closure that constituents are migrating
below the treatment zone above health-based levels,
additional steps may be required, such as treatment zone
removal or installation of a low permeability final
cover. The determination of what steps are required will
depend primarily upon whether the hazardous constituents
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7
The owner or operator should be aware that the post-
closure care period cannot be terminated until the owner
or operator successfully demonstrates that all the ground
water at the site is safe for all potential receptors
(Alternate Concentration Limit Guidance, EPA/530-SW-87-
017).
7. Q. At what point in the life of the unit do closure
activities become in-situ remediation under corrective
action? At what concentrations and frequencies for soil,
pore-water, surface water and ground water? What permit
modifications are required?
A* Host actions taken to remedy migration of constituents
of concern outside the treatment zone (into ground water,
surface water, or soil adjacent to the treatment zone}
at closing units can be accomplished as a part of
closure.
At a permitted facility, methods for preventing such
migration should be outlined in the permit (see Sections
264.270-264.283). If, during closure, migratory
constituent concentrations are found to exceed levels
specified in the permit, a corrective action program must
be initiated (see Sections 264.S0-264.101). The addition
of a corrective action program requires a permittee to
initiate a Class 3 permit modification, although some
limited remediation activities, such as a change in the
number of ground-water monitoring wells at a regulated
unit, may require only a Class 2 permit modification (see
Appendix Z to Section 270.42). Such modifications may
receive temporary authorization provided they meet the
test of Section 270.42(e)(2). (Of course, Class 2 or 3
modifications would not be used in states authorized for
ground-water corrective action, but not authorized for
EPA's new permit modification procedures. In authorized
States, permit modifications must be made according to
state modification procedures.) In the alternative, the
Agency may take unilateral action to modify a permit to
require corrective action (see Section 270.41).
At an interim status facility, certain requirements
designed to prevent migration of constituents of concern
are specified in Sections 265.270-265.282 and 265.90-
265.94. Unlike permitted facilities, at present there
are no regulatory provisions requiring corrective action
when migratory constituent concentrations exceed
regulatory levels of concern. Instead, the Agency may
compel corrective action at an interim status facility
through the issuance of an administrative order pursuant
to RCRA, Section 3008(h). In addition, as an
alternative, the Agency may expedite the issuance of a
-------
8
permit to an interim status facility, with the result
that the corrective action provisions referenced above
would be applicable.
Completion of remedial activities may exceed 180 days.
As mentioned previously, this is a legitimate basis for
granting an extension of the closure period. In
addition, long-term remediation activities at regulated
units, such as ground-water counterpumping, may be
performed during the post-closure care period.
8. Q. At what point in time, and to what standards does a
facility certify closure?
A. This question is directly related to question 4 in your
letter. You will note in Sections 264.115 and 265.115
that closure is to be certified when the unit has been
closed in accordance with the specifications in the
approved closure plan. Closure will be complete when
closure activities have immobilized, degraded, or
transformed hazardous constituents in the treatment zone
to levels agreed upon in the closure plan and when a
vegetative cover has been established. In the case where
the treatment zone is ineffective, closure may be
certified after the treatment zone is removed or after
a low permeability cap is installed. Other long-term
activities such as ground-water remediation will normally
be completed during the post-closure care period and
after closure certification.
We hope these responses are useful. Please feel free to call
Chris Rhyme (FTS 382-4695) to discuss other technical aspects of
land treatment closure.
Attachment
cc: Sylvia Lowrance, OSW
RCRA Branch Chiefs, Regions I-X
Nancy Bethune, Region IV
John Matthews, RSKERL-Ada
Scott Huling, RSKERL-Ada
Tom Beisswenger* OGC
Susan Bromm, RED, OWPE
Chris Rhyne, AB, PSFD, osw
Barbara Foster, FB, PSFD, OSW
Dave Fagan, CAB, PSFD, OSW
-------
9476.1991(02)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
OCTOBER 1991
2. TSDF CIosure/Post-C1osur» After Loss
of Interim Status
Pursuant to 40 CFR §270J73(cX2)$ & Subtitle C
land disposal facility lost its interim status due to
the ownerioperator's failure to submit
certification that the facility was in compliance
with ail applicable groundwater monitoring and
financial responsibility requirements. The
ownertoperator has been told by his enforcement
agency that he is required to close his facility in
accordance with 40 CFR Part265, Subpart C
closure standards. Ifthefacility has lost its
interim status to operate, why should the awnen
operator be required to comply with interim
status standards to close the facility?
According ® 40 CFR §265.1(b), the standards of
Pari 265 are applicable to interim status facilities
until Pan 265 closure and post-closure respons-
ibilities are fbifiBed. As EPA explained in the
preamble to its November 21,1984, amendments to
the applicability seasons of Pat 265 (49 IE 46094),
EPA has statutory authority under §3004 ©enforce
the Pan 265 standards at facilities which no longer
have interim stasis to operate. The preamble
explains that such ferilities mast dose in accordance:
with 40 CFR Pan 265. Subpart G.
The September 25,1985, Register (50
IE 38949), specifically indicates that compliance
with all applicable closure and post-closure
requirements specified in 40 CFR 265, Subpart G is
required when a facility has km its interim status
dae to the owner/operator's failure to submit
certification of compliance with all applicable
groundwater monitoring and financial requirements
(40 CFR 5270.73(c)(2)) to the Regional
Administrator. Such a facility ownetfoperator must,
is accordance with 40 CFR §§265.112(d)(3)0) and
265.118(e)(1), submit a closure and post-closure
plan to the Regional Administrator no later than 15
days after icnninatwwi of interim status
3T3>
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9481.1991(01)
<&>
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE O*
SOLID WASTE ANO EMEHGENCr WESSONS!
October 16,1991
Glen D. Johnson
CommonweaMb of Pennsylvania
Dept. of Environmental Resources
P.O. Box 2063
Hanisbuig, Pennsylvania 17105-2063
Dear Mr. Johnson,
Four questions were raised in your letter of August 21. Hopefully our responses
will be satisfactory. If you still have any concerns please feel free to contact us again.
First, concerning the "Analysis of Retesting Procedures" paper, we have re-
examined our simulation code used to generate the power results given in that paper and
have examined the code you provided as weE It seems that the discrepancy between
our results can be traced to the method by which you generate future values lor
comparison to the sfnmlatrd prediction Emits.
The theory behind prediction intervals assumes that not only are the background
measurements drawn at random from a (Normal) distribution, but that the future values
to be compared against the prediction limits are also randomly drawn from the same
population. That is, two sources of variability are built into the equation used to
calibrate the width of a prediction interval: variability in the badcground measurements
(accounted for by the quantity W-i and by 1/n under the root symbol) and variability in
tiie future values (accounted for by adding 1 to 1/n under the root symbol).
In your SAS code, the fixture values for a given effect size are always fixed at the
expected mean level of the downgradient well No variation is built into these numbers;
consequently our power results differ. We have made an additional run of our
simulations (based again on 10,000 iterations) to give you approximate power levels is
the table below for each of the effect sizes you used. These results make sense from the
standpoint that if the alternative mean is dose to the background mean, adding variation
to the future values should increase how often these numbers fall above the prediction
limit and hence increase the power over what you derived. The reverse situation should
It true when the background and alternative means are far apart, as seen in the table,
for then the alternative mean will generally be above the prediction limit, and variability
in the future values will tend to lower the power somewhat
^3
Printtdorfiecyded
-------
EFFECT YOUR POWER OUR POWER
0.0
05
1.0
15
2.0
25
3.0
35
4.0
45
5.0
0.0000
0.0008
0.0051
0.0301
aui6
02698
0.4756
0.6946
0.8473
0.9386
0J801
aoioo
0.0257
0.0613
0.1189
02073
03319
0.4802
06256
0.7570
0.8568
0.9223
With regard to the article by Robert Gibbons in Ground Water (Vol. 29, No. 4,
1991), oar basic reaction to the method Gibbons proposes for monitoring large networks
of downgradient wells is not wholly unfavorable. There do seem to be advantages to
employing some type of retesting strategy in order to verify results from wells that show
possible contamination. EPA has in fact already approved a proposal from the State of
California that adopts a retesting strategy. However, the specific strategy put forward by
Gibbons, that is, an initial tolerance interval followed by a prediction interval on any
resampled wells, may or may not be the best retesting strategy. Hie approved California
proposal, for instance, consists only of prediction intervals with double resampling of
downgradient wells that initially exceed the prediction limit Both resamples must be
immediately collected from the monitoring well, and both must pass the retest to verify
that the initial Mure was a false positive.
In addition, Gibbons* article raises a few questions concerning the statistical logic
^ used. First, Gibbons* basic example hypothesizes a network of 20 downgradient wells,
' " each being monitored quarterly for fire constituents. As Gibbons notes, this results in
100 sample measurements per quarter that must be tested statistically. It is not true,
however, that all 100 values would be compared to single tolerance (or prediction) limit
calculated from the badeground data. Rather, each constituent would have to be tested
separately, leading to five separate tolerance (or prediction) limits each used to test 20
measurements. Clearly, it would not be the case that all five constituents would have
similar distributions of concentration values, this point is not crucial to Gibbons case,
but it is worth emphasizing that his hypothetical framework should actually lead to more
conservative prediction limits than he describes.
Another point is that Gibbons' discussion of Type I error rates when comparing
the performance of tolerance and prediction limits without resampling, particularly in
2

-------
regard to Figure 1 cm p. 568, is somewhat	Gibbons argues for instance that
"the 95% predicdon limit for the next 1000 measurements achieves its nominal error rate
of 5%. However, the false positive rate for the 95% confidence 95% coverage tolerance
limit is over 70%. Even 99% coverage produces a false positive rate of approximately
17%." What Gibbons means by false positive rate here is not the traditional Type I
error probability, rather, it represents the frequency with which any of the 100 sample
measurements falls above the prediction or tolerance limit
For prediction limits these two definitions of etror are the same, since the
prediction limit is designed to contain all of the 100 samples. For tolerance limits,
however. Gibbons* definition of the false positive rate is not correct, because a tolerance
limit is designed to "miss" a certain fraction of the tested measurements. Under 95%
coverage, a tolerance limit is expected to miss approximately 5 out of eveiy 100 new
samples. The tolerance limit only fails in the Type I error sense, if the actual coverage
of the limit is less than expected amount (e.g* 10 out of 100 samples fall above the limit
instead of the expected 5 or less). It is true enough that some measurements in a large
enough sample will fall above the tolerance limit; however, this does not indicate a
Mure of the tolerance limit to do its job. If 100 new measurements were collected from
a single downgradient well, and at least 95 of those values fell below the tolerance limit,
there would be no need to designate the well as possibly contaminated.
Granting the above comments, Gibbons does recognize a basic problem in
applying a tolerance limit approach to a set of measurements taken one per
downgradient well. That is, measurements which M above the tolerance limit may
indeed indicate contamination at particular wells, because distinct wells may have
different distributions of the constituent being tested. If data from many downgradient
wells are pooled together, the tolerance limit approach assumes that each well has the
same distribution of sample values and that values fall above the tolerance limit only
because a large enough sample from any (normal) distribution will haw a few extreme
measurements. This assumption may not be troe if just one or two downgradient wells
have been contaminated, so that some of the extreme values are the result of
contamination rather than just random variation in a large set of measurements. In
other words, by allowing a certain fraction of the values to be above the tolerance limit
(typically 1% or 5% of the concentrations), actual contamination at a very few wells
could be missed.
One solution to this problem is as Gibbons suggests to retest each well for which
the sample measurement falls above the tolerance limit A more practical alternative
not discussed in the article relates to the likely nature of contaminated wells for many
constituents. Experience with monitoring data suggests that an actual spill or leak from
a monitored facility results in concentration levels elevated typically by one or more
factors of magnitude above background levels. Samples from wells contaminated in this
way should be much greater in concentration than even extreme values from
uncontaminated wells. Consequently, it may be easy to identify contaminated wells by
-------
comparing the relative magnitudes of those samples which fall above the tolerance limit,
even in the absence of any retesting strategy.
Your inclination concerning ground-water sample independence with respect to
quarterly measurements is consistent with our experience in evaluating ground-water
monitoring data. Keep in mind, however, thai the 40 CFR Part 264, Subpart F
regulations require at least semiannual sampling, which may improve the likelihood of
sample independence In slow moving ground water. Further, well purging procedures
that are implemented prior to sample collection also improve sample Independence.
EPA is in the process of developing software for assisting Regional and State
personnel in evaluating ground-water monitoring data. The system (GRITS-ground-
water research information system) is an enhancement to an EPA Region YD data base
that uses 1 files for data input and will perform all of the Subpart F statistical
procedures. We plan to provide training on the system and the included statistical
procedures throughout the late summer and fall of 1992 (Philadelphia or a nearby
metropolitan area wiB be a hem training ate).
I hope that these comments have been useful. Please contact me at (202) 260-
3240 if I can be of farther assistance.
Sincerely,
James R. Brown
cc Denise Keehner
Vernon Myers
4

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Volume 8
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 8
211
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9483.1990(03)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP 2 0 1990
OFFICE OF
SOLID WASTE AND EMEHGiNCv RESPONSE
Philip F. Fox
Heritage Remediation/Engineering, Inc.
P.O. Box 51020
Indianapolis, IN 46251
Dear Mr. Fox:
This letter is in response to your letter dated July 16, 1990,
requesting several regulatory interpretations of the Federal
hazardous waste regulations in 40 CFR Parts 260 - 271. In your
letter, you had outlined your assumptions about the Federal hazardous
waste regulations' applicability in certain situations. You also
requested answers to a number of questions related to listed
hazardous wastes from petroleum refining, as well as the exemption
from permitting requirements available for certain wastewater
treatment units (WWTU's).
My staff has prepared responses to the assumptions about the
regulations that you outlined in Sections I and II of your letter,
and to the questions in Section III of your letter. The responses
are enclosed. However, please note that State or local regulatory
agencies may have regulations that are more stringent or are broader
in scope than the Federal hazardous waste regulations. Thus, any
facility-specific questions must be addressed by the EPA Regional
Offices, authorized States, and/or localities. If you have questions
on the responses provided here, please contact Becky Cuthbertson of
my staff at (202) 475-9715.
Sincerely,
Office of Solid Haste
Enclosures
hmui m iUeyeitd Pat
-------
Enclosure X
I- Response to Section T.
This section responds to certain points in Section I of the July
16, 1990 letter that we would like to clarify.
•	In Part A., Wastewater Treatment Unit Exemption, your
discussion refers to facilities in several places. Please be
aware of the specific meaning attached to the word "facility" in
the federal hazardous waste regulations; the wastewater
treatment unit exemption only applies to wastewater treatment
units that, among other things, meet the definition of "tank" in
40 CFR 260.10.
•	In your discussion of the 1981 Lehman letter, the broad
interpretation of "tank" in the Lehman letter refers to "unit
operations which are not obviously tanks such as filter presses,
filters, sumps, and many other types of processing equipment.**
It does not specifically mention filter pressing and cake
drying. [You should also be aware that EPA has proposed
regulating sludge drying units that do not qualify for the
wastewater treatment unit exemption. See Enclosure 2 (the July
is, 1990 federal Register, 55 ib 29230).]
•	At Line 70, the tank systems you refer to are subject to
permitting requirements if they are not eligible for another
exemption (including, but not necessarily limited to, the 90-day
exemption).
•	In Part B., Ninety Day Storage Exemption, we presume you meant
40 CFR 262.34(a)(1) - (4).
ZIC Response fro Sqgtjpn II t
The discussion of the regulations in II.A. and II.B. of the July
16, 1990 letter is fairly accurate. The determination of petroleum
refinery listing applicability is not addressed here; we presume that
the listing applicability has been correctly determined at the
refineries in question.
the discussion in II.C. of the July 16, 1990 letter contains
three terminology problems:
•	In Line 155, the exemption includes tanks and ancillary
equipment - not all process units.
•	In Line 156, we would say "which treat or store a sludge of a
wastewater treatment plant" - the term by-product has a specific
meaning and use in the Part 261 regulations (II 261.1 and

-------
Enclosure 1
bottoms are specifically listed under §261.32 as K052, and by-
products that are specifically listed are hazardous wastes when
reclaimed (40 CFR 261.2(c)(3)).
• In lines 208 through 214, you state broadly that 40 CFR Parts
262 - 270 apply to recyclable materials. However, certain
recyclable materials are not subject to regulation, or are
subject to reduced requirements, when they are managed according
to the terms of their exemption in Section 261.6.
III. Response to Section III.
Listed below are portions of the questions in Section III of
your July 16, 1990 letter, along with responses.
A.l. Does the refinery stand to lose its coverage under the
exemption if it accepts wastewater treatment sludges from other
facilities, such as neighboring refineries, for dewatering at its
facility?
We initially addressed this question in the July 31, 1981 letter
from John Lehman to Richard Boynton. In this letter, Mr. Lehman
explains that although the Agency contemplated limiting the exemption
to on-site wastewater treatment units, the Agency decided not to
differentiate between on-site versus off-site wastewater treatment
onits. This policy was reiterated in the September 2, 1988 Federal
Register (53 EE 34079), where we explained that "the applicability of
the exemption does not depend on whether the on-site wastewater
treatment facility also treats wastewater generated off-site."
Accordingly, the refinery may be able to use the wastewater treatment
unit exemption in 40 CFR 270.1(c) (2) (v) when accepting wastewater
from off-site. However, your question asked about wastewater
treatment sludge? while wastewaters may be accepted under the
exemption, the Lehman letter goes on to state that the facility can
receive wastewaters, but not concentrated chemicals or non-aqueous
wastes. As long as the wastewater treatment sludge is not a
Concentrated chemical or non-aqueous waste, the receiving facility
may receive it and still be potentially eligible for the wastewater
treatment unit exemption.
In addition, we note that the accepting refinery must qualify as
a "designated facility" in order to accept hazardous waste shipments
from off-site via air, rail, highway, or water (see the definition of
"designated facility" in 40 CFR 260.10, recently revised at 55 £&
2353).
2. Does it matter whether the company that owns the refinery
accepting sludge from the neighboring refineries also owns the
neighboring refineries?
3
~
Cf c
-------
Enclosure 1
S. If the wastewater treatment unit exemption eovera an onsite
facility, is the exemption modified or endangered if the facility
treats petroleum tank bottoms, either as a non-waste or as a
recyclable material (hazardous waste)? Does it matter that the tan*
bottoms coma from ma offsita facility such as another refinery or a
product		Does it make any difference whether or not the
exempted onsite facility's owner owns the tank bottoms?
Addressing your first question in this scenario, is the
exemption modified if the facility treats tank bottoms [which are a
non-waste] - we reiterate our explanation from Section II. that only
in certain situations are the tank bottoms not a waste (i.e., if they
are not listed and are reclaimed for use as feedstocks in a
lubricating oil refining process and not in a process where fuels are
made). In such situations, the placement of the tank bottoms in the
wastewater treatment unit has no effect on the availability of the
exemption, because the hazardous waste regulations govern only those
materials that are hazardous wastes. Addressing the variation where
the tank bottoms are a hazardous waste that is a recyclable material,
the wastewater treatment unit exemption is not available because the
tank bottoms are neither wastewater nor sludge (the two types o£
material that can be managed in an exempt wastewater treatment unit).
The question of the tank bottoms' origin is thus moot, as is the
question of who owns them.
S. Do the answers to amy of the above questions depend on
whether or not 50% or more of the treated waste is wastewater
treatment sludge generated onsite at the facility operating under the
wastewater treatment exemption?
No. There are no criteria that limit the exemption's
availability based on the facility where the sludge is generated.
B.l. If the riisted sludges K048 and K0S1 are! taken offsite to
a facility owned by a third party who is in the hazardous waste
treatment business and if the sludge treatment at the offsite
facility consists of dawaterino fcentrifuge/beIt press/filter
press/or similar!. is the offsite dewaterinq system eligible for the
40 CFR 270.if el f2> tvl wastewater treatment system exemption?
If the off-site facility meets the conditions in 40 CFR 260.10,
then it may be eligible for an exemption under §270.1(c) (2) (v). The
definition of wastewater treatment unit is specified in §260.10.
Assuming the unit is a tank and is subject to regulation under
sections 307(b) or 402 of the Clean Hater Act, the remaining
criterion specified in §260.10 is the type of material received and
the activity conducted ("Receives and treats or stores an influent
wastewater...generates and accumulates...or treats or stores a
wastewater treatment sludge which is a hazardous waste... Mr.
S

-------
Enclosure 1
requirements. However, the wastewater treatment unit exemption
itself is not altered by the TC.
5* Is the ansver to the main question starting at Line 276
different if tvo or more refiners jointly ovn the off site facility as
a partnership and if the refinery partners each send their respective
vastevater treatment sludges to the offsite facility?
The answer is not affected by the joint ownership (i.e.,
partnership) of the off-site facility receiving the sludge.
6. Zf the vastevater treatment unit exemption covers an offsite
facility, is the exemption endangered or modified if the facility
accepts petroleum tank bottoms, either as a non-vast* or as a
recyclable material (hazardous vaste)?
The exemption's applicability is indeed "endangered," or rather
the wastewater treatment unit's owner/operator would not be able to
claim it, if s/he did not meet the terms of the exemption in the
definition of wastewater treatment unit in §260.10. Specifically, •
the unit must receive and treat or store a wastewater, generate and
accumulate a sludge, or treat or store a sludge. As explained in the
response to question A.5., when the tank bottoms that are a hazardous
waste are neither a wastewater nor a sludge, the exemption is not
available.
Mote that if the recycling process where the tank bottoms are
reclaimed is legitimate recycling, then under 1261.6(c)(1) the
recycling process is exempt from regulation.
When the tank bottoms are not a waste (i.e. in the limited case
where they are being recycled for use as a lubricating oil refinery
feedstock, and are not specifically listed) or when they are not a
hazardous waste (i.e. are neither listed not exhibit a characteristic
of hazardous waste) the exemption's applicability is moot because the
hazardous waste regulations apply only to hazardous wastes.
C.l. can the refinery preserve the vastevater treatment unit
exemption for units dovnstream of the storage tanks if it obtains
RCRA permits for the storage tanks for the offsite vastevater
treatment sludge and/or for the petroleum tank bottoms?
The wastewater treatment unit exemption is not altered by the
regulatory status of other storage tanks located at the same
facility. If a hazardous waste storage tank does not meet the
necessary criteria in the definition of wastewater treatment unit,
that unit cannot be eligible for the wastewater treatment unit
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9483.1991(01)
i S \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I SxIZZ ?	WASHINGTON, D.C. 20460
JAN 4 1991	,C,CE
30L Z Aas" mz ?Ms
mnmhrnm
SUBJECT: Request for Solid Waste Management Unit
Determination
FROM: Sylvia K. Lowrance, Directed /\ *V
Office of Solid Waste	r
TO:	David A. Ullrich, Director
Waste Management Division, Region V
We have reviewed your memorandum of July 10, 1990, and
your follow-up memorandum of November 20, 1990, in which were
requested a determination as to whether an area which
formerly held a leaking product tank constitutes a solid
waste management unit (SWMU) subject to corrective action
under RCRA S3004 
-------
also dealt with the issue. As you might expect, however, a
substantial number of comments that were submitted on the
Subpart S proposal also addressed this particular aspect of
the definition of "solid waste management unit". We thus
recognize this to be an important issue for further review in
finalizing the Subpart S rulemaking.
In the meantime, however, we support Regions V's
decision to use the S3005(c)(3) "Omnibus" provision to
address the releases in question at the GM Delco facility.
The contamination problem clearly appears to warrant further
investigation and remedial action. Although GM has appealed
the permit partly on the basis of this use of the Omnibus
authority, we believe that its use by the Region in these
circumstances is both appropriate and consistent with the
mandate of 53005(c)(3). Several recent permit appeal
decisions dealing with this same issue and under very similar
fact patterns have consistently upheld the Agency's authority
to deal with non-SWMU releases in this manner. We have
enclosed copies of two of these appeal decisions.
If you have any further questions, please contact Dave
Fagan CFTS 382-44 97) or Judy Goldberg (FTS 382-4534) .
Attachments
cc: Regional Branch Chiefs
-------
UNITED STATES EMYIRONMENTAL PROTECTION AGENCY
MAR 81991
9484.1991(0g
MEMORANDUM
SUBJECT: Regulation of Surface Impoundments that Exhibit the
Toxicity Characteristics (TC)
FROM: Sylvia K. IJowrance, Director
Office Of Solid Waste
TO:	Kristine A. M. Leopold
Assistant Regional Counsel (6C-MT)
In your November 7, 1990 memorandum to our office, you
conveyed the concerns of Ms. Paula Floeck of ENSR Consulting and
Engineering, Houston, Texas, regarding the regulation of sludges
within surface impoundments that may have the potential to become
newly regulated units as a result of the Toxicity Characteristics
(TC) rule. This memorandum responds to Ms. Floeck*s and your
concerns.
In Scenario one (1) of Ms. Floeck letter (see Attachment)
she asked, if it were "true that the sludge becomes regulatory
concern (sic) at the point it is intended to be discarded, that
is, when the impoundment is cleaned or closed?" Before answering
that question Z would first like to address some specifics in her
Stormwater Impoundment Scenario (#1). For example, Ms. Floeck
,stated that in determining whether the sludge (in the
impoundment) would render the impoundment a hazardous waste
management unit, we must first determine whether the sludge at
this point is classified as a waste. According to 40 CFR 261.2,
she states, a solid waste is defined as any discarded material
that is:
o abandoned;
o recycled; or
o considered inherently waste-like
She concludes that the sediment (sludge) within the impoundment
does not meet any of these criteria and therefore should not be
defined as a solid waste.

-------
The Agency disagrees with her interpretation of the above
prescribed federal regulation with respect to sludge within an
impoundment. The Agency interprets the federal definition of
solid waste to apply to the sludge generated within an
impoundment (unit), and believes that the unit would become
regulated for these following reasons:
1.	The RCRA regulation define a solid waste as any discarded
material. This includes materials that are abandoned by
being "accumulated, stored, or treated (but not recycled)
before or in lieu of being abandoned by being disposed of,
burned, or incinerated." (Emphasis added; see §261.2
(b) (3))
2.	Our past interpretations include sludge as a solid waste.
"Any pollution abatement technique such as the land
treatment, disposal, or storage of a wastewater will
invariably generate a sludge. The mechanisms for sludge
formation involve either precipitation, adsorption, or
accumulation of biomass. These units would be subject to
regulation ...if the sludges exhibit a characteristic..."
(See enclosed July 17,1985 memo from Skinner to Scarbrough).
3.	The Agency has always maintained that sludges are
generated at the moment of their deposition at the bottom of
the unit ("point of generation"). Note that deposition is
defined as a condition where there has been at least a
temporary cessation of lateral particle movement (See 55 12
46380, November 2, 1990).
Therefore, in response to Ms. Floeck•s question, the sludge does
become of regulatory concern at the point it is intended to be
discarded. However, "discarded" does not mean only when the
impoundment is cleaned or closed. Zf sludge in an impoundment,
which is considered to be a solid waste under 261.2, exhibits the
TC, then the sludge and unit would become subject to Subtitle C
,^requirements. Under the federal regulations accumulation and
storage of TC-hazardous waste in a unit subjects that unit to the
hazardous waste program. Note, however, that the solid waste
determination in an authorized State is a State call. If State
law is more stringent or broader in scope than federal RCRA
regulations, then compliance with those regulations would also be
required.
In addition, on September 27, 1990 (55 IE 39409) an Agency
clarification notice was published regarding a variety of TC-
related issues, including the regulatory status of surface
impoundments managing newly regulated TC waste. The third
surface impoundment scenario discussed in the notice is clearly
applicable to both of Ms. Floeck*s situations (Scenarios #1 and
#2). That is, a TC waste is generated from non-hazardous
2
2%^
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wastewater on or after the TC effective date. This could occur
where hazardous constituents in wastewater become concentrated,
or if a new TC sludge is formed by settling. Once the TC waste
is generated and stored or disposed in the unit, the unit is
subject to Subtitle C regulations. This clarification also
confirms your stated reasoning as to why the sludge in the
surface impoundment would be covered by the TC.
Z hope this response clarifies the issues you raised. As
noted previously, I encourage you to contact the appropriate
State and local regulatory agencies for additional assistance or
clarification. If you or Ms. Floeck have further questions
regarding the TC rule, please contact Daryl Hoore at FTS 475-8551
or (202) 475-8551.
3
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY _ . 00 , QO, ,,
7^00•1991(01)
FEB 5 1991
Mr. Janes Buckert, Manager
Technical Support Unit, Permits Section
Division of Air Pollution Control
Illinois Environmental Protection Agency
P.O. Box 19276
Springfield, IL 62794-9276
Dear Mr. Buckert:
This is in response to your January 7, 1991 letter on POHC
selection for a RCRA hazardous waste incinerator trial bum. You
inquired whether 1,2,3-trichlorobenzene would be acceptable to
use as a solid POHC, considering that this compound is not listed
in 40 CFR Part 261, Appendix VIII.
My understanding from your letter and discussions with you
and Mike Davidson is that you believe that, on a technical basis,
1,2,3-trichlorobenzene would be a good choice as a POHC because
1) it is a solid at ambient conditions and thus could be mixed
with solid waste feed; 2) with respect to incinerability, 1,2,3-
trichlorobenzene is expected to perform similarly to 1,2,4-
trichlorobenzene, an Appendix VIII compound which is in Class I
of the Thermal Stability at Low Oxygen (TSLo02) ranking (This is
based on input from Dr. Barry Dellinger, University of Dayton
Research Institute, as relayed by Larry Johnson, EPA Office of
Research and Development); and 3) the compound is readily
available and can be sampled and analyzed by standard EPA methods
,and procedures.
Thus, your inquiry primarily focused on whether the fact
that 1,2,3-trichlorobenzene is not on Appendix VIII would
eliminate this compound as a potential POHC. As I mentioned to
you in our telephone conversation, this issue was addressed in an
April 27, 1990 EPA proposal to amend the hazardous waste
incinerator regulations. EPA believes that there are situations
where compounds not on Appendix VIII may be more suitable as
POHC's than Appendix VIII compounds (due to concerns such as
availability, toxicity, etc.). For this reason, we proposed to
amend 1264.342(b)(1) and §270.62(b)(4) to specifically state that
POHC's need not be listed in Appendix VIII or be present in the
normal waste feed provided the applicant demonstrates that the
3^
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Therefore, your proposal to use a non-Appendix VIZI compound
as a PQHC is considered acceptable in terms of our most up-to-
date thinking on POHC selection. Further, since it is planned
that the trial burn will include two additional POHC's which are
Appendix VIII compounds, the proposed set of POHC's would also be
consistent with the current wording of the RCRA incinerator
regulations.
If you have any further questions on this issue, feel free
to contact se at (202) 382-3132.
Sincerely,
Sonya H. Sasseville, Chief
Alternative Technology Section
cc: Y.J. Kim, Region V
Lionel Vega
larry Johnson
Elizabeth Cotsworth

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9488.1991(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
JUH -6 B9t
Mr. Samuel I. Gutter
Sidley & Austin
1722 Eye Street, N.W.
Washington, D.C. 20006
Dear Mr. Gutter:
This is in response to your May 1, 1991, letter requesting
clarification of the regulatory status of an industrial furnace
burning hazardous waste under the boiler and industrial furnace
(BIF) regulation if the furnace ceases making product or halts
the industrial activity and burns hazardous vaste for purposes of
destruction only. You indicated that you had discussed this
issue with Steve Silverman and that he agreed with your
understanding that in these situations the furnace could continue
to bum hazardous waste under the BIF regulations. However, you
noted that Bob Holloway in a recent Chicago meeting had stated a
contrary opinion.
Bob Holloway of my staff has resolved this question with
Steve Silverman. This letter confirms the answer which
Mr. Holloway has already verbally provided to you. Although an
industrial furnace may burn hazardous waste solely for the
purpose of destruction under the BIF rule after the owner or
operator submits a certification of compliance as required by
Section 266.103(c), the device must continue to meet the
, - definition of an industrial furnace. If the facility no longer
meets the definition of an industrial furnace, then it would
typically be subject to regulation as an incinerator. For
example, if the owner of a cement facility operating in interim
status under the BIF rule determined that it was more profitable
to cease- making cement and focus the business on destroying solid
and liquid hazardous wastes, the device would no longer meet the
definition of a cement kiln. The facility would have to cease
burning hazardous waste until it obtained an operating permit as
an incinerator under Subpart 0, Part 264. If the facility was
operating under a RCRA operating permit as a cement kiln, then it
could not burn hazardous waste without producing marketable
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
- 2 -
cement product until the permit was modified to classify the
device as an incinerator (and, most likely, increase the
hazardous vaste burning capacity).
If you have further questions or comments, please feel free
to contact Bob Hollovay at (703) 308-8461.
Sincerely,
Sylvia K. Lowranee
Director
Office of Solid Waste
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9488.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SO? *3 1991
oeeiCE Of
SOLlO WASTE AfeO emergence wessons
Honorable Alex McMillan
House of Representatives
Washington, D.C. 20515
Dear Mr. McMillan:
Thank you for your letter of August 2, 1991, regarding
Rexhau Industrial~s and Richard McClintock's concerns about
the recent regulations for burning hazardous wastes in boilers
and industrial furnaces (BXFs). You requested information on how
the BIF regulations and the recently amended Clean Air Act would
affect the operation of Rexham*s boiler.
The Environmental Protection Agency (EPA) published the
BIF regulations on February 21, 1991 (copy enclosed). These
regulations require facilities that bum hazardous wastes to
monitor the combustion for high efficiency and to control any
pollutants in the flue gases that might pose a threat to human
health and the environment. EPA developed these regulations over
a period of four years and requested public comments on them on
two different occasions. After giving the industry opportunity
to submit comments, EPA responded to all comments and
accommodated many of them by revising the proposed regulations.
Zn his letter, Mr. McClintock indicated that he is not sure
whether the spent solvents he has been burning as fuel are
actually regulated as hazardous waste. The BIF rule applies to
boilers only if they burn hazardous waste. Although I suspect
that the spent solvents are hazardous wastes, the state of North
Carolina can assist Mr. McClintock in making a final
determination*
Mr. McClintock also indicated that the spent solvents are a
cleaner fuel than No. 2 fuel oil. In developing the final BIF
regulations, EPA wis aware that some hazardous waste fuels have
very low levels of toxie organic or metal constituents and may bm
hazardous only because they are ignitable and pose a fire or
explosion hazard. Accordingly, the BIF regulations exempt
boilers burning such low-hazard waste from many of the emissions
standards (e.g., particulate matter limits and emissions testing
for organics and toxic metals). These exemptions are	^
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implemented, however, under the permitting process established by
the regulations. Thus, although a boiler burning "low-risk
waste" may be exempt from certain emission standards, it would
still need a Resource Conservation and Recovery Act (RCRA)
permit.
Regulations that EPA will promulgate under the recently
amended Clean Air Act are not likely to affect the burning of
hazardous waste in boilers. Amended Section 112 requires EPA to
establish standards for toxic pollutants representing maximum
achievable control technology. Although boilers are a source
category that EPA will consider in developing regulations,
amended Section 112 explicitly requires EPA to consider existing
RCRA regulations in determining whether additional controls are
necessary. Given that EPA believes that the BIF regulations
adequately control emissions from boilers that burn hazardous
waste, additional controls under Section 112 may not be needed to
address waste burning in boilers.
Thank you for your interest in the safe and effective
management of hazardous waste.
Sincerely yours,
Don R. Clay
Assistant Administrator
Enclosure
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9488- "91 (04)
SEP 3 0 1991
SUBJECT: Response to Region VI Inquiry on Regulatory
Classification of Quantum Tech Plasma Arc Unit
FROM: Sylvia K. Lowrance, Director
Office of Solid Waste
TO:	Allyn M. Davis, Director
Region VI Hazardous Waste Management Division
This memorandum is in response to your August 14, 1991,
memorandum requesting guidance on whether the Quantum Tech plasma
arc unit falls within the February 21, 1991, revised definition
of incinerator, even though the unit has no afterburner.
The language of the February 21 revised definition of
incinerator unintentially includes all plasma arc and infrared
units, rather than just those with afterburners. However, the
regulatory status of such devices does not immediately change in
authorized States. Thus, at present, the state would make a
determination on the regulatory classification of this device
based on the definitions currently in effect in the state. To
prevent problems in the future, we plan to make a technical
correction to the revised definition of incinerator. Foil wing
is a more detailed description of our interpretation and planned
follow-up.
Classification under Subpart o vs. subpart 1
On February 21, 1991, along with the BIF (boiler and
industrial furnace) rule, SPA published modifications to the
definition of incinerator. One modification specifically added
plasma arc and infrared devices to the definition. The reasons
for this modification were, as stated at 56 £& 7204, that "(1)
although these devices use nonflame sources of thermal energy to
treat waste in the primary chamber, they invariably employ
controlled flame afterburners to combust hydrocarbons..."
(emphasis added); and "(2) the incinerator standards are workable
and protective for these units."

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EPA was unaware at the time the definition was being
developed, and commenters on the proposed rule did not indicate,
that there were plasma arc units without afterburners, as
indicated by the above preamble language. Therefore, the
presence of an afterburner was not specifically included as a
criterion in the new definition. Under revised §260.10, plasma
arc incinerator is defined as "any enclosed device using a high
intensity electrical discharge or arc as a source of heat and
which is not listed as an industrial furnace." Since there is no
mention of afterburners in either the plasma arc incinerator or
incinerator definitions, the revised definition of incinerator
does not exclude plasma arc units which do not have afterburners.
This is also the case for infrared units.
Since the Regions are now aware of two such devices without
afterburners, we plan to make a technical correction to the
February 21 rule to only include plasma arc and infrared units
with afterburners in the definition of incinerator. Considering
a plasma arc or infrared device without an afterburner as an
incinerator is clearly not consistent with the intent of the
regulation. In addition, the types of operating conditions and
other performance requirements for incinerators may not make
technical sense to apply to a non-combustion device. For
example, carbon monoxide is a measure of combustion efficiency
and therefore may not be a meaningful operating parameter for a
non-combustion device.
Permitting these devices under Subpart X will allow more
flexibility to address the specific operating and emissions
characteristics of the units. Parts of Subpart O which do "fit"
these devices can still be applied under Subpart X.
Rule Does Hot Impact Authorized States Immediately
The revision to the incinerator definition is a non-HSWA
rule and therefore does not take effect in an authorized state
-*mtil the state becomes authorized for the rule change. Thus,
assuming that plasma arc (and infrared) units have not been
considered in the past to be incinerators under the authorized
Texas program, they will continue to be outside the incinerator
definition until Texas adopts the February 21 provisions. Our
goal is to complete the technical correction well before
authorized states adopt the new rule.
you also requested clarification on whether the Quantum Tech
unit may be an exempt recycling device. While incinerators (and
boilers and industrial furnaces) cannot be considered exempt
recycling units, other recycling devices can potentially be
considered for the recycling exemption. Since plasma arc units
would not presently be classified as incinerators in authorized

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states, Texas will need to make a determination on whether the
Quantum Tech unit is a recycling unit. If Texas determines that
the unit is not an exempt recyling device, then we agree that it
would be subject to permitting under Subpart X for miscellaneous
units. Attached is a memorandum which provides criteria for
determining whether a unit is engaged in recycling. You may wish
to provide this to Texas to assist them in this effort.
nirmrnm-ry
In summary, plasma arc (and infrared) units without
afterburners were unintentionally included in the revised
definition of incinerator. Our goal is to make a technical
correction to the rule before this provision is adopted by
authorized states. In the meantime, the February 21 rule would
not affect the regulatory status of these devices in authorized
states, and Texas will need to determine whether the Quantum Tech
unit is an exempt recycler.
We would like to remind you that if the facility has other
units which will be receiving a RCRA permit, the plasma arc unit
will be subject to the air emissions standards under Fart 264,
Subpart BB, even if it is determined to be a recycling device.
It may also potentially be subject to the Phase XI air emissions
rule proposed on July 22, 1991, when this rule is promulgated.
We will keep you informed through the Incinerator and
Subpart X Permit Writers1 Workgroups of the progress on the
technical correction. If your staff have any further questions,
they may feel free to contact Sonya Sasseville at FTS 260-3132.
Attachment
cc: Devereaux Barnes
Elizabeth Cotsworth
Incinerator Permit Writers' Workgroup
Subpart X Permit Writers' Workgroup
sett*
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9488.1991(05)
RCRA/SUFERFUND HOTLINE MONTHLY SUMMARY
OCTOBER 1991
1. Application of the Sham Recycling
Policy to Certified Bolters an* Industrial
Furnaces
The February 22, 2991,	Krister (56
££ 7234) promulgated regulations for hazardous
waste boilers and industrial furnaces (B!Fs) in 40
CFR Part266, Subpart H. The preamble (page
7283) to the rule explains that prior to certification
of compliance with the emissions standards under
Section 266.203(c), BIFs (other than BIFs burning
waste solely asm ingredient or solely for material
recovery) must comply with EPA's sham recycling
policy published in the March 26, 2983, Federal
eoiner (48 ER 22257) This policy requires
burners of hazardous waste who claim that their
burning activities constitute legitimate recycling to
demonstrate that the waste has a healing value of
5,000 B tut lb or more. How does the sham
recycling policy apply to B2Fs which htm certified
compliance with the Section 266J03(c) at
emissions standards under the B2F rule2
B^Fs are no longer required to ptovt
rhar the wastes they are burning have an as*
generated heating value of 5,000 Btu/lb or more.
The requirement that burning be protective of
human hfnltf1 af"* tha environment is warn satisfied
through compliance with erosions standards. The
February 21,1991, B1F rule states that the sham
recycling policy stays in effect (except for wastes
fed solely as an ingredient or solely for material
recovery) until an	facility certifies
compliance with the emissions standards of
Section 266.103(c). (56 EE 7149)
The 5,000 Btu/Ib policy was intended to prevent
the burning of hazardous wastes for destruction
purposes (Le., incineration) rather than for energy
recovery in units which do not meet incinerator
standards. Wastes going to boilers which are not
legitimately burning for energy recovery axe
likely to vent hazardous contaminants to the
atmosphere as unbumed at partially burned
combustion products, presenting a risk to human
health and the environment. By requiring burners
to demonstrate that a waste's heating value is
greater than or equal to 5,000 Btu/lb, the Agency
is able to assure a high enough temperature and
long enough residence time in die boiler to
destroy hazardous constituents at a rate which is
protective of human health and the environment.
After certification of compliance, however,
protection of human health and the environment
will be achieved through die new air emission
tranHat^f,
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t
UNITED STATES ENVIRONMENTAL PROTFCTtON AGENCY 9493.1991 (04)
OCT I I 1991
David wisch
RCRA Unit Supervisor
Hazardous Waste Section
Land Quality Division
Department of Environmental Control
State of Nebraska
301 Centennial Mall South
P.O. Box 98922
Lincoln, Nebraska 68509-8922
Dear Mr. Wisch:
Thank you for your letter of June 26, 1991 commenting on a
May 3, 1991 letter ve received from Mike Bates of the State of
Arkansas requesting clarification of the federal Resource
Conservation and Recovery Act (RCRA) Subtitle C regulations
governing the management of certain materials used as ingredients
in the production of fertilizers.
Mr. BatebSl letter requested clarification of how materials
and activities would be regulated under the federal regulations
in a situation involving the facts listed below. In addition,
you request clarification on hov such materials and activities
would be regulated if lead values were recovered from the
baghouse dust prior to its use as an ingredient in fertilizer
production.
•	A generator in your ft ate _ erates a baghouse dust
that is not a listed waste identified in 40 CFR 261.32
or 261.33 (or, we assume, 40 CFR 261.31)?
•	The baghouse dust, which has a high concentration of
zinc, fails the Toxicity Characteristic for lead;
•	The dust is a "sludge," as defined in 40 CFR 260.10
because it is generated in an air pollution control
facility; and
•	The generator would like to send the baghouse dust to a
producer that could use the dust as an ingredient in
fertilizer for the zinc content.
must be nade is whether the! material! in Question is a solid I

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2
waste, since
solid waste (40 CFR 261.3). For materials that are recycled, 40
CFR 261.2(c) defines those materials that are solid wastes. If
the material is both a solid waste and a hazardous waste, the
waste management activities must then be evaluated to identify
applicable requirements.
In the situation described by Mr. Bates, the baghouse dust
would be a solid waste because it is a sludge exhibiting a
characteristic of hazardous waste which is to be used to produce
a product that is applied to or placed on the land (i.e., used in
a manner constituting disposal). (See 40 CFR 261.2(c)(l)(i)(B).)
Since the dust exhibits the Toxicity Characteristic, it is also a
hazardous waste (40 CFR 261.3(a)(2(i)).
Similarly, if the baghouse dust were sent to a facility at
which lead was recovered from the dust prior to shipment to the
fertilizer producer, the baghouse dust would also be a solid
waste under 40 CFR 261.2(c)(1)(i)(B) because it continues to be a
characteristic sludge which is to be used to produce a
fertilizer. The regulatory determination does not change because
some portion of the dust is to be used in a manner constituting
disposal, even though another portion (the recovered lead) will
not. In other words, the solid waste determination for a
recycled material is made at the point of generation of the
waste, and .takes into account the entire waste recycling process,
not just the first step in a waste recycling train. Any step
which involves use in a manner constituting disposal (or burning
for energy recovery) causes the waste to be a solid waste from
the point of generation on. Any portions of the waste that are
separated from the waste and recycled in ways that do not involve
use constituting disposal (or burning for energy recovery) may no
longer be solid wastes (depending on applicable regulations).
For completeness it should also be noted that the regulatory
status of the dust after the lead recovery step would depend on
whether the dust exhibited any hazardous waste characteristics.
Thus, if the dust exhibited a characteristic it would continue to
be a solid and hazardous waste, again because it would be a
characteristic sludge to be used in a manner constituting
s"disposal. On the other hand, if the dust did not exhibit any
characteristics after the lead recovery step, it would not be a
hazardous waste at that point.
Once the regulatory status of a recycled material is
determined, the applicable management requirements are specified
in 40 CFR 261.6. For the characteristic sludge which is to be
used in a manner constituting disposal, the generator and any
transporters would be subject to the applicable requirements of
40 CFR Parts 262, 263, and 268 (including use of the manifest),
and the recycling facility (storer) to the applicable
requirements of Subparts A through L of 40 CFR Parts 264 and 265
2W
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3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
268, 270, and 124. (See 40 CFR §§ 261.6(a)(2)(i), 266.21, and
266.22.) The recycling process itself (lead recovery and/or
fertilizer production), assuming it is legitimate would not be
subject to Subtitle C regulation.	A i
/I
Once the fertilizer is produced, if it meets the conditions
of 40 CPU 266.20(b) (i.e., is produced for the general public's
use and meets the applicable land disposal restrictions treatment
standards in 40 CFR Part 268, Subpart D), the fertilizer is not
presently subject to regulation (although under 40 CFR
261.2(c)(1)(i)(B) the fertilizer remains a solid waste, and 40
CFR 268.7(b)(7) recordkeeping requirements would be applicable).
If the fertilizer did not meet the conditions of 40 CFR
266.20(b), use of the product would be subject to 40 CFR 266.23
(i.e., full Subtitle C regulation).
The above discussion addresses the federal regulatory
requirements applicable to the use of characteristic sludges as
ingredients in fertilizers. For your information, several past
letters and other material addressing this issue are enclosed.
However, individual state requirements may be different and may
vary from state to state.
In addition, there are several follow-up points that I would
like to make. First, I believe that some background on the
development of the use constituting disposal regulations will
shed some light on the reason the regulations are structured as
they are. When these regulations were promulgated on January 4,
1985 (50 £2 €14), the preamble explained that RCRA Subtitle C
jurisdiction unquestionably encompasses wastes that are placed on
the land (used in a manner constituting disposal) because this
type of recycling is so similar to normal forms of waste
management (i.e., land disposal). In fact, placement on the land
is one of the activities that Congress most clearly intended to
control under RCRA. As with any other waste that is to be
managed in a manner that is analogous to disposal, generation,
transportation, and storage of any wastes that are (even in part)
to be used to produce waste-derived products sure regulated (in
addition to those that are to be used directly on the land).
Second, there was a discussion in the January 4, 1985
Federal Register notice explaining that in the future, the Agency
envisioned developing a more tailored regulatory system for
waste-derived products recycled by placement on the land. Such a
system would take into account the safety of the product (e.g.,
levels of hazardous constituents in the wastes, likely routes of
exposure, etc.). We will shortly be proposing a rule that will
allow producers of waste-derived products placed on the land to
make such a demonstration.
Third, as you may know, this proposal is part of a larger
effort that we are currently undertaking to reevaluate our
UQ^
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4
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
overall approach to regulation of hazardous waste recycling
activities and to make changes to ensure that the regulations
encourage environmentally beneficial recycling while at the same
time ensuring protection of human health and the environment.
I understand your concern that the hazardous waste regulations
may, as in the case discussed, discourage recycling activities.
We expect to publish an Advanced Notice, of Proposed Rulemaking in
the Federal Register soon which fays ou%» our current thinking on
this issue and solicits comment on a number of possible
approaches. Z strongly encourage you to review this notice and
give us your thoughts on the issues discussed. The reactions and
ideas of state agencies implementing the RCRA program will be
very important to the success of this project.
Thank you for bringing this issue to my attention. Should
you require any further information or have any additional
questions, please call Mike Fetruska, Chief of the Regulatory
Development Branch, at (202) 260-8551.
Sincerely,
Sylvia K. Lowrance, Director
Office of Solid Waste
cc: Hazardous Waste Management Division Directors; Regions I-X
trot
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/Of	9489.1991 (Ui;
^	T>
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
FEB I 5 1991
Francis S. Blake, Esq.
Swidler & Berlin
3000 K Street, N.W.
Suite 300
Washington, D.C. 20007-3851
Dear Mr. Blake:
This letter responds to your January 18, 1991 correspondence
requesting a follow-up response to the October 28, 1990 meeting
between representatives of Texas Industries, Inc. (TXI) and EPA.
The meeting focused on TXI's use of hazardous wastewaters as
quenchwater in the production of cement, as well as on the use of
such wastewaters as a slurrying agent in the production process.
The Agency presented its position under current regulations
on the use of hazardous wastewaters as slurry water used in the
production of cement in the final rule regulating the burning of
hazardous' waste in boilers and industrial furnaces (BIF rule)
which was promulgated December 31, 1990. Basically, EPA has
ruled that the practice of using hazardous wastewaters in this
manner is a form of waste management that is subject to
regulation as treatment, rather than a recycling activity that is
exempt from regulation. (I note that there may be cases for
which a hazardous wastewater could legitimately be used in this
manner, but such a determination would be case-specific.) The
main consideration in this determination is that, in general, the
hazardous constituents in the wastewater are not necessary to the
operation of the production process, but are being treated in the
process.
While the preamble to the BIF rule did not specifically
address the use of hazardous wastewaters as a quenchwater in the
production of cement, the determining factors would be the same
as in all such regulatory determinations regarding the use of a
hazardous secondary material as an ingredient in a production
process, or as a substitute for a commercial product. To the
extent that the hazardous constituents in the wastewater are not
also present in the analogous raw material or product that the
wastewater is replacing and are also not necessary to the
production process, but are being destroyed or otherwise treated
in the process (or incorporated into the product), the process
itself would be regulated as a treatment process. The Agency
agrees that the use of the wastewaters as a quenchwater in the
hot end of the kiln may be conducted in an environmentally safe
manner, provided that adequate controls are in placi. The BIF
rules will ensure that the process is, in fact, saft>. However,
the fact that the hazardous wastewater may adequately serve as a
office o*
SOCIO WASTE AND EMERGENCY RESPONS
Printed on Recycled
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2
quenchwater and that the hazardous constituents are efficiently
destroyed in the process without detrimental effect to the
product does not, in itself, demonstrate that such use of the
wastewater is legitimate recycling, unregulated under the current
Federal requirements. The destruction of hazardous constituents
without any significant benefit to the process or the product
identifies the process as hazardous waste treatment, subject to
regulation under Subtitle C of RCRA.
As you noted in your letter, the Agency is currently
reevaluating the regulatory provisions applicable to the
recycling of hazardous wastes. The discussion of regulatory
determinations regarding the use of the hazardous wastewaters
presented in this letter reflects the application of the current
regulations. While EPA is continuing to explore possible
alternative regulatory approaches to encourage environmentally
sound hazardous waste recycling, we are unable to state with
certainty at this time whether the answer to the question you
pose would be different under a new regulatory scheme. In the
meantime, of course, the existing regulations are applicable.
I hope this letter has answered your questions regarding the
factors used to determine the regulatory status of using
hazardous wastewaters as a quenchwater and as a slurrying agent.
If you have any further questions, feel free to contact me at
(202) 382-4637.
Sincerely
David Bussard
Director
Characterization and
Assessment Division

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9489*1991(02)
MAY 3 I 1991
MEMORAHDPM
SUBJECT: Drippage In Wood Preserving storage Yards
ntOM: Sylvia K. Lowrance, Director
Office of Solid Haste
TO:	Hazardous Waste Management Division Directors
Regions I-X
A question has arisen regarding the regulatory status of
drippage from treated wood that occurs in wood preserving plants'
storage yards. The final rule requires that treated wood must be
held on process area drip pads until drippage ceases (see $S
264.572 (k), 265.443 (k)). Even so, infrequent and incidental
drippage may occur from the treated wood after its removal from
the drip pad. Infrequent and incidental drippage may occur due
to the effects of weather, type of wood, or type of preservative.
EPA recognized in the rulemaking that the de minimis losses that
could occur would not require the storage yard to be equipped
with a drip pad (55 FR at 50456, December 6, 1990).
We note further that this type of incidental drippage would
not constitute illegal disposal of a hazardous waste provided
that there is an immediate response to the discharge of the
drippage (§$ 264.1 (g) (8) (i) (A) and 265.1 (a) (11) (i) (A),
persons responding immediately to discharges of hazardous wastes
are not subject to regulatory standards for the response
activities, although the hazardous wastes become subject to
' subtitle C regulation after they are removed). ' Determination of
what constitutes an "immediate response" to storage yard drippage
would be a site specific determination. Wood preserving
facilities should prepare a contingency plan which includes
measures to respond to drippage by removing the contaminated
media in a timely manner and documenting by appropriate records
the actions taken to respond to such drippage. Once removed from
the drippage area, the contaminated media would be a hazardous
waste carrying the F032, F034 or F035 waste code and be subject
to subtitle C regulatory standards (48 F* at 2510, January 19,
1983).
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9489.1991(03)
RGRA/StJPERFOND HOTLIKE MONTHLY SUMMARY
JUKE 1991
1. Administrative Stay for Wood Preserving Wastes
Or June 13,1991, SPA announced an administrative stay that extends the date by
which owners and operators of facilities that manage F032, F034, and F035 wastes on
drip pads are required to comply with the standards of 264/265 Subpart W.C56EI
27132) How does this affect the management and disposal of wood preserving
wastes? *
Three new listings for wastes generated by wood preserving processes, F032,
F034, and F035, were finalized on December 6,1990. (55 EE 50450) Due to
the inability of a significant portion of the affected facilities to comply with
tile new drip pad standards by the effective date of June 6,1991, EPA
announced an administrative stay that postpones the applicability of the new
listings to certain process areas and drip pads at facilities that "intend to
comply with the Subpart W standards and that are willing to maice bona fide
efforts to do so during the stay period." C56FR 27333) In order to qualify for
the stay, by August 6,1991, affected facilities must notify the appropriate
authorized State or EPA Regional office of their intent to comply with the
new regulations or to cease operation. (56 fS 27333) By November 6,1991,
affected facilities must submit a second notification providing evidence that
they expect to comply in good faith.

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1. Administrative Stay for Wood Preserving Wastes (Cont'd)
Provided the facility gives proper notice, certain activities that would
otherwise constitute disposal of F032, FQ34, or F035 wastes into a process area
or onto an existing drip pad are not regulated during the stay. However, the
removal or subsequent management of such wastes outside of the process
area or drip pad, including soil contaminated with these wastes, would be
considered generation of a hazardous waste and cause the waste-to become
subject to regulation under Subtitle C of RCRA. The scope of the stay is,
therefore, limited and applies only to those wood preserving wastes managed
in process areas or on existing drip pads. (56 FR 27333) In addition, any
active management of previously unregulated wastes after the expiration of
the stay would constitute generation of an FQ32, F034, or F035 waste.
Although the administrative stay does postpone the effective date of the F032,
F034, and F035 listings for certain wastes, these wastes may already be
regulated as hazardous if they exhibit the Toxicity Characteristic (TO.
During the stay, wood preserving wastes which exhibit the TC are subject to
full Subtitle C regulation, and cannot be disposed of on the land except in a
properly permitted land disposal facility. According to 40 CFR 264570(a),
and 263.440(a), Subpart W standards "apply to owners and operators of *
facilities that use new or existing drip pads to convey treated wood drippage,
precipitation, and/or surface water run-on* to an associated collection
system". Therefore, owners and operators who manage wood preserving
wastes that exhibit the Toxicity Characteristic on drip pads can use pads to
collect their wastes.
See 55 fE 50470-71 (technical correction notice signed June 21,1991).
Source: Ed Freedman, OSW	(202)245-3657
Research: Peter LeTouraeau
%

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UNHID STATES ENVIRONMENTAL PROTECTION AGENCY
9489.1991(04)
AUG 2 ©91
MEMORANDUM
SUBJECT; Regulatory Status of Carbon Regeneration Units
FROM: Sylvia K. Lowrance, Director
Office of Solid Waste
TO:
Bruce P. Smith, Director
Office of Hazardous Waste Programs
Region III
This is in response to your June 7, 1991 memorandum
requesting that we provide our interpretation of regulatory
situations involving carbon regeneration units in light of the
provisions on such units in the February 21, 1991 boiler and
industrial furnace (BIF) rule. Belov is a brief summary of the
rule's provisions related to carbon regeneration units, followed
by our responses to each of the scenarios and issues outlined in
your memo.
The February 21 rule added a definition of "carbon
regeneration unit" to 40 CFR 260.10. The preamble stated that
both flame and non-flame carbon regeneration units should be
permitted as hazardous waste thermal treatment units under Part
-264 Subpart X and existing units should be regulated until then
under Part 265 Subpart P. The rule also reopened until August
21, 1991, the period for existing carbon regeneration units to
obtain interim status under RCRA, due to the substantial
confusion among the regulated community, as veil as permitting
authorities, as to whether these devices were exempt recycling
units or regulated treatment units. Since the carbon
regeneration unit portion of the rule was promulgated under RCRA,
not HSWA, authority, it does not take effect in authorized states
until they adopt these provisions.
Regulatory Status of tttistiao Onits
We agree with your interpretation that the regulatory status
in an authorized State""
4Uft^^"£he7>Sfc*t« Betexminte* existing jnulMram i sufficient fcr,
I Reproduced (rc
1 best available
py
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if they are not, makes the necessary regulatory change to ensure
equivalency with the Federal standards. We would like to clarify
that, in either case, the change would not become effective until
EPA approves the rules and interpretation as consistent with the
§260.10 definitions. In the meantime, a State may continue to
regulate the facility consistent with the policy and regulations
in effect at the time of authorization.
If the State determines that the carbon regeneration unit
provisions of the BIF rule can be implemented in the State under
its authorized State program without a regulatory change, the
State Attorney General would need to certify that the existing
State authorities are equivalent to the Federal requirements set
out in the February 21 rulemaking. EPA could then authorize the
State for this portion of the rule. If the State, or EPA,
determines that a regulatory change is required, these provisions
would not become effective in the State until the State modifies
its program and is authorized to implement the rule in lieu of
EPA. (However, States may adopt and implement comparable rules
under State authority prior to authorization by EPA.) In either
case, in adopting the new regulatory approach for carbon
regeneration units, the State could provide a "window" similar to
that established by EPA in the February 21 preamble for existing
units to qualify for interim status.
We also agree that the status of residues is not affected by
the February 21 rule. Residues, such as scrubber blowdown,
continue to be regulated as hazardous wastes if they result from
processing listed hazardous wastes, or if they exhibit a
hazardous waste characteristic.
In cases where the authorized State is not yet authorized
for the new provisions, you also proposed to impose conditions on
the carbon regeneration unit, if determined necessary to protect
human health and the environment, when issuing a permit to
another TSD process at the facility. We would not recommend EPA
imposing Subtitle C requirements while the carbon regeneration
, -units remain unregulated by the State. The February 21 notice
was explicit that the new carbon regeneration unit provisions
would not take effect in authorized States until the states pick
up the new provisions. We feel that regulating these units prior
to the State becoming authorized for these provisions would work
against our goal in the February notice to finally end the
confusion on the regulatory status of these units. In addition,
if we took this approach, there would be substantial question as
to whether we provided affected facilities with adequate notice.
Units not "In existence" as of Aucrost 21. 1991
We disagree with your interpretation that because the State
is not authorized to issue Subpart X permits, units which are not
"in existence" as of August 21, 1991, must obtain a Subpart X
permit from EPA before constructing. Section 264.1(f)(2) gives
U
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the Agency authority to issue Subpart X permits in States that
are not authorized for the Subpart X regulations. However, this
section simply gives EPA authority to permit regulated
miscellaneous units in authorized states; it does not authorize
EPA to permit unregulated units. The definitions and
interpretations related to carbon regeneration units in the
February 21 rule do not go into effect in an authorized state
until the state becomes authorized for those new provisions.
Until that time, as you correctly observed in the first issue you
raised, the regulatory status of carbon regeneration units in the
state does not change, but rather is determined by the
regulations and policies currently in effect in the state.
Thus, the effective date of the authorized state's approved
redefinition of carbon regeneration unit, rather than the
effective date of EPA's rule, determines when new carbon
regeneration units become subject to regulation, including
Subpart X permitting.
Effect of February 21 rule on past management of waste in carbon
regeneration units
Although we did state in the BIF rule preamble that direct
controlled flame carbon regeneration units have met the
definition of incinerator and were subject to regulation as such,
we also stated that we believe there has been legitimate doubt as
to these units' regulatory status. Thus, we did not intend to
provide basis for enforcing against past operation of such units
without interim status or permits, but rather to address the
prospective regulation of these devices. (See 56 £B 7200-7201.)
According to S270.10(e)(2), the Administrator may extend the
date by which owners and operators of specific classes of
existing hazardous waste management facilities must submit Part A
of their permit applications if he finds that there has been
substantial confusion as to whether the owners and operators of
^such facilities were required to file applications and that the
confusion is attributed to ambiguities in the regulations. The
Agency made such a finding of "substantial confusion" as to the
regulatory status of carbon regeneration units. Therefore, since
the date for obtaining interim status was extended, the Agency
should enforce only prospective compliance with the regulations
for carbon regeneration units.
Authorized States, however, would determine compliance based
upon their current regulations and policies. Therefore, we
disagree with your proposal to rely upon the August 21, 1991 date
to treat all carbon regeneration units as subj ect to RCRA.
Carbon regeneration units should be treated consistent with state
policies and regulations which have been in effect until the
State program is revised to reflect the §260.10 definition of
carbon regeneration unit and revised incinerator definition.
Thus, in an authorized state which has considered carbon
i\
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regeneration units to be unregulated, these devices should be
treated as "newly regulated" as of the effective date of the
§260.10 definition changes in that state, which will likely be
later than August 21, 1991. In contrast, there may be authorized
states that have always considered carbon regeneration units as
incinerators or thermal treatment units, and therefore will not
be treated as "newly regulated" in the future.
Carbon regeneration units managing TC wastes
We also disagree with your interpretation that all carbon
regeneration units managing toxicity characteristic (TC) wastes
are subject to regulation by EPA as of August 21, 1991. In an
authorized state which has not yet picked up the TC listing, the
waste is regulated by EPA, and EPA applies Federal regulations
rather than issuing permits based on State laws. However, EPA
does not have authority to issue permits to types of units which
are exempt from regulation. The applicable RCRA program, which
in this case would be the authorized State program, determines
which classes of units are RCRA-regulated. Thus, EPA would not
regulate the treatment of TC waste in a carbon regeneration unit
until such units are regulated under the approved state program.
Thank you for raising these issues. They are nationally
significant for effective program implementation. While we could
not agree with all the recommended solutions that Region III put
forward, the careful thinking that was put into framing the
issues was commendable. If your staff has further questions,
they may call Sonya Sasseville at FTS 382-3132 or Frank McAlister
at FTS 382-2223.
cc: Subpart X Permit Writers' Workgroup
Incinerator Permit Writers' Workgroup
Permit Section Chiefs, Regions I - X
m°
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9489.19 91(C
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
FEB 2%, 1**1
OFFICE OP
SOLID WASTE AMO EME RGENCV RESPONSE
David Case
General Counsel
Hazardous Waste Treatment Council
1440 New York Avenue, H.W.
Suite 310
Washington, B.C. 20005
Dear Mr. Case:
Thank you for your letter of November 21, 1990, regarding
performance standards for disposal of hazardous waste in salt
domes.
Enclosed is a legal opinion from the Environmental
Protection Agency's (EPA*s) Office of General Counsel concerning
a permit application for placing hazardous vaste in a salt dome,
along with the remand in Natural Resources Defense Council fWRDCI
v. EPA, 907 7.2d 1146 (D.C. Cir.). This opinion generally agrees
that to lift the specific prohibition in Section 3004(b)(1) (B) of
RCRA, EPA must promulgate specific regulations for placement of
liquid hazardous waste in salt formations. EPA further agrees
that the placement of any hazardous waste in salt domes or other
geological repositories should be pursuant to appropriate
standards consistent with the RCRA mandate to protect human
health and the environment.
To the extent that this practice could now occur under
Section 3004(b)(2), it would be limited to non-liquid or
. -Containerized hazardous waste subject to a RCRA permit issued
pursuant to 40 CFR Parts 264 and 270. As you are aware, a
RCRA permit allowing such disposal may be issued only when human
health and the environment are adequately protected. For
example, a Subpart X permit—which would be appropriate for
disposal in salt domes—may contain any provisions needed to
achieve this overall standard of protection, including those
found in other parts of the RCRA regulations, or other relevant
standards, such as those at 40 CFR Part 146 implementing the
Underground Injection Control (VIC) program. Of course, a state
authorized to implement RCRA might also use some analogous
standards when writing an environmentally protective RCRA permit
for the disposal of hazardous waste in salt domes. 1 believe
that this comprehensive approach can provide the type of
environmental protection envisioned by Section 3004(b)(2) of
RCRA.
Mil	@ Prima
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Unlike RCRA Section 3004(b)(1), Section (b)(2) does not, as
a prerequisite to receiving a permit, require promulgation of
specific performance or unique permitting standards for salt dome
formations. Of course, any RCRA permit covering disposal in salt
domes would contain a full set of requirements to ensure
protection of human health and the environment. Neither the tfRDC
opinion nor any EPA statements in the Federal Register notice (53
EE 28118) that is the subject of the court opinion purport to
construe RCRA Section 3004(b)(2). Thus, as explained above, EPA
or an authorized state can permit disposal in salt domes or other
geologic repositories under Section 3004(b)(2) using the existing
Subpart X permit standards found in 40 CFR Part 264, as veil as
other appropriate state or federal standards.
Be will most certainly consider any rulemaking petition you
may wish to submit for hazardous waste disposal in salt domes, as
mentioned in your letter. However, for the reasons discussed
above, we believe that existing RCRA permit procedures and
standards are fully protective of human health and the
environment. Given EPA's limited resources and formidable
regulatory agenda in the RCRA area, I anticipate that, for the
near term, EPA or the authorized states will use existing
standards to regulate the disposal of containerized and non-
liquid wastes in the geological repositories covered by RCRA
Section 3004(b)(2). If you have any suggestions on how to
improve the contents of such permits, or on RCRA's applicability,
please feel free to call Elisabeth Cotsworth at (202) 382-4206.
If you have further questions regarding UlC-related rulemakings,
please contact Francoise Brasier at (202) 382-5530.
1 appreciate your continuing interest in this issue and your
concern for the safe management of hazardous waste.
Sincerely yours,
Don R. Clay
Assistant Administrator
Enclosure
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Inserts
Please Replace the
Attached Memo With
the Current
9489.1988(01) Memo in
Volume 8

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/•	94 39.1988(01}
/ '"*%.
A \ '	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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included in the definition of surface impoundment in 40 CFR
260.10 (that is, aeration pits). Being such, the units will
require permits based on Part 264 Subpart K. 40 CFR 264.220
states that Subpart K applies to facilities that use surface
impoundments to treat, store, or dispose'of hazardous waste.
However, the permit applicant can be required to supply
additional information as required in 40 CFR 270.23 (i.e., for
miscellaneous units) if the Subpart K standards do not provide
adequate protection for human health and the environment. For
example, the Regional Administrator may write permit conditions
based on the Subpart X standards which would protect the air or
surrounding soils during the burning phase of the treatment
process.
What land disposal deadlines and restrictions are applicable to
the units as defined bv the answer to the above question? Must
the units meet the Wovenber 8, 1988. retrofit deadline or
close?
The Agency has concluded that open burning/open detonation
(OB/OD) of waste explosives in a Part 265, Subpart Q, or a Part
264, Subpart X, OB/OD unit does not constitute land disposal
because it is treatment, not disposal (52 £B 46592). This is
true except in cases where the residuals from the OB/OD
operation remain a hazardous waste. Therefore, OB/OD
activities are not automatically subject to the land disposal
restrictions.
As we indicated above, the treatment pits are properly
classified as surface impoundments; therefore, all land
disposal deadlines and restrictions and the surface impoundment
retrofit deadline remain applicable. Furthermore, a unit is an
OB/OD unit under Parts 264 and 265 when it is not a surface .
impoundment and when it open bums/detonates waste explosives.
As mentioned in $265,382, non-military waste explosives can be
open burned/detonated only when they have the potential to
detonate. According to the information we have on Morton
Thiokol's treatment pits or impoundments, wastewater that does
not have the potential to detonate is placed in a pit and is
treated by.' dewatering and subsequent burning.
Does the burning of solvents which are contaminated with
reactive material constitute a violation of 40 CFR 265.382
hazardous waste open burning prohibition? P9?? til?
mXJCBQ WaSyg	PUPPfllw O PBiHiirl i¦ ¦ Tiflr 11 Vr*
The opes burning of solvents is strictly prohibited. Only
waste explosives that have the potential to detonate, and bulic
military propellants which cannot be safely disposed of through
other modes of treatment,. can be open burned in a Part 264
Subpart X, or Part 265, Subpart Q, unit. (See 40 CFR 265.382)
If the waste solvent is a waste explosive that has the
potential to detonate, then it can be open burned provided that
-------
the unit fits the appropriate criteria. The descriptive
information, on unit #11 is not definitive but we suspect that
"trough" reftffSred to in your memorandum may be a tank, and
therefore, also does not qualify as a 264, Subpart X, or Part
265, Subpart Q unit.
More information is needed for us to make a final
determination on the potential to detonate (e.g., exact
concentration of explosive or ratio of materials is not known
nor is its fulfillment of the definition of "detonate" in
265.382 fully known). However, we do not think the open burning
of the 1,1, 1-trichlorethane or any other solvent will prove to
be proper when this information is provided.
What land ban requirements are applicable to the solvent
vast??? Can the solvents be opened burned and do the land ban
reouirements apply to the solvents?
Because disposal of the solvents is not likely to qualify
as OB/OD in a Subpart X or Subpart Q unit, all of the land
disposal restriction requirements, including those at 40 CFR
268.4, would appear to be applicable to the management of
solvents in the situation you outlined. In such event, the
solvents cannot be open burned.
If you have a question regarding these clarifications or
would like to discuss the issues in more detail, please contact
Chester Oszman (382-4499).
cc: Hazardous Waste Branch Chiefs, Regions I-X
Lisa Reed, Region VIII
Fred Chanania, OGC
Kent Anderson, OSW
Chester Oszman, OSW

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V olume 9
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 9
mi
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9493.1991(01)
\

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*	WASHINGTON. D.C. 20460
JAN 8 1991
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
Frank Dixon
President
Thermal Waste Management
237 Royal Street
Nev Orleans, Louisiana 70130
Dear Mr. Dixon:
This letter responds to your August 9, 1990, letter to
Mr. Bob Hollovay, as veil as to phone conversations between
Mr. George Lane of Thermal Waste Management (TWM) and Mr. Mitch
Kidvell, of my staff. Your principal intent in writing to EPA is
to seek confirmation of your assessment that the fuels TWM
produces are exempt from hazardous waste labeling requirements.
You also ask for clarification of the regulatory provisions that
govern the production of fuels from oily hazardous petroleum
refinery wastes (i.e., 40 CFR 261.6(a)(3)) and the impact of
various court opinions on these regulations.
As Z understand your letter, TWM has a process that produces
marketable liquid and solid fossil fuel products from oily
hazardous petroleum refinery wastes. The liquid portion is
reinserted into the petroleum refining process and the solid
portion is marketed as a fuel. You assert that the TWM process
is unique because it leaves no residues that would require
subsequent treatment or disposal (aside from the wastewater,
which is further managed in the refinery*s wastewater treatment
system) and use this as a basis for drawing a "significant
difference" between the TWM process and typical oil reclamation
' "processes that recover a liquid component, yet leave a solid
residue requiring disposal.
Regulatory determinations such as the one you seek (i.e.,
specific to your process or products) are made by the appropriate
State regulatory agency or EPA Regional 'Offices. Z am able to
respond to your questions regarding which Federal regulations may
be applicable, clarifying the intent and meaning of various terms
used in the regulations, and provide some of the pertinent
factors to consider in determining the regulatory status of the
TWM process and the fuels produced; however, the determination
must be made on a case-specific basis by the regulating agency.
Under the Federal regulations, there is no regulatory basis
to draw a distinction between secondary materials processed by em
oil recovery process that does not generate a residue and
secondary materials processed by an oil recovery process that
~
frmudmRuyeUdtaptr
41%
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2
does generate a residue. The emphasis you apply to the phrase
"no element of discard" as it describes the TWM process suggests
a misunderstanding of the Agency's use of the phrase in its
January 8, 1988 proposal (see 53 FS 525) on the definition of
solid waste. (This definition is used to determine whether a
secondary material is subject to hazardous waste regulations
promulgated under the Resource Conservation and Recovery Act
(RCRA).)
In the January 8, 1988 preamble discussion, the phrase **no
element of discard" is used to indicate that where there is an
element of discard evidenced in the management of a hazardous
petroleum secondary material (e.g., placement in a surface
impoundment) prior to reinsertion into the petroleum refining
process, the very element of discard indicates that the secondary
material is a solid waste subject to RCRA regulation.
Conversely, if a secondary material is managed prior to
reinsertion into the petroleum refinery process that generated it
such that there is no element of discard (e.g., by managing the
materials solely in tanks), the secondary material is considered
to be part of an ongoing continuous production process, and thus,
outside the scope of RCRA regulation. Whether or not the
processing of the secondary material (in this example, by
reinsertion into the petroleum refining process) results in a
residue that must be disposed of is irrelevant to determining
whether the secondary material, prior to reinsertion, is a solid
waste subject to regulation.
The January 8, 1988 preamble discussion, as well as the
exclusion proposed for oil-bearing hazardous secondary materials
that are reinserted into the petroleum refinery process (proposed
40 CFR 261.4(a)(10)), is neither relevant nor applicable to such
materials that are inserted into an oil recovery process other
than the petroleum refinery process that generated the secondary
material (regardless of whether the recovery process generates a
residue). Rather, fuel that is produced (and oil that is
' "reclaimed and used as a fuel) from hazardous wastes resulting
from normal petroleum refining, production, and transportation by
processes other than normal petroleum refining operations are
eligible for an exemption from hazardous waste regulation under
40 CFR 261.6(a)(3)(viii).
/
Your first four questions indicate a concern regarding
whether the ownership of the unit, the operator of the unit, the
characterization of the unit's operation as intermittent (i.e.,
batch) rather than continuous, or the unit's characterization as
mobile rather than stationary has an impact on whether the
products produced are exempt from regulation. Zn general, under
Federal regulations such aspects of a process have little impact
on the regulatory status of the products produced or the residues
generated.
Lfl°\
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3
The applicable regulatory provisions (40 CFR 261.6(a)(3))
explicitly state the conditions which must be met for fuels
produced from hazardous secondary materials from petroleum
refining to be exempt from regulation. (For example, in
261.6(a)(3)(v), "refining of oil-bearing hazardous wastes along
with normal process streams*; and in 261.6(a)(3)(viii)(A),
"reintroduced into a process that does not use distillation or
does not produce products from crude oil so long as the resulting
fuel meets the used oil specifications under $ 266.40(e).1*)
Zn another question, you refer to the proposed 40 CFR
261.4(a)(10) (S3 FR 529, January 8, 1988) which excludes:
"Oil-bearing hazardous secondary materials from petroleum
refining that are generated onsite and reinserted into the
petroleum refining process along with normal process
streams, provided that the materials are not stored in a
manner involving placement on the land, or accumulated
speculatively, before being so recycled. (Fuels produced
from such recycling activities are not solid wastes.)"
You ask for EPA*s concurrence that TWM fuels are not solid
wastes, since the feed materials meet all of the above
requirements. Such an evaluation would need to be made on a
case-specific basis by the regulating agency.
Zt should be clear from the January 8, 1988 proposal
preamble discussion regarding RCRA jurisdiction that the
exclusion applies only to those secondary materials that are
reinserted into the petroleum refining process (rather than being
"inserted" into an onsite "recovery" process), thereby being part
of an ongoing, continuous production process. (This language is
taken from the statutory provision in section 3004(r).)
Materials that are processed by processes other than "the
petroleum refining process" would not be excluded under this
proposed provision (although, as stated above, there is an
- "existing rule that exempts fuels produced by such other
processes, provided the fuels meet the used oil specifications).
Please keep in mind that the Agency has not finalized the 1988
proposal, nor has any State, to our knowledge, adopted such a
provision in a final regulation. Conditions for meeting the
exclusion could change at promulgation.
A number of your questions refer to the January 8, 1988
preamble discussion and make an assumption that the TWM process
is a "petroleum refining process." EPA described what it means
by a petroleum refinery process (i.e., petroleum refining
facility) in a November 29, 1985 rulemaking that promulgated the
exemptions for fuels derived from petroleum refinery wastes (see
50 FR 49169). (This description was reiterated in the January 8,
1988 proposal preamble discussion, and is consistent with the
statutory language in section 3004(r).) As Footnote No. 11 in
the November 29, 1985 FEDERAL REGISTER notice states, the Agency
~

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4
does not consider used oil-based processes that produce fuel to
be refining operations "(in spite of the use of distillation)
because they do not produce fuels from crude oil." This footnote
further explains that if such processes use "... oilbearing
petroleum refining hazardous waste as a feed material, the
resulting fuels would be exempt if they Met the used oil
specification ..." (emphasis added). By requiring that such
fuels meet the used oil specifications of 266.40(e) to be exempt
from regulation as a hazardous waste fuel (assuming that the
fuels are derived from listed hazardous wastes or exhibit a
hazardous characteristic), the Agency clearly did not intend for
used oil distillation processes (and, by extension, other oil
recovery processes) to be considered petroleum refining
processes, even when oil-bearing petroleum refining hazardous
wastes are used as a feedstock in the used oil distillation
process.
The TWM process does not appear to meet the Agency's
definition of a petroleum refining operation because it: 1) does
not use crude oil as a feedstock, 2) recovers a liquid fraction
that must be rerefined in the petroleum refining process (and
therefore, is not itself a refined hydrocarbon product), and
3) exhibits no evidence that the solid fuel produced is a typical
petroleum refining product rather than a hazardous waste fuel
(i.e., if there is no removal of contaminants in the processing -
- as would be the assumption if such fuel meets the used oil
specifications found at 40 CfR 266.40(e) — then there is no
basis on which to conclude that such fuel is a refined petroleum
product rather than a petroleum refining waste recovery residue
with recoverable energy (BTU) value, or rather, a hazardous waste
fuel). Since it does not appear that the TWM process is a
petroleum refining operation, many of your questions are moot or
are otherwise unanswerable because there is insufficient
information on which to base a response.
Zn two questions you ask whether the January 8, 1988
' proposal has been finalized and whether the Agency has considered
recent court opinions regarding the jurisdiction of RCRA in
responding to your questions regarding the status of the fuels
produced by the TWM process. EPA has not yet finalized the
January 8, 1988 proposal; however, insofar as the proposal and
relevant court opinions address the -scope of RCRA, particularly
in relation to secondary materials that are part of an ongoing
continuous petroleum refining processes, these considerations
were taken into account in responding to your questions.
In another question, you cite the Standard Industrial
Classification (SZC) 2911 for petroleum refining and ask whether
the TWM process is the "redistillation of unfinished petroleum
derivatives." While the TWM process does appear to be the
redistillation of an "unfinished petroleum derivative," the main
focus of the SZC classification seems to be the actual production
of petroleum products. Because the SZC description includes the
<
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phrase "other processes," the emphasis does not appear to be on
2he typ« of process involved, but rather on the feed materials
and the products produced. The TOM process is best characterized
as a recovery process that processes hazardous petroleum refining
wastes to recover a liquid component vhich is reinserted into the
petroleum recovery and a solid component which, assuming it meets
the used oil specifications of 266. 40(e), is a hazardous waste
fuel that is exempt from regulation. Zf the solid fuel produced
by the TOM process does not meet the used oil specifications at
266.40(e), it is subject to regulation as a hazardous waste fuel.
In describing a petroleum refining process, SPA sought to
distinguish between actual petroleum production processes and
ancillary recovery processes. However, exemptions were also
promulgated to address fuels produced by recovery operations
where the contaminants were removed from the fuels, thus ensuring
that the use of the fuels would not pose an increase in risk to
human health and the environment over the use of normal petroleum
refining fuel products. You have provided no data indicating
whether the solid fuel produced by the TOM process meets the
266.40(e) used oil specifications; therefore we are unable to
determine the regulatory status of the solid fuel.
You specifically asked whether the Agency agrees that the
TOM process is a refining process. For the purpose of the
regulatory exemptions found at 40 CFR 261.6(a)(3), the TOM
process does not appear to be a refining process in the same way
that a used oil distillation process is not a refining process.
Rather, the TOM process appears to be a recovery process.
In summary, I reiterate that EPA Headquarters is not the
appropriate entity to make a determination on the regulatory
status of the TOM process as it operates at a particular facility
or on the products it produces. There is no basis on which to
conclude that the TOM process is a petroleum refining process,
and no information was supplied to make a regulatory
* "determination on the status of either the liquid or solid
portions recovered (i.e., no data on whether the fossil products
meet the used oil specifications). If the liquid portion is sold
for direct use as a fuel, the fuel would be exempt from
regulation as a hazardous waste fuel only if it meets the used
oil specifications of 40 CFR 266.40(e). If the liquid portion
(i.e., oil) is reinserted into the petroleum refining process
along with normal process streams, it would be exempt from
hazardous waste regulation under 261.6(a)(3)(vi). If the solid
portion is marketed as a fuel, or further used to produce a fuel,
it would likewise not be regulated as a hazardous waste fuel only
provided that it meets the used oil specifications (assuming that
it meets other relevant criteria for a hazardous waste fuel). If
the recovered portions that are marketed as fuel do not meet the
used oil specifications, such fuels are hazardous waste fuels
(assuming that they are derived from listed hazardous petroleum
4^5
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6
wastes or are themselves hazardous by exhibiting a characteristic
of a hazardous waste).
If you have further generic questions regarding the
regulatory status of recovery processes or fuel products derived
from hazardous petroleum wastes, you should contact Mr. Kitch
Kidvell, of ay staff, at (202) 475-8551. For specific questions
regarding the application of RCRA regulation to the TWM process
or TWM fuel products, you should contact the appropriate State
regulatory agency or 1PA Regional Office.
Sincerely,
David Bussard
Director
Characterization and Assessment
Division
bcc: Allyn Davis, Director
Waste Management Division, Region VI
Bob Kolloway, Chief
Combustion Section
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9493.1991(02)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN 20 199!
ICE OF
SOLID WASTE AND EMERGENCE RESPONSE
MEMORAHDUM
SUBJECT: Regulatory Determination Regarding the Use of
Petroleum-Contaminated Soils as an Ingredient in
Asphalt Ba
FROM: Sylvia K. iQwra,
Office of SotlbsL
TO:
Merrill S. Hi
Waste Manage]
Region Z
This responds to your March 11, 1991, memorandum requesting
a regulatory interpretation regarding the use of petroleum-
contaminated soils as an ingredient in asphalt batching. This
use of petroleum-contaminated soils has become an issue because
the recently promulgated Toxicity Characteristic (TC) rule may
result in such soils being hazardous wastes subject to
regulation, while the majority of such asphalt batching
operations have failed to apply for interim status. Thus, the
two main issues are: (1) determining the regulatory status of
the asphalt batching processes, and (2) the appropriate
enforcement approach to address those regulated facilities that
failed to apply for interim status, or were late in applying.
For the latter issue, I refer you to the April 10, 1991,
memorandum from Bruce Diamond.
In determining the regulatory status of the asphalt batching
operation, there are four different points of consideration:
1) whether the petroleum-contaminated soils are hazardous solid
wastes when used as an ingredient in a product used in a manner
constituting disposal, 2) whether the batching process itself is
legitimate recycling or treatment, 3) whether the asphalt product
meets the waste-derived product exemption found at 40 CFR
266.20(b), and 4) whether the storage of petroleum-contaminated
soils is subject to regulation.
1. Determining whether petroleum contaminated soils are solid
wastes.
In determining whether the contaminated soils are hazardous
wastes when used as ingredients in asphalt, the term "petroleum-
contaminated" may be too generic to enable a definitive
regulatory determination because this term could encompass too

frimudmlUeyeUdfe
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2
broad a variation of contaminants. A more case-specific approach
nay be necessary because certain "petroleum-contaminated" soils
nay be subject to RCRA regulation while others may not.
In general, a hazardous secondary material (and soils
contaminated with a hazardous secondary material) used to produce
a product used in a manner constituting disposal is a solid
waste, unless it is a commercial chemical product that is
normally used la this manner, such as a petroleum product
normally used as an ingredient in asphalt batching (see 40 CFR
261.2 (c) (1) (ii) — although the commercial product may not be
listed in section 261.33, the same regulatory approach applies).
The regulatory status of soils contaminated with crude oil would
be determined by using the same approach. The crude oil, while
not a secondary material, would be a solid waste because it is
being discarded by use in a manner constituting disposal, unless
crude oil is a normal ingredient in asphalt batching. We expect
that most petroleum-contaminated soils are not contaminated
with the petroleum product that normally is used in asphalt
production and would, therefore, be solid wastes. (For example,
if gasoline is not normally used in asphalt production, then
gasoline-contaminated soil is a solid waste when used in asphalt
production.) However, there may be specific cases where the soil
is contaminated with a petroleum product normally used to make
asphalt, in which case the contaminated soil would not be a solid
waste when used in asphalt batching.
Also, you should note that any media (including soil) or
debris resulting from remediation of an underground storage tank
cleanup under Part 280 is excluded from regulation as hazardous
waste (for the D018-D043 constituents) regardless of the intended
disposition, so these soils could be used in asphalt production.
(You should also note that we are presently reviewing a petition
from New York State that requests that the Agency exclude all
, - petroleum contaminated media and debris from regulation under the
TC. A rulemaking may be initiated to address issues raised by
this petition, but the remainder of this memo is based on the
current rules.)
In summary, with the exceptions of soils contaminated with
petroleum materials normally used in asphalt production and
soils resulting from underground storage tank cleanups, soils
contaminated with petroleum materials that are listed waste or
exhibit one of the characteristics would be hazardous and solid
waste. The remainder of this memo discusses the issues relevant
for these soils.
2. Determining whether asphalt batchinj is legitimate recycling.
The act of mixing petroleum contaminated soils into the
asphalt production process may be a form of treatment, subject
to permitting under Part 270, or may~ instead be recycling,

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3
exempt from permitting under section 261.6(c). The main question
is whether the'batching is "legitimate" recycling, as opposed
to treatment in the guise of.recycling ("sham" recycling).
In determining whether the asphalt batching is legitimate
recycling, the Agency compares the contaminated soil with the
analogous raw materials normally used in asphalt batching. To
the extent that the contaminated soils contain hazardous
constituents not found in the analogous raw materials, or contain
hazardous constituents in significantly higher concentrations
than in the analogous raw materials, the batching process would
be considered "sham" recycling, unless such hazardous
constituents can be demonstrated to be useful in the production
of the product or in the product itself. Another factor
indicating whether the batching process is sham recycling is
whether the contaminated soils are legitimately replacing a raw
material or ingredient normally used in the process. For
example, if the contaminated soils are being used in excess of
the amount of raw materials that would otherwise be used, sham
recycling would be indicated. Where sham recycling is indicated
(i.e., where contaminants in the soils are actually being treated
or disposed of by incorporation into a product), a treatment
permit may be required.
3. Determining the-status of the asphalt product.
Whether the batching process is considered legitimate
recycling or not, the resulting waste-derived asphalt product is
a solid waste because it is placed on the land. Assuming that
the resulting product is a legitimate asphalt product, the
applicable regulations are found at 40 CFR 266 Subpart C. Doubts
regarding the legitimacy of the waste-derived product are
resolved by a comparison of the constituents found in the waste-
derived product to the constituents found in an analogous product
that is not produced using contaminated soils as an ingredient.
If the asphalt product is produced using soils contaminated
with a listed hazardous waste (e.g., K048-52), it would be
subject to hazardous waste regulations as a waste-derived
product. If the product meets the conditions of the exemption
found at 40 CFR 266.20(b), which include meeting the applicable
Land Disposal Restriction (LDR) treatment standard(s), the
asphalt product is exempt from further regulation as a hazardous
waste. If the product does not meet the terms of that exemption,
then it remains subject to regulation as hazardous waste, which
would amount to a de facto ban on the product's use. Also, if
the asphalt product does not meet the conditions of the exenption
until further processing, then the asphalt is subject to
regulation as a hazardous waste until the conditions have been
met.
If the asphalt product is produced using soil contaminated
~
Ok
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4
with waste hazardous only because it exhibits a characteristic
(e.g., the TC), then the above discussion applies for as long
as the naterial continues to exhibit the characteristic. Further,
there are currently no LDR treatment standards for TC waste.
You should note that over the next 1-2 years we will be
developing regulations that will address various issues
associated with waste-derived products. We expect those
regulations to further clarify the distinction between legitimate
and "sham" recycling.
4. Determining the status of stored materials.
With the exception of the materials described above in
number 1 (i.e., soils contaminated with petroleum normally used
in asphalt production or from underground storage tank
remediations), — and the exception discussed below — the
storage of contaminated soil that either contains a listed waste
or exhibits a characteristic is regulated under Parts 262, 264,
265, 268, and is potentially subject to permitting under Part
270.
In the case of asphalt product that meets the conditions
of section 266.20(b), no storage requirements apply once the
conditions are met.
Z hope this has helped to resolve your issues. Zf you have
any questions regarding the late notifier guidance document sent
to you earlier by the Office of Waste Programs Enforcement, your
staff should contact Hugh Davis at FTS 475-9867. Zf you have any
questions regarding the regulatory status of recycling processes,
your staff should contact Mitch Kidwell at FTS 475-8551. For
information regarding the New York petition, your staff should
contact Denise Keehner at FTS 382-4740.
Attachment
cc: Waste Management Division Directors
EPA Regions ZZ-X

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9493.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
JUN 2 I 1991
o*nc£ of
SOLID WASTE AMD EMERGENCE RESPONSE
Kevin Young, Esq.
Whiteman, Osterman & Hanna
One Cosiaerce Plaza
Albany, New York 12660
Dear Mr. Young:
This letter responds to your letters of June 19, 1990 and
December 21, 1990 to Mr. Randolph Hill of EPA's Office of General
Counsel regarding the RCBA regulatory status of air pollution
control dusts (i.e., baghouse dusts) generated at facilities
owned by Norlite. These facilities burn hazardous vaste fuels
and the baghouse dust will either be recycled to produce the
aggregate product or be directly used as aggregate.
Specifically, you have asked for a determination that the
baghouse dust, when recycled, aeets the exemption from RCBA
regulation for waste-derived products used in a manner
constituting disposal found at 40 CFR 266.20(b). You have also
requested a determination that baghouse dust used as an
ingredient in the manufacture of concrete masonry is not solid
waste under 40 CFR 261.2(e)(1)(i).
There appear to be four different scenarios for recycling
the baghouse dust that you outline in your letters, two in which
the material is used directly as a product, and two in which the
material is used as an ingredient to produce a product. More
specifically, the scenarios are when the baghouse dust is used:
1) as a product used in a manner constituting disposal (e.g.,
, Uhen used as an aggregate material for asphalt production), 2) as
a product not used in a manner constituting disposal, 3) as an
ingredient in a process that produces a product used in a manner
constituting disposal, and 4) as an ingredient in a process that
produces a product that is nafc used in a manner constituting
disposal (e.g., when used as an ingredient of "block mix" for the
manufacture of concrete masonry that is not, in turn, used in a
manner constituting disposal). Although the uses of the baghouse
dust presented in these four scenarios may seem very similar, the
regulatory determinations differ based on the ultimate
destination of the baghouse dusts or products into which they are
incorporated. We have considered two issues raised by your
request: 1) whether the process or activity involving the
baghouse dust is legitimate recycling (i.e., not treatment or
\ disposal), and 2) whether the baghouse dust itself is a solid
waste or is excluded from being a solid waste because it is a
legitimate substitute for a commercial product or raw ingredient.
•55. PrmtmlonR-
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2
We should note at the outset that a final determination on
these questions must be made by the authorized State regulatory
agency or appropriate EPA Regional office. As we understand it,
your request relates to the Norlite facility in New York? thus,
the regulatory determination must be made by the State of New
York. We provide below a discussion of the factors that EPA
would use to evaluate whether the recycling of the baghouse dust
generated by the burning of listed hazardous waste fuels is
legitimate under Federal regulations; however, this discussion
does not constitute a site-specific regulatory determination for
the Norlite facility.
Scenario 1 — Use as a product in a maimer constituting disposal
The baghouse dust would be considered a waste-derived
product and, when used in a manner constituting disposal, subject
to the conditions placed on such products in the exemption
provided at 40 CFR 266.20(b). It appears from the data you
supplied that the baghouse dust meets the applicable treatment
standards. Thus the waste-derived product would be exempt from
further regulation, assuming it is otherwise determined to be a
legitimate product, which we discuss further in Scenario 2.
In section E of your letter, you suggest that the "contained
in" rule is not applicable to the baghouse dust, and thus that
the baghouse dust is not derived from the listed wastes burned as
fuel in the aggregate kiln and thus is not a listed waste. You
cite the land Disposal Restrictions for First Third Wastes final
rule preamble discussion that presented the Agency's position
regarding the regulatory status of products produced using
hazardous waste fuels. The Agency stated that such products are
not deemed to be used in a manner constituting disposal because
hazardous wastes were not used as ingredients to produce them.
The hazardous waste burned as fuel does not contribute to the
product as an ingredient, but rather fires the production
' process. 53 TR 31198. This preamble discussion is clearly not
applicable to the baghouse dust itself. The baghouse dust i§, the
residue from burning the hazardous waste fuel; it is not the
product. Thus, the baghouse dust itself would be a "derived-
from" waste. However, since the dust itself appears to meet the
section 266.20(b) waste-derived product exemption, this rule
would not affect the status of the dust used as a product.
In section D of your letter you also raise the issue of how
the Bevill rule affects "derived-from" wastes from mineral
processing. As you note, EPA has stated that mineral processing
wastes removed from the Bevill exemption are considered "newly
identified" for the purposes of the land disposal restrictions.
While the preamble discussion states that characteristic wastes
from mineral processing which were removed from the Bevill
exclusion are not subject to treatment standards pending further

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3
rulemaking/ it is silent on how and whether listed wastes used in
the process, either as a fuel or as an ingredient, affect the
wastes newly removed from the exclusion, including residues
derived from listed wastes. We wish to clarify that the
aggregate kiln generates a residue, the baghouse dust, from the
treatment of listed hazardous wastes — wastes that are not newly
identified and for which treatment standards are applicable. So,
the baghouse dust is subject to the land disposal restrictions
treatment standards applicable to the listed wastes burned in the
aggregate kiln. Nonetheless, since the data indicate that the
treatment standards are met, this issue is also moot.
Scenario 2 — Use as a product in a manner that does not
constitute disposal
The baghouse dust would be considered a waste-derived
product, although there are no regulatory requirements for use in
a manner that does not constitute disposal (e.g., the land
disposal restrictions treatment standards do not apply). We
believe that the State of New York should, however, evaluate the
baghouse dust to determine whether it is a legitimate product by
comparison with the aggregate that would normally be used. Based
on your letter, we assume the "normal aggregate" would be the
multiclone dust (i.e., the typical fines product). The data you
submitted indicate that the lead and cadmium concentrations in
the baghouse dust are double the concentrations found in the
multiclone dust. The State should determine whether this is a
significant difference and, therefore, determine whether the
baghouse dust is not a legitimate product.
Scenario 3 — Use as an ingredient to make a product used is a
manner constituting disposal
Use as an ingredient to make a product that is used in a
manner constituting disposal would not exclude the baghouse dust
from the definition of solid waste (see 40 CFR 261.2(e)(2)(i)).
' The aggregate (as a product that is to be placed on the ground)
continues to be a derived-from waste and would be required to
meet the treatment standard. Further, an evaluation of the
actual processing would be in order, i.e., a determination as to
whether the process would be considered legitimate exempt
recycling vs. fully regulated treatment or disposal by
incorporating the hazardous constituents into the product. To
the extent that there are hazardous constituents found in the
baghouse dust that are not found in the analogous raw material,
or that are found in the baghouse dust in significantly greater
concentrations, the process would be determined to be treatment,
unless a demonstration is made that the hazardous constituents
are necessary or beneficial to the process or product. In other
words, the hazardous constituents are being treated rather than
being used as ingredients, unless demonstrated otherwise using
the criteria mentioned above. We should note that EPA would

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4
generally use a total concentration analysis rather than a
leachate analysis to make this determination since we are
comparing the waste against the raw material rather than their
respective leachates. A demonstration of legitimate recycling
would also need to show that the baghouse dust actually replaces
a raw material (e.g.,"for every ton of baghouse dust used, there
is a roughly equivalent reduction of shale or other raw
materials). We note that your letter asserts that the baghouse
dust would be used as a direct substitute for additional raw
material consumption.
In section F, you cite EPA's "indigenous principle* to
suggest that the baghouse dust may not be a hazardous waste when
returned to the kiln. However, absent such a policy EPA
evaluates the baghouse dust as it would any secondary material
being used as an ingredient. The "indigenous principle" most
closely captured in the current regulatory language at 40 CFR
261.2(e)(1)(iii) (the closed-loop exclusion) is not applicable in
any instance where the product is to be used in a manner
constituting disposal (see 40 CFR 261.2(e)(2)(i)).
Scenario 4 r- Us# as an ingredient to make a product aot used in*
a maimer constituting disposal
As in Scenario 2 above, there are no regulatory requirements
for a waste-derived product that is not used in a manner that
constitutes disposal (or burned for energy recovery). If the
baghouse dust will be legitimately used as an ingredient to
produce a product that is not used in a manner constituting
disposal, it would be excluded from the definition of solid
waste. The determining consideration, however, is whether the
baghouse dust is a legitimate substitute for a raw material (as
discussed in Scenario 3). Zf the baghouse dust is determined to
not be a legitimate substitute, the production process would be
considered treatment, and thus would subject the aggregate kiln
to RCRA regulation as a treatment process for the hazardous waste
'burned as an ingredient.
Under Federal regulations, regardless of the scenario, since
the baghouse dust appears to meet the applicable treatment
standards, it could be used as a waste-derived product or
ingredient, assuming that it is marketed commercially and is a
legitimate product. When the baghouse dust is used as an
ingredient in the manufacturing process, the State of Hew York
must determine: 1) whether the baghouse dust is a solid waste
(i.e., whether the product will be used in a manner constituting
disposal) and 2) whether the process is legitimate recycling
(i.e., whether the baghouse dust is a legitimate substitute).
We must again emphasize that the Mew York Department of
Environmental Conservation must make the determinations regarding
the status of baghouse dust under each of these scenarios for the

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5
facilities operating in New York. The role of EPA Headquarters
is to provide technical and policy support to the Regional
offices (or to the States through the Regional offices). We have
provided you the factors that ve would use to evaluate whether
the recycling of the derived-from baghouse dust is legitimate
under Federal regulations. The key considerations are whether
the lead and cadmium concentrations are considered to be
significantly greater in the baghouse dust them in the raw
material and whether the process that uses the baghouse dust as
an ingredient would be considered treatment.
If you have any further questions regarding the factors to
consider in evaluating the regulatory status of a secondary
material when recycled, please contact Mitch Kidwell at (202)
475-8551. For a specific determination regarding the regulatory
status of the baghouse dust when recycled at Norlite's New York
facility, you must contact the State regulatory agency.
Sincerely
Ds
Characterization and
Assessment Division

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9493.1991(05)
OCT I I fggj
N.G. Kaul, P.E.
Director
Division of Hazardous Substance Regulation
Mew York State Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
Dear Mr. Kaul:
thank you for your letter of June 21, 19 9 ^responding to a
May 3, 199^letter we received from Mike Bates of the State of
Arkansas. -4ir. Bates1 letter requested clarification of the
federal Resource Conservation and Recovery Act (RCRA) Subtitle C
regulations governing the management of certain materials used as
ingredients in the production of fertilizers. Your letter
discussed application of the federal regulations to this
situation and raised several additional issues as well,
i ^ i* M>4,
^Mr. Batfs* letter requested clarxfxcatxon of how materials
and activities would be regulated under the federal regulations
in a situation involving the following facts:
•	A generator generates a baghouse dust that is not a
listed waste identified in 40 CFR 261.32 or 261.33 (or,
we assume, 40 CFR 261.31);
•	The baghouse dust, which has a high concentration of
zinc, fails the Toxicity Characteristic for lead;
•	The dust is a "sludge," as defined in 40 CFR 260.10
because it is generated in an air pollution control
facility; and
•	The generator would like to send the baghouse dust to a
producer that could use the dust as an ingredient in
fertilizer for the zinc content.
We will also address the case raised by other states in which
lead is first recovered from the dust prior to its use as an
ingredient in fertilizer production process.
To determine how the federal hazardous waste regulations
apply to management of amy material the first determination that
must be made is whether the material in question is a solid
waste, since by definition a hazardous waste must first be a

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
solid waste (40 CFR 261.3). For materials that are recycled, 40
CFR 261.2(c) defines those materials that are solid wastes. If
the material is both a solid waste and a hazardous waste, the
waste management activities must then he evaluated to identify
applicable requirements.
In the situation described by Mr. Bates, the baghouse dust
would be a solid waste because it is a sludge exhibiting a
characteristic of hazardous waste which is to be used to produce
a product that is applied to or placed on the land (i.e., used in
a manner constituting disposal). (See 40 CFR 261.2(c)(1)(i)(B).)
Since the dust exhibits the Toxicity Characteristic, it is also a
hazardous waste (40 CFR 261.3(a)(2(i)).
Similarly, if the baghouse dust were sent to a facility at
which lead was recovered from the dust prior to shipment to the
fertilizer producer, the baghouse dust would also be a solid
waste under 40 CFR 261.2(c) (1) (i) (B) because it continues to be a
characteristic sludge which is to be used to produce a
fertilizer. This is the case because some portion of the dust is
to be used in a manner constituting disposal, even though another
portion (the recovered lead) will not be used in such a way. In
other words, the solid waste determination for a recycled
material is made at the point of generation of the waste, and
takes into account the entire waste recycling process, not just
the first step in a waste recycling train.
For completeness it should also be noted that the regulatory
status of the dust after the lead recovery step would depend on
whether the dust exhibited any hazardous waste characteristics.
Thus, if the dust exhibited a characteristic it would continue to
be a solid and hazardous waste, again because it would be a
characteristic sludge to be used in a manner constituting
disposal. On the other hand, if the dust did not exhibit any
characteristics after the lead recovery step, it would not be a
hazardous waste at that point.
Once the regulatory status of a recycled material is
determined, the applicable management requirements are specified
in 40 CFR 261.6. For the characteristic sludge which is to be
tised in a manner constituting disposal, the generator and any
transporters would be subject to the applicable requirements of
40 CFR Parts 262, 263, and 268 (including use of the manifest),
and the recycling facility (storer) to the applicable
requirements of Subparts A through L of 40 CFR Parts 264 and 265
268, 270, and 124. (See 40 CFR SI 261.6(a)(2)(i), 266.21, and
266.22.) The recycling process itself (lead recovery and/or
fertilizer production), assuming it is legitimate, would not be
subject to Subtitle C regulation.	. A /
Once the fertilizer is produced, if it meets the' conditions
of 40 CFR 266.20(b) (i.e., is produced for the general public's
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UNITED STATES EHYIROKMeIjTAL PROTECTION AGENCY
.use and meets the applicable land disposal restrictions treatment
standards in 40 CFR Part 268, Subpart D), the fertilizer is not
presently subject to regulation (although under 40 CFR
261.2(c)(1J(i)(B) the fertilizer remains a solid waste, and 40
CFR 268.7(b)(7) recordkeeping requirements would be applicable).
If the fertilizer did not meet the conditions of 40 CFR
266.20(b), use of the product would be subject to 40 CFR 266.23
(i.e., full Subtitle c regulation).
Please note that fertilizers produced using solid wastes are
solid wastes under 40 CFR 261.2 (c) (1) (i) (B) . Although, as you
noted in your letter, 40 CFR 261.2(c) (ii) does include both
commercial chemical products that are listed and those that
exhibit characteristics, this provision applies only to non-
waste-derived products. Fertilizers that are produced using
solid wastes continue to be solid wastes under 40 CFR
261.2(c)(1)(i)(B).
There are several additional points that I would like to
make on this topic. First, I believe that some background on the
development of the use constituting disposal regulations will
shed some light on the reason the regulations are structured as
they are. When these regulations were promulgated on January 4,
1985 (50 EE 614), the preamble explained that RCRA Subtitle C
jurisdiction unquestionably encompasses wastes that are placed on
the land (used in a manner constituting disposal) because this
type of recycling is so similar to normal forms of waste
management (i.e., land disposal). Zn fact, placement on the land
is one of the activities that Congress most clearly intended to
control under RCRA. As with any other waste that is to be
managed in a manner that is analogous to disposal, generation,
transportation, and storage of any wastes that are (even in part)
to be used to produce waste-derived products are regulated (as
are those that are used directly on the land).
Second, there was a discussion in the January 4, 1985
Federal Register notice explaining that in the future, the Agency
envisioned developing a more tailored regulatory system for
waste-derived products recycled by placement on the land. Such a
system would take into account the safety of the product (e.g.,
' levels of hazardous constituents in the wastes, likely routes of
exposure, etc.). We will shortly be proposing a rule that will
allow producers of waste-derived products placed on the land to
make such a demonstration.
In your letter you also raised the issue of how the use (or
fate) of hazardous constituents in a recycling process should be
viewed when evaluating the legitimacy of the process. We agree
with you that this is an important consideration in determining
whether a recycling process is legitimate, and thus whether
recycling exemptions are applicable (e.g., 40 CFR §§ 261.2(c)(3),
261.2(c)(4), 261.2(e), 261.4(a)(8), and 261.6). We have
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
addressed this issue in the past in several preambles (see the
January 4, 1985 Federal Register (50 M 638, 648-9) and the
January 8# 1988 Federal Register (53 £B 526-7)) and in guidance
to the Regional Offices (see the enclosed April 26, 1989
memorandum from Sylvia Lowrance to EPA's Hazardous Waste
Management Division Directors in Regions I-X). For example,
criteria to be used to evaluate the legitimacy of recycling
include the following:
•	Does the waste contain Appendix VIII constituents not
found in the analogous raw material/product (or at
higher levels)?
•	Does tiie waste exhibit hazardous characteristics that
the analogous raw materials/product would not?
•	Are the toxic constituents actually necessary (or of
sufficient use) to the product or are they not
necessary for the product?
Further, as you may know, we are currently undertaking a
larger effort to reevaluate the overall approach to regulation of
hazardous waste recycling activities and to make changes to
ensure that the regulations encourage environmentally beneficial
recycling. We expect "to publish an Advanced Notigg^gf Proposed
Rulemaking in the Federal Register soon which fiyw nut- our
.current thinking on this topic and solicits comment on a number
of possible approaches. One of the	issues-to be discus bed in the
UaPtie^-is- ways to improve implementation of the hazardous waste
regulations by more clearly defining sham recycling and/or by
requiring persons claiming recycling exemptions to notify the
implementing agency of their activities. I strongly encourage
you to review this notice and give us your thoughts on the broad
issues discussed as well as on the sham recycling issue. The
input of state agencies implementing the RCRA program will be
very important to the success of this project.
Thank you for bringing these issues to my attention. Should
you require any further information or have any additional
questions, please call Mike Petruska, Chief of the Regulatory
'Development Branch, at (202) 260-8551.
Sincerely,
Sylvia K. Lowrance, Director
Office of Solid Waste
Enclosure
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9494.1991(01)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C. 20460
FEB 4 I99I
THE ADMINISTRATOR
Honorable Robert W. Hasten, Jr.
United states Senate
Washington, D.C. 20510
Dear Bob:
Thank you for your letter of December 4, 1990, expressing
your concern about the burning of hazardous waste in boilers and
industrial furnaces (BZFs).
I share your concerns about the need to ensure safe
management of hazardous waste in the United States. In your
letter you posed a number of questions regarding the BIF
regulations we issued on December 31, 1990. I am pleased to
provide the following answers to those questions.
Q: Are the new standards as stringent as those required of
other waste incinerators?
A; Yes. The performance standards for boilers and
industrial furnaces burning hazardous wastes are
essentially equivalent to the proposed incineration
amendments, and are more stringent than the current
incineration standards. As in the incinerator
regulations, the BIF regulations include performance
standards for Destruction and Removal Efficiency (DRE)
of organic constituents, hydrogen chloride emissions,
and particulate emissions. The BIF regulations also
include limits on emissions of products of incomplete
combustion (through limits on carbon monoxide and/or
hydrocarbons), hazardous metals, and free chlorine.
The BIF regulations impose substantive requirements on
existing facilities pending permit issuance or denial.
According to the Resource Conservation and Recovery Act
(RCRA), any BIF facilities in existence before these
regulations became effective are granted interim
status, BIF facilities wishing to continue burning
hazardous waste under interim status will have to
submit data, under specific time frames, verifying
compliance with limits on emissions of carbon monoxide
and/or hydrocarbons, hazardous metals, chlorine/
hydrogen chloride, and particulates.	_ ^
4^1
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Q: Is there a strict certification process for new
facilities that is similar to the review other
facilities must complete?
A: Yes. The regulations for boilers and industrial
furnaces subject these devices to the full RCRA
permitting process. Implementation of these
regulations through the permitting process will require
the involvement throughout the Environmental Protection
Agency (EPA) , or the authorized state, prior to any
permit decision. This involvement includes a detailed
review of the permit applications and the solicitation
of and response to public comments. In addition, as
discussed above, BIFs will be required to submit
"certification" data demonstrating compliance with the
interim-status standards in order to continue burning
hazardous waste before that permit decision.
Q: Do the regulations provide for the safe management of
the residue?
A: Yes, in general, residues are subject to the full
panoply of RCRA Subtitle C requirements (i.e., our most
stringent hazardous waste management standards). One
exception would be residues subject to the "Bevill
Amendment." In Section 3001(b)(3)(A) of RCRA, Congress
— excluded from Subtitle C restrictions any residues from
boilers burning primarily coal or other fossil fuels,
industrial furnaces processing primarily ores or
minerals, or cement kilns processing primarily raw
materials. These wastes were deemed by Congress to be
"high volume/low hazard" in character. This exclusion
will be effective until special studies are conducted
to determine how these devices should be regulated.
EPA's position reflected in the BIF regulations is that
so long as, on a case-by-case basis, the processing of
hazardous waste does not significantly affect the
character of the waste residues as high volume/low
hazard, then those wastes may remain excluded under the
Bevill amendment. Any residues that do not meet these
criteria would be subject to Subtitle C requirements.
Q: Do the new regulations establish a definitive timetable
for closing this loophole in our hazardous materials
law that ensures the protection of the public's health
and safety?
A: The rule will require facilities wishing to continue
burning hazardous wastes to demonstrate compliance with
the interim-status standards within specified time
frames. Thus, facilities subject to these rules will
be under a substantial level of control from the
interim-status compliance deadlines until permit
issuance or denial.
-------
Permit applications will be "called in" and reviewed
by the EPA regions or authorized states, based on a
system of environmental priorities. This reflects
one of the conclusions of our RCRA Implementation
Study. which was that EPA (along with the states)
should develop a system that ensures that the most
environmentally significant facilities in a particular
state or region are addressed first.
Z hope that these responses give you a clearer understanding
of how ve plan to regulate boilers and industrial furnaces
burning hazardous wastes. I also want to reiterate my own
concern about the significance of this rulemaking and its role in
ensuring that hazardous waste is managed safely and effectively.
Zf you have any further questions or comments, please have your
staff contact Russ Wyer, Director of EPA's Waste Management
Division in the Office of Solid Waste and Emergency Response,
at (703) 308-8414.
Sincerely yours
William K. Reilly
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UNh^O STATES EHV1R0MMENTAL PROTEC.-M AGENCY 9494 1991(Q2)
NWR 29 1991
Mr. Robert X. Scalliet, President
Scalliet Technologies Inc.
87 Oates Rd., Bldg. 1
Houston, TX 77013
Dear Mr. Scalliet,
I am writing in response to your February 21, 1991, letter in
which you brought up several issues related to sham incineration
and treatment of K048-K052 wastes in cement kilns and industrial
furnaces. Z have fully discussed these issues with Bob Holloway,
Chief of the Combustion Section of the Waste Treatment Branch in
the Office of Solid Haste, and, based on this discussion, am
providing you the following response to the issues raised.
For industrial furnaces, including ceaent kilns, if a K048-
K052 waste is treated to separate oil and water, and the cake
obtained has a heat content below the sham incineration threshold,
then oil cannot be added to the cake to satisfy the threshold
requirement unless the oil was originally part of the K048-K052
waste and was removed during the treatment process. This
requirement applies regardless of whether or not the combustion ash
is recycled in the industrial furnace.
Additionally, all residues generated from the treatment of a
listed hazardous waste, namely K048-K052 wastes in this instance,
are subject to the Land Disposal Restrictions (LDRs) except for
certain residues (e.g., cement kiln dust and primary smelter
, slag) that may be excluded from regulation under the Bevill
Amendment. The February 21, 1991, Federal Register contains the
Boiler and Industrial Furnace Rule which outlines a test for when
the Bevill exclusion applies. If a residue is exempt under the
Bevill exclusion, then the LDRs do not apply to the residue. You
should note, however, that the Agency is considering a rulemaking
to require that Bevill-excluded residues nonetheless comply with
the LDRs. Because of this, we understand that some cement
facilities are voluntarily complying with the LDRs. We encourage
you to do the same for any Bevill excluded residuals that you
generate.
L^O
-------
If you have any questions regarding this response, please call
ae at (703)308-8469 to further discuss these issues.
Jerry F. Vorbach, P.E.
Wa^te Treatment Branch
Office of Solid Waste
tffi
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i £5 \
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
APR 2 3 i99l
ICE Of
SOLID WASTE AND EMERGENCY RESPONSE
Mr. Chris L. Gansel
Test Engineer
Robert Sim Company
240 Great Circle Road, #344
Nashville, IN 37228
Dear Mr. Gansel:
This is in response to your letter of March 21,1990 to Denise Wright concerning
the burning of compressor oil with ammonia in space heaters. You asked whether there
are any regulations prohibiting the burning of such oH
There are no federal hazardous waste regulations specifically restricting die
burning of ammonia contaminated used oils in space heaters. Our regulations under 40
CFR 266.41 governing used oil burning allow off-spedication used oil to be burned in
space heaters provided three conditions are met;
(1)	Hie heater burns only used oil that is generated by the owner/operator of
the space heater or used oil from do-it-yourself oil changers Who generate
the used oil as a household waste;
(2)	The beater has a maximum design capacity of no more than 0 J million
BTU per hour, and
(3)	The heater's combustion gases are vented to the ambient air.
Thus, if your space heater model Sun 2 meets these design and use criteria, it
may be used for the burning of off-specification used oils, including those that may be
contaminated with ammonia, according to the federal regulations. Some States,
however, have different regulations governing used ol and we recommend your checking
with the respective States.
Sincerely yours, .
David Bussard, Director
Characterization and Assessment Division

Primed on R*cyded Pi
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I ^"¥7 5	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
*\ mKl^-
9494.1991(04)
Mr. Gary Anderson
Safety/Environmental Officer
ARA Leisure Services
P.O. Bo* 1926
Page, Arizona 86040
APR 2 3 1991
Of=*>C6 Of
SOLID WASTE AND EMEASINC* RESPONSE
Dear Mr. Anderson:
Tills is in response to your letter of March 25, 1991 concerning the management
and burning of used oil generated by private boat owners. You asked whether there are
any applicable standards for acceptance, storage, testing, or burning, of such oil iu on-
site waste oil furnaces.
Under our regulations in 40 CFR 266.41 for used oil burned for energy recovery,
you may bum off-specification used oil in oil-fired space heaters provided three
conditions are met:
(1)	The heater burns only used oil generated by the owner/operator or
received from do-it-yourself oil changes;
(2)	The heater has a maximum design capacity of no more than 05 million
BTU per hour, and
(3)	The combustion gases are vented to the ambient air.
In the case you described, the oil generated by the owners of private boats would
be considered oil from do-it-yourself oil changers. If your furnaces meet the design and
operating requirements listed above, no federal hazardous waste regulations apply.
, 3Tius, there are no additional standards for the acceptance, storage, or burning, or
testing of used oil generated by either your business or do-it-yourself boat owner oil
changes. Please note that your State may have additional restrictions. Thus, you should
check with your State to see if their are any applicable restrictions.
Should you have any further requirements, please contact Denise Wright at (202)
245-3519.
Sincerely yours, *
Sylvia iL Lowran®:, Director
Office of Solid Waste
MM 3

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9495.1991(01)
I	5	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20450
IHM _ C IC
OFFICE Of
SOLID WASTE A*DEMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Determination on the Regulatory Status of Two Waste oil
Management Practices Utilized by.Wyoming Coal Companies
TO:	Robert L. Duprey, Director
Hazardous Waste Management^Division
Region VIII	f J
FROM: Sylvia K. Lov^anco
Office of Solid
This memorandum responds to your March 4, 1991 request for
regulatory determinations ^regarding two different scenarios in
which waste oil is utilized by Wyoming coal companies. These
determinations concern: 1} whether the waste oil is a solid
waste when used in certain ways, 2) whether the waste oil is
being legitimately recycled (rather than disposed of) when used
in these ways, and 3) whether the management of the waste oil is
subject to Part 266 Subpart E. Although your memorandum does not
specify what type of waste the "waste oil" is, our response
assumes it is "vised oil." The responses to your questions may
change based on what the "waste oil" is. For example, a listed
oily waste or an unused off-specification product oil could have
a different regulatory status than used oil under the different
recycling scenarios you describe.
1. Coal Treating.
In the first scenario, the coal companies mix/spray
approximately three gallons of used oil per ton/cubic yard of
pea-coal (coal crushed to pea size) during railroad car loading.
The used oil is used to suppress coal dust while in transit to
power plants and, to a lesser extent, to increase the BTO value
of the coal. It is ay understanding that this is a standard
practice in the coal industry and that the pea-coal is burned as
fuel.
Because the used oil is being burned for energy recovery
(assuming the oil is a spent material rather than an unused
commercial fuel oil product), the used oil is a solid waste (see
40 CFR 261.2(c)(2)). Because the coal/oil is ultimately used as
a fuel, the material is subject to regulation as a "used oil"
being burned for energy recovery (see 40 CFR Part 266 Subpart £).
PfWt00 /ISCJNCtttf Pi
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2
The toxicity characteristic and TCLP are not applicable as
long as the used oil is legitimately recycled. (See the
exemption at Section 261.6(a) (2) (iii))..
Insofar as such use of the used oil is a standard practice
within the coal industry, our concerns regarding whether this is
a legitimate recycling practice focus on the amounts of used oil
being used and on the hazardous constituents contained in the
waste oil itself. (If such use was not a standard practice, the
Agency would be concerned about the actual use of the waste oil
for this purpose.} Hore specifically, if used oil is used in
excess of the amounts necessary (e.g., if the oil leaks out of
the railroad cars while in transit}, such use could be considered
sham recycling, subject to regulation as a hazardous waste
management activity if the used oil exhibits a hazardous
characteristic.
2. Use in making explosives.
Zn the second scenario, the used oil is used as an
ingredient to produce AHFO (an acronym for an explosive normally
made by combining ammonium nitrate and a fuel oil, such as a
product #l/#2 diesel oil blend or product #2 diesel oil} that is
used to remove overburden/coal from the earth. The key
determination is whether such use of the used oil is legitimate
recycling (i.e., is the waste oil a legitimate ingredient in the
production of ANFO). If the used oil is not a legitimate
ingredient, the used oil is a solid waste (and hazardous if it
exhibits a characteristic of a hazardous waste), and the use of
the used oil to produce the AHFO, as well as the use of the used
oil-derived AHFO, would be subject to permitting requirements.
A key factor in evaluating whether the used oil is a
legitimate ingredient is a comparison of the constituents found
in the used oil to the constituents found in the analogous raw
material, i.e. fuel oil. To the extent that there are hazardous
constituents in the oil that are not found in the fuel oil (or
' "that are present in the fuel oil, but in significantly lower
concentrations}, the oil is not a legitimate ingredient in the
production of ANFO (unless it can be demonstrated that such
hazardous constituents are actually useful in the production of
the product or to the product itself). [Note: Other factors to
consider include an assessment of: 1) how the oil is managed
(i.e., whether the oil is handled in a manner similar to the fuel
oil before use and whether it is handled in a manner to prevent
release to the environment), 2) whether the oil is as effective
as the fuel oil when used as an ingredient in ANFO production
(i.e., whether more used oil must be used to replace the fuel oil
and whether the waste oil-derived ANFO performs as well as the
fuel oil-derived ANFO), and 3) whether excessive amounts of oil
are used (i.e., excessive amounts of oil being used could
indicate an intent to discard)].
uu,<
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3
If the used oil is not a legitimate ingredient in the
production of ANFO, then it is a solid waste being treated by
mixing with ammonium nitrate and the toxicity characteristic is
applicable. And, if hazardous, the used oil may be subject to
the "open burning and detonation" requirements of 40 CFR 265.382.
[Note: Whether the used oil-derived ANFO itself performs as well
as the fuel oil-derived ANFO is not the determining factor in
considering the regulatory status of the waste oil. In other
words, just because a secondary material eaa be used as an
ingredient and still result in a usable product does not, by
itself, mean that the secondary material is not a solid waste and
nor does it mean, necessarily, that the processing is legitimate
recycling. Rather, the determining factors must include the
consideration of the constituents in the secondary material and
the role these constituents play in the production of the
product.]
You mentioned in your letter that the Mine Safety and Health
Administration (MSHA) is currently allowing/monitoring this
practice at Bridger Coal Company from a health and safety
standpoint. It should be noted that although there is agency
overlap between EPA and MSHA regarding health, safety and
environmental considerations, neither agency's jurisdiction
supersedes the other's. For example, if EPA determined that the
used oil is a legitimate ingredient in the production of ANFO,
this would not absolve the coal company from its regulatory
obligations under the MSHA. Likewise, if MSHA grants approval of
the use of used oil as an ingredient in ANFO, this does not
absolve the company from its regulatory obligations under RCRA.
Nonetheless, you may find it useful to share this response with
your colleague from MSHA, Mr. Dick Fischer, whom you mention in
your letter.
I hope this has helped to resolve the issues you have
presented regarding the current regulatory status of used oil
^used as a dust suppressant in the transportation of pea-coal and
as an ingredient in the production of ANFO. As you know, we are
currently developing regulations applicable to the management of
used oil. If you have any further questions regarding the
regulation of used oil or the determination of legitimate vs.
sham recycling, your staff should contact Denise Wright (for used
oil) or Mitch Xidwell (for recycling) at FTS 475-8551.
44b
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9496.1991(01)
tto s*,.
£	*Si
| rimfij g	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
*ima
•Mil?
EME2H
AUG - 5 1991
OP^ ICE OF
SOUO WASTE AND EMERGENCY RESPONSE
SUBJECT:
FROM:
TO:
Regulatory Status of Residues From Secondary Lead
Smelters That Recycle KC69 Wastes
Sylvia K. Lowrance, Direct
Office of Solid Waste

Waste Management Division Directors, Regions I-X
It has come to my attention that there is an issue about the
status of wastes such as slags and drosses that result from
secondary lead smelting when the smelter returns its emission
control dust/sludge (Hazardous Waste K069) to the smelting
furnace as feedstock. This memorandum reiterates that such
residues are hazardous wastes subject to Subtitle C regulation if
they exhibit a hazardous characteristic (e.g.. toxicity for
lead), and it discusses the Agency's intent regarding whether
such residues are considered listed hazardous wastes pursuant to
the "derived from" rule.
EPA stated in the February 21, 1991 "Boiler/Industrial
Furnace" Final Rule ("BIF Rule") (56 Fed. Reg. 7134, 7144) that
residues from metal recovery of listed hazardous wastes normally
are considered to be "derived from" treatment of hazardous waste
and thus listed hazardous waste themselves. Although this
general principle remains valid, we note that EPA did not intend
--for the "derived from" rule to apply to K069 slags and drosses
that result from returning the K069 to the smelting furnace as
feedstock. The Agency initially attempted to achieve this result
through application of the so-called "indigenous" principle to
K069 slags. See August 17, 1988 "First Third" Land Disposal
Restrictions Final Rule, 53 Fed. Reg. 31138, 31198-99. The June
1, 1990 "Third Third" Land Disposal Restrictions Final Rule (55
Fed. Reg. 22520, 22565-68) also presumed this result in its
discussion of slags from secondary lead production, which were
discussed exclusively in the context of D008 wastes. However, a
subsequent decision by the U.S. Court of Appeals, in American
Petroleum Institute v. EPA. 906 F.2d- 726, 740-42 (D.C. Cir.
1990), called into question the validity of the "indigenous
principle" as EPA had applied it. (See BIF Rule, 56 Jed. Reg. at
7142, 7144, for a brief discussion of the court's decision.)
Although EPA maintained in the BIF Rule that residues from
treating listed hazardous wastes in metals recovery processes
4M1
-------
generally are subject to the "derived from" rule, the Agency
overlooked the recycling practices in the secondary lead industry
in promulgating that rule, it was not our intent that the
"derived from" rule apply to secondary lead smelting residues
that result when K069 dusts are recycled to the smelting process
as feedstock.
We expect to address these issues more formally in the
context of upcoming rulemakings. In the interim, please contact
Mike Petruska at 475-8551 if you have any questions.
cc: Regional Counsel RCRA Branch Chiefs
Gary Jonesi, OE-RCRA
Steve Silverman, OGC
Susan Bromm, OWPE-RZD
2
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9497.1991(01)
i S3

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
4 mi
O* * ICE O*
SOCIO WASTE AMD EMERGENCY RESPONSE
Richard A. Svanda
Director
Hazardous Haste Division
Minnesota Pollution Control Agency
520 Lafayette Road
This letter responds to your January 16, 1991 request for an
interpretation concerning the regulatory exemption found at 40
CFR 261.6(a)(3)(ii) for "used batteries (or used battery cells),
returned to a battery manufacturer for regeneration." In your
letter you explain that the Minnesota State Legislature has
passed a bill making it illegal to dispose of four types of waste
battery cells in municipal solid vaste landfills. The bill went
further by requiring manufacturers to establish a system for
proper handling and disposal of such batteries.
You are requesting that SPA interpret the exemption for used
battery regeneration to include material recovery. In this way,
the management of the batteries would -be exempt from the
otherwise applicable hazardous waste regulations (e.g.,
manifesting and storage), thus facilitating the recycling of
these materials. As alternatives to this interpretation, you
request that SPA either: 1) revise 40 CFR Part 266 Subpart G,
"Spent Lead-Acid Batteries Being Reclaimed," to include all waste
batteries being reclaimed; or 2) recommend to the state
regulatory agencies that they use enforcement discretion in
implementing the applicable regulations.
Zn promulgating the exemption for used batteries that are
"regenerated," the Agency discussed its reasons for doing so (see
the April 4, 1983 proposal preamble, 48 FR 14496). The main
reasons were that there was minimal risk of environmental damages
and that the activity of regenerating the batteries was very
similar to the recycling of a commercial product. Such
activities are generally not considered waste management
activities, but are more akin to a manufacturing operation. Zn
the January 4, 1985 final rule preamble (see 50 FR €33), SPA
defined reclamation to include the "regeneration" of waste
materials and the processing of waste materials to recover usable
products, but not all reclamation is exempt. In the preamble
discussion, the Agency drew a distinction between regeneration
(i.e., processing to remove contaminants in a way that restores a

PrintmloRfiecvdettf
-------
2
product to its usable original condition, as in the reclamation
of spent solvents through, distillation) and material recovery
(i.e., processing to recover usable material values as the end-
products of the process, as in the reclamation of metal values by
the smelting of a secondary material). EPA*s long-standing
policy is that smelting is not regeneration, and batteries sent
for smelting are therefore not exempt under this provision, i.e.,
the definition of "regeneration" is veil established and does not
include metals recovery. A change in the meaning of
"regeneration" is not interpretive, but would require a
regulatory change (i.e., amending 40 CER 261.1(c)(4)), and would
have far-reaching implications, e.g., the standards at Part 266
Subpart G for spent lead-acid batteries that are reclaimed would
not apply to anything if the spent lead-acid batteries were
exempt.
Regarding your request that the Agency extend the current
reduced regulatory requirements applicable to spent lead-acid
batteries that are reclaimed to all waste batteries, SPA may
consider such an amendment to encourage the recycling of waste
batteries provided that protection of human health and the
environment can be ensured. The reasons for the special
requirements for spent lead-acid batteries destined to be
reclaimed were discussed in the April 4, 1983 proposal (see
discussion 48 FR 14496-99) to the January 4, 1985 final rule.
While EPA required hazardous waste permits for storage at
reclamation sites (e.g., secondary smelters and battery
crackers), EPA did not believe that regulatory controls on
generators and transporters were necessary because there were
other incentives outside of RCRA that would ensure that the
materials would both arrive at their intended destination and
would not be improperly managed before their reclamation. For
example, spent lead-acid batteries were an established valuable
commodity and were customarily reclaimed (indeed, the secondary
lead smelting industry is based on the reclamation of lead-acid
batteries) and mishandling during transportation was considered
unlikely due to Department of Transportation requirements under
40 CF1 122. Also, the Agency believed that the storage of the
spent batteries by retailers, wholesalers, or local service
stations would be properly managed because these establishments
rely heavily on good public relations with the consumer. To the
extent that the same considerations are evidenced in the
management of other types of waste batteries, the Agency may
consider providing a similar regulatory framework in a future
rulemaking.
Finally, with regard to your third alternative, it is
certainly within the purview of an authorised State to use
discretion in how it implements its own hazardous waste program,
including how it sets its enforcement priorities, lowever, SPA
has a policy against giving definitive assurances, written or
oral, outside the context of a formal enforcement proceeding.
-------
that EPA will not proceed with an enforcement response for a
violation of an environmental protection statute or regulation.
We share your interest in finding alternatives to control
the disposal of potentially hazardous waste streams that are
typically managed in municipal landfills. The situation you
described will be considered in efforts underway to address
multiple concerns regarding the regulation of hazardous waste
recycling. If you have further questions regarding the
regulations applicable to these waste types, you may contact Mr.
Mike Fetruska, Chief of the Regulatory Development Branch, at
(202) 475-8551.
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9497.1991(02)
I M 1	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\j4Vy	WASHINGTON, D.C. 20460
NAY ? r
OFFICE Of
SOUO WASTE AND EMERGENCV RESPONSE
Mr. Paul £. Pentz
Executive Vice President, C.O.O.
SERVISTAR Corporation
P.O. BOX 1510
Butler, PA 16003-1510
Dear Mr. Pentz:
Chi* letter responds to your letter of May 13, 1991
concerning the regulation of nickel-cadmium'(HiCd) batteries
under the Resource Conservation and Recovery Act (RCRA) and state
legislation requiring manufacturers to take back spent batteries
(take-back programs). We appreciate your interest in developing
recycling programs for NiCd batteries and in the BORA regulation
of these prpgrams. We commend your recycling efforts and hope
that you will be developing recycling systems not only in states
passing take-back legislation, but nation-wide.
We are considering the points that you raise in your letter
concerning the difficulties involved in implementing recycling
programs for NiCd batteries if they exhibit the TC. We are
currently examining the available options to determine how to
facilitate the kind of take-back system you describe. We expect
it will take us several more weeks to assess options and reach a
tentative decision on how to best address your concerns. At that
time, we will notify you of the results of our analysis and of
our plans to implement the decision.
To ensure that you are informed about our approach to this
tissue, there are several options that we are exploring. First,
we are investigating what could be accomplished in the short term
to alleviate the problems you have identified. One possibility
is to extend the current regulations governing lead-acid battery
reclamation to spent NiCd battery reclamation. As part of this
effort, we will be evaluating issues such as the size of the
problem, the hazards posed by NiCd battery waste management and
recycling practices, and the feasibility of possible solutions.
Second, over the longer term, we are currently analyzing the
RCRA regulations to determine how they could best be modified to
encourage environmentally sound recycling of hazardous wastes.
In particular, we are evaluating how to address reverse
distribution systems that involve the returr of hazardous wastes
trmUdmKiKfdMHft

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2
to product manufacturers. In any case, we will continue with
this longer term effort to examine fully how best to address this
difficult issue, including the possibility of changes to the
regulations to accomodate take-back systems.
Finally, we would like to be sure that you are aware that
under the current federal regulations, hazardous wastes generated
by certain persons are not subject to the full hazardous waste
regulations even when subsequently collected and managed by
others. Particularly, these excluded wastes include household
wastes generated by individuals at home (40 CFR 261.4(b)(1)) and
hazardous wastes generated by conditionally exempt small quantity
generators (generators who generate a total of less than 100
kilograms of hazardous waste per month; 40 CFR 261.5).
Thank you for your interest in the hazardous waste
regulations concerning recycling of HiCd batteries. Should you
have any further questions regarding this issue, please contact
Mike Petruska, Chief of the Regulatory Development Branch, at
(202) 475-8551.
David Bussard
Director
Characterization and Assessment
Division

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
9503.1991(01)

MAY 2 I 1991
¦1.	;VE°CESC> BcSsC\S:
Mr. Steve Novak, Controller
Compacting Technologies International
241? N.W. Thurman
P.O. Box 29046
Portland, Oregon 97210
Dear Mr. Nowak:
I an writing in response to your letter, dated
March 14, 1991, in which you request clarification of the
definition of treatment. Of particular concern to you is whether
treatment includes practices such as compacting hazardous waste
inside a steel drum.
As described in your letter, Compacting Technologies
International (CTI) sells a machine that compacts hazardous waste
inside a steel drum? the benefit to the customer is a reduction
in waste volume and thus, a reduction in disposal cost. Your
concern seems to be whether such a practice constitutes treatment
that is subject to the permitting requirements of
4 0 CFR 270.
Treatment is defined in 40 CFR 260.10 as "...any method,
technique, or process, including neutralization, designed to
change the physical, chemical, or biological character or
cpmposition of any hazardous waste so as to neutralize such
'waste, or so as to recover energy or material resources from the
waste, or so as to render such waste non-hazardous, or less
hazardous; safer to transport, store, or dispose of? or amenable
for recovery, amenable for storage, or reduced in volume"
(emphasis added). Based on the limited amount of information in
your letter, a machine that compacts hazardous waste in a drum
will meet the definition of treatment if the reduction in volume
results in a change in the physical, chemical, or biological
character or composition of the waste. Bear in mind, however,
that under many circumstances, RCRA permits are not required for
generators who treat their waste on-site in tanks or containers
(see enclosed memorandum dated June 17, 1986).
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A final determination on whether a permit is required for
such a compaction practice, however, must be made in the EPA
region or authorized state where this machine will be operated.
The determination will be subject to site-specific conditions and
waste types that are best assessed by regional or state
personnel.
I hope thxs information is helpful. Again, if more specific
information is needed, please contact the applicable EPA regional
office or the authorized state.
Director
Office of Solid Waste
/
I-5
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9521.1991(01)
UNITED STATES EHYIRONMENTAL PROTECTION AGENCY
mil \m
MEMORANDUM
Subject: Potentially Conflicting Regulation of Infiltration
Galleries by the Office of Ground Water and Drinking
Water and the Office of Solid Waste
From; Sylvia K. Lovrance
Director
Office of Solid Waste
To:	Frederick F. Stiehl
Enforcement Counsel for Water
This is in response to your July 26 memorandum regarding
potential conflicts in the regulation of infiltration galleries
by OGWDW and OSW as a result of our April 2, 1991 Federal
Register notice extending the Toxicity Characteristic compliance
date for certain injection veils. Apparently, since the
compliance date was not extended for infiltration galleries, our
discussion was construed to indicate that injection wells and
infiltration galleries are mutually exclusive unit types. As is
explained below, this was not our intention.
The intent of the extension was to provide relief to
operators of injection wells used in certain hydrocarbon recovery
operations. Since application of the TC would cause these Class
V wells to become Class IV wells, these beneficial cleanup
operations would be halted in cases where the Class XV wells do
not have UIC permits and where the cleanup operations do not meet
' the conditions of Section 3020 of RCRA. We believed that
owners/operators of these units were in an impossibility
situation—that is, their operation would be in violation of
RCRA, but the continuation of the cleanup was ordered by the
State. Where the unit was not an injection well, this
impossibility did not exist, since they could continue to operate
the unit under interim status. For such units (i.e., units
other than injection wells), the extension was not provided. In
distinguishing between units to which the extension was
applicable vs. other units, we noted that if the infiltration
gallery met the definition of an injection well, then the
extension would apply. That is, we recognized that some of the
units identified by the industry as "infiltration galleries" may
meet the UIC program's definition of an injection well and, if
they did, they were included in the extension. On the other
MM, afert&in units mat eoui&^saacziiuaMv i>u idmiLiiiua ds»
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UNITED STATES EN VIRONMEMTAL PROTECTION AGENCY
"infiltration galleries" {e.g., leaking surface impoundments)
were not injection wells and thus were not included in the
extension.
We believe that this approach is consistent with that of
OGWDW and the Department of Justice, as described it in your
memorandum. In order to clarify this matter, there are two
apparent options: we could either issue a clarifying memorandum
to the Regions or publish a short clarification notice in the
Federal Register. We would be pleased to work with you to
develop appropriate language to ensure consistency between our
offices. Should you wish to pursue either of these options, or
discuss another course of action, please contact Dave Topping of
my staff at 382-7737.
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9521.1991(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
AUB 3 0 1991
OFFICE OF
SOCIO WASTE AND EMERGENCY response
MEMORANDUM
SUBJECT: Permit Status of Underground Injection Wells Used in
Certain Hydrocarbon Recovery Operations
FROM:
Sylvia K. Lovranca. a *1/ _0
Director	A-.	
Office of Solid-waste
TO:	Janes R. Elder
Director
Office of Ground Water and Drinking Water
On April 2, 1991, OSW promulgated a rule that extended the
compliance date for the Toxicity Characteristic until January 25,
1993 for groundwater that is reinjected through injection wells
during certain cleanup operations. More specifically,
application to produced groundwater from free-phase hydrocarbon
recovery operations at petroleum refineries, marketing terminals,
and bulk plants was deferred at the point at which the
groundwater is reinjected. Without this extension, most
reinjected groundwater from these operations would have become a
RCRA hazardous waste on September 25, 1990.
The basis for this compliance date extension was a
regulatory "impossibility" situation encountered at these
operations. In many cases, the cleanup/recovery operations were
^ mandated under State orders but would be banned under both RCRA
and UIC regulations unless they were, among other things, part of
a cleanup under either RCRA or CERCLA. The two-year extension
was intended to allow time for the Agency to develop a mechanism
to permit these wells (as Class IV) upon the January 25, 1993
compliance date of the TC. The purpose of this memorandum is to
ensure that our Offices work together to resolve this situation
before that date.
In a February 19, 1991 memorandum from Peter Cook to Jeffery
Denit (copy attached), it was stated that ODW's policy is that
Agency approval of these operations under RCRA or CERCLA
constitutes "authorization by rule" for the Class IV wells
involved in the cleanup. Since this may be- crucial to
establishing the mechanism to allow continued operation of these
operations, we should ensure that the affected programs are
comfortable with this policy and that it is legally defensible.

Printed on Recycled Pa
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Key issues include the meaning of "approved under RCRA or
CERCLA." It must be determined whether this "approval" is in the
form of a permit, a written order, or some less formal
endorsement of the operation. Likewise, the scope of the RCRA
permit-by rule provisions of 40 CFR 270.60 (b), which afford a
RCRA permit to a tJIC-permitted injection well, should be
discussed and clarified. There are also procedural issues to be
addressed, including whether the policy has been subject to
sufficient public notice and comment.
Depending upon the resolution of these issues, one of
several options may be preferred. If additional notice and
comment is not required, an explanation of the policy could be
included in an upcoming TC clarification notice planned by OSW.
Otherwise, notice and comment requirements could be satisfied
through an OGWDW rulemaking to codify the policy into the UIC
regulations.
We look forward to working with you on this issue to ensure
that the purpose of the compliance-date extension is realized.
The OSW lead for this project is Dave Topping, who can be reached
at 382-7737. Please have the appropriate member of your staff
contact him-at your earliest convenience.

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Volume 10
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 10
LjGO
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9523.1985(07)
|	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*	WASHINGTON. D.C. 20460
November 18, 1985
OFFICE OF
SOLID WASTE AND EMERG6NCV RESPONSE
OSWER Directive #9540.6-1A
MEMORANDUM
SUBJECT: Post-Closure Permit Part B Requirements
FROM: Marcia E. Williams, Director \$\
Office of Solid Waste	*
TO:	Waste Management Division Directors,
Regions I-X
This Office has recently received a number of inquiries
concerning information requirements for Part B post-closure
permit applications. Outlined below is a brief discussion of
those requirements and a list of information elements which
should be included is such applications.
40 CFR 270.14 establishes the information requirements for
RCRA permit applications. Because of the inherent differences
between an operating permit and a permit covering only post-
closure care activities, some of the information requirements for
an operating permit will not be applicable to a permit for the
post-closure care period. Section 270.10(c) gives EPA and States
the authority to determine that an application is complete
whenever an application form and supplemental information are
completed to the satisfaction of the Director. We therefore
recommend that the Director only require information be submitted
< Which is relevant to post-closure care activities. Relevant
information may be determined on a case-by-case basis. At a
minimum however, it should include:
A* Pre-BSWA Regulatory Requirements (§270.14):
-	A copy of the post-closure inspection schedule
($270.14(b)(5))
Floodplain information (5270.14(11)(iii - iv))
A copy of the post-closure plan ($270.14(b)(13))
-	Documentation of the notice in deed or an appropriate
alternative instrument ($270.14(b)(14))
-	Cost estimate for post-closure and post-closure
financial mechanism ($270.14(b} Ci£>)
-	A copy o£ IShe stafea llnaiicial instrument XZ appxofnrXmxm
($270.14)(b)(18))

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Groundwater data and information demonstrating
compliance with requirements for detection monitoring,
compliance monitoring and corrective action, as
applicable (§270.14(c))
B. New information required by HSWA, including at least:
- Information on solid waste management units and
releases from those units (§264.101? see RSI #3)
Financial responsibility for corrective action (if
applicable)
For landfills and surface impoundments, exposure
information (§270.10(j)) (Hot© that lack of exposure
information would not result in an incomplete
application, but would be a separate violation).
As stated above, this list represents the minimum
information that should be required. In some cases, it may be
appropriate to require additional information depending on the
nature of the facility, waste characteristics and other factors.
For example, if a facility is expected to handle wastes (e.g.,
leachates) during the post-closure period which could potentially
cause environmental or public health damage if mismanaged or if
accidents were to occur, it may be advisable to require a
contingency plan (5270.14(b)(7)).
_ If you have any further questions, please contact George
Faison at 382-2221.
cc: RCRA Branch Chiefs
Permit Section Chiefs

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i5
y^V	9523.19 91(01:
\

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
•-1AR I 3 1991
oppice Of
SOLID WASTE AND EMERGENCY RESPONSE
Honorable Glenn English
House of Representatives
Washington, D.C. 20515
Dear Mr. English:
Thank you for your letter of February 4, 1991, regarding the
Environmental Protection Agency's (EPA's) authority to consider a
permit applicant's history of compliance with the Resource
Conservation and Recovery Act (RCRA).
As Mr. Robert Layton stated in his January 15, 1991, letter
to you, RCRA section 3005(c) requires that EPA (or the state)
shall issue a permit to a hazardous waste treatment, storage, or
disposal facility once the EPA determines that the facility is in
compliance with the requirements of sections 3004 and 3005 of
RCRA. Neither section 3004 nor 3005 explicitly requires a permit
applicant to have complied with RCRA in the past, or requires EPA
to deny a permit if past noncompliance has occurred. However,
the statute provides a broad "omnibus** authority that the EPA may
use to address a facility's compliance history when developing
permit conditions or making permit decisions. The scope of this
omnibus authority and our implementation of this provision are
described below.
Section 3005(c)(3) provides that permits issued under that
section shall contain whatever terms and conditions EPA
determines are necessary to protect human health and the
* "environment. When issuing a permit, EPA may invoke this omnibus
authority to address past noncompliance in two ways. First, EPA
may include permit conditions that specifically address areas in
which the facility has a history of noncompliance if EPA
determines that such conditions are necessary to protect human
health and the environment. In addition, in perhaps a more
extreme and unusual case, some instances of serious past
noncompliance could conceivably lead EPA to conclude that
noncompliance in the future is inevitable. If EPA cannot draft
conditions to ensure protection of human health and the
environment in this type of case, then EPA may invoke its omnibus
authority to deny the permit (see the enclosed page from the
Federal Register notice). It is important to note that the
omnibus provision is invoked on a case by case basis, and only
where EPA believes that the usual permitting conditions will not
provide adequate human health and environmental protection.
Printed on Recycled f
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Furthermore, EPA need not rely completely on the potential
for permit denial to encourage compliance with RCRA prior to
permit issuance.. Section 3008 of RCRA authorizes EPA to take
enforcement actions against facilities prior to permit issuance,
including those already operating under interim status. Thus,
even though previous violations of the interim status standards
of Part 265 may not ultimately prevent the issuance of a permit,
a facility owner or operator is still subject to civil and
criminal penalties for those violations (including penalties for
each day of non-compliance).
After issuing a permit, EPA has several mechanisms in place
to address noncompliance. The regulations at 40 CFR 270.43(a)
allow EPA either to terminate a permit or to deny its renewal
if the owner or operator fails to comply with any term of the
permit or if the facility's operation endangers human health or
the environment. In addition, EPA may invoke enforcement
authority under RCRA section 3 008 to remedy noncompliance at a
permitted facility.
In light of the above statutory and regulatory authorities,
it does not appear necessary to modify the regulations at this
time. If you have any further questions on this matter, please
have your staff contact Devereaux Barnes at (202) 475-7267.
We appreciate your interest in the safe and effective
management of hazardous waste.
Sincerely yours
Don R. Clay
Assistant Administrator
Enclosure
HUM
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9525.1990(02)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20450
OCT It 1990
opfice of
SOLID WASTE iNOIMERCINC* RESPONSE
Mr. James T. McVey
Executive Vice President
Diversified Scientific Services, Inc.
P. 0. Box 863
Kingston, Tennessee 37763
Dear Mr. McVey:
This is in response to your letter of August 8, 1990, in
which you request the Environmental Protection Agency's (EPA)
consideration and advice on your proposal to treat some
radioactive mixed waste prior to disposal. Currently, your
permit, which was issued under the authority of the Resource
Conservation and Recovery Act (RCRA) for treatment, storage, and
disposal (TSD) of hazardous waste, does not include provisions
for the management of the specific type of mixed waste you
propose to treat. I understand that my staff has discussed this
issue and the delay in our response in earlier telephone
conversations with you.
Specifically, you propose to stabilize 825 drums of barium
chloride salts (D005 wastes) containing low concentrations of
uranimum prior to disposal of the waste in a licensed nuclear
waste burial facility. This waste would be shipped from its
present location at Westinghouse Materials Company of Ohio in
Fernald, Ohio, to Diversified Scientific Services, Incorporated's
4-DSSI*s) TSD facility in Kingston, Tennessee for treatment. The
State of Tennessee, which is authorized for both the radioactive
mixed waste program and radioactive materials licensing
activities, has denied your request to treat the D005 waste under
the existing conditions of your RCRA permit. The State has
determined that your RCRA permit must be modified to include
specific provisions for the management of D005 waste, prior to
treating the waste for land disposal. EPA concurs with the
State's assessment that this waste may not be treated at the DSSI
facility without first obtaining the necessary modification to
DSSI's RCRA permit.
Before addressing the permit modification procedures, please
be advised that D005 waste is subject to the land disposal
restrictions which are provisions of the Hazardous and Solid
Waste Amendments (HSWA) to RCRA. Among other things, HSWA
frimtd on Rtcyckd Paptt
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prohibits restricted wastes from land disposal unless the wastes
meet the treatment standards established by EPA. For D005 waste,
EPA has prescribed a treatment level of 100 mg/1 as the
characteristic level for barium. In your letter, you indicated
that the D005 mixed waste would be disposed at a licensed nuclear
waste burial site after treatment. Therefore, the waste must be
treated to meet the land disposal restriction program•s
prescribed t*^atment level prior to such disposal.
In regard to RCRA permit modification procedures, there are
two procedural avenues available for obtaining the necessary
modification; through State procedures or through Federal
procedures. Since Tennessee is authorized to control D005 mixed
waste, you could apply to the State for appropriate changes to
your RCRA permit. In this case, you would follow the State's
permit modification process. Alternatively, since Tennessee does
not have authorization for the land disposal restrictions, EPA
administers and enforces this program, as mandated by HSWA, until
the State is specific-lly authorized to do so. Pursuant to this
Federal authority, EPA may add conditions to your RCRA permit to
allow treatment of the D005 wastes so that the land disposal
restrictions will be met. In this case, the Federal modification
procedures in 40 CFR 270.42 would be used. Please note that on
March 7, 1989, EPA created expedited modification procedures to
allow facilities to add new waste codes and/or treatment
processes to comply with the land disposal restrictions, if the
specified conditions are met (54 FR 9596; see enclosure).
However, you should also note that a Federal change to the RCRA
permit will not override more stringent state requirements. In
this regard, you should confirm with the State that such Federal
approval will also satisfy the State program.
I encourage you to work closely with the EPA Region and
State authorities to obtain the permit modification required to
treat the D005 waste. Mr. Wayne Garfinkel in the RCRA program
office, USEPA Region IV, in Atlanta, Georgia may be contacted at
(404) 347-3433 for further assistance on this matter. In
addition, Mr. Dale Ozier of the Solid Waste Management Division,
' Department of Health and Environment in Nashville, Tennessee may
be contacted at (615) 741-3424, for assistance from the State.
Also, we have a strong interest in following the development
of s**fe and environmentally sound treatment and disposal methods
for mixed waste, particularly in view of the current shortfall in
treatment and disposal capacity. As part of our effort to
maintain current information in this area, I invite you to work
closely with my staff to exchange information en technology
development, as well as existing permitted facilities involved in
the management and disposal of radioactive mixed waste.

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If you have general questions regarding the Federal permit
modification procedures, please contact Wayne Roepe of my staff
at (202) 475-7245. Please contact Jared Flood of my staff at
(202) 475-7066, if you have any questions concerning our
activities on radioactive mixed waste.
Enclosure
cc: Wayne Garfinkel
USEPA, Region IV
Dale Ozier
Solid Waste Management Division
Dept. of Health and Environment
Office of Solid Waste
uL>1
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9528.1991(01)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
„ „ _	SOLID WASTE AND emergence *espo
AUG 7 1991
Samuel I. Gutter
Sidley & Austin
1722 Eye Street, N.W.
Washington, D.C. 20006
Dear Mr. Gutter,
This letter is in response to your letter of June 27, 1991
to Sylvia Lowrance, in which you seek clarification of the
application of the Boiler and Industrial Furnace (BIF) rale to
newly regulated units at interim status facilities. In your
letter, you ask questions regarding the criteria a unit must meet
to gain interim status as a newly regulated unit. First, you ask
what constitutes a "newly regulated" unit under 5270.72(a)(6).
Then you ask what requirements a unit must meet to qualify for
interim status as a newly regulated unit. Finally, you ask if
construction may commence after the effective date of the rule.
The criteria for a unit to gain interim status are the same
for an interim status facility and a newly regulated facility. A
"newly regulated" unit under 1270.72(a)(6) is one which is
subject to the RCRA permitting requirements for the first time as
a result of a rulemaking. An example of a newly regulated unit
is a boiler or industrial furnace that will become subject to the
RCRA permitting requirements on the effective date of the BZF
rule.
To obtain interim status under §270.72(a)(6), a newly
regulated unit such as a BIF must meet the definition of an
, ^existing hazardous waste management facility" as defined under
' §260.10. This definition does not necessarily require that
physical construction of a unit be underway before the effective
date of the BZF rule. However, if construction of a BIF unit has
not begun by August 21, 1991, the facility must meet the criteria
in the definition of "existing facility," including (1) have
obtained the Federal, State and local approvals or permits
necessary to commence construction and (2) have entered into
contractual obligations — which cannot be canceled or modified
without substantial loss — for physical construction of th»
facility (or unit) within a reasonable time.
For the BIF rule, E7A Regional offices will be making the
determinations regarding interim status. These decisions are
necessarily made on a case-by-case basis, considering the
~
Lj&S
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specific facts of a particular site. Therefore, I recommend that
you contact the appropriate EPA Regional office to discuss
specific facilities that may be subject to the BIF rule.
Z hope that this response answers your (juestions. If you
require further clarification, please call Wayne Roepe (202) 475-
7245 of my staff.
Sincerely,
Frank McAlister, Chief
Permits Branch

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*> A \
iSSSi
9528.1991(021
UNITED states environmental protection agency
WASHINGTON, D.C. 20460
FFR ? 7 1QQI	ofocc of
I UU L. I »35Jl	SOLID WASTE AND FMPBf.l
SOLID WASTE AND IM6RCINCY RESI
Mr. George Sullivan
Chairman, Recycling Sciences
International, Inc.
30 South WacJcer Drive
Suite 1420
Chicago, Illinois 6060$
Dear Mr. Sullivan:
This letter responds to the inquiry made by you and your
company's legal counsel whether several hazardous waste treatment
facilities that employ a single mobile treatment unit may qualify
for interim status. Your firm, Recycling Sciences International,
Inc. (RSI) owns several waste storage and treatment facilities at
different locations, but employs only one mobile treatment unit.
among these various facilities, transporting the treatment unit '
from one facility to another. You also indicated that RSI's
mobile treatment unit accepts only organic-contaminated soils
that are newly regulated as hazardous waste under the revised
toxicity characteristic (TC) rule (55 IB 11798, March 29, 1990),
and that RSI has applied for interim status to EPA for facilities
in Arizona, Pennsylvania, Michigan, and Mississippi.
As you are aware,. the TC rule was promulgated by EPA under
the authority of the Hazardous and Solid Waste Amendments (HSWA)
and therefore is implemented by EPA in all states (until the
states become authorized for the TC rule). 1 have addressed your
specific questions below:
1. How does a facility qualify for interim status under the TC
rule?
There are three basic prerequisites for obtaining interim
status pursuant to $ 3005 of RCRA:
(a)	The facility must be in existence on the effective date
of statutory or regulatory amendments that render the
facility subject to the requirement to have a RCRA
permit ($ 270.70(a))?
(b)	The facility must have complied with the notification
requirements of $ 3010(a) of RCRA (S 270.70(a)(1)); and
fcj7§
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(c) The facility must comply with the requirements in 40
CFR 270.10 for the submission of the Part A permit
application (S 270.70(a)(2)).
A facility must meet all of the above criteria to qualify
for interim status. Note that for a facility to be "in
existence", it may either be in operation or under construction.
See | 270.2 for the definition of "existing hazardous waste
facility".
2.	Can a mobile treatment unit qualify for interim status at
each facility where it is operated?
Yes, a single MTU may qualify for interim status at more
than one location. At each site the MTU must meet the three
interim status criteria described in question one above. The
fact that the treatment unit is a mobile unit instead of a
stationary unit does not diminish the opportunity to gain interim
status. After the effective date of the TC rule (September 25,
1990), the unit must meet all applicable interim status
standards.
3.	Does routine movement of the MTU from site to site
constitute a change in interim status- that has to be k
approved by EPA?
No, such movement is not a change in interim status under
Federal regulations as long as the unit is always operated within
the constraints identified on the Part A permit application
(e.g., the types and quantities of hazardous waste, and the unit
process types and design capacity). Simply moving the unit to or
from the site does not in itself constitute a change in interim
status. However, any change to the unit or to the operation that
results in an "increase in design capacity", a "change in
process", or an "addition of process" would require a revised
Part A and prior approval by EPA before the change could be
'Implemented (see § 270.72(a)).
4.	If a facility in an authorized state obtains interim status
for TC wastes from EPA, can the company amend interim status
without prior approval to treat and store hazardous waste
not previously identified in the Part A?
An interim status facility located in an authorized state
but regulated by SPA because of the TC rule can apply to EPA for
additional TC waste codes not on the original Part A and other
HSWA waste codes that the State is not authorized for. The
addition of a new, non-HSWA waste code would be subject to
regulation by the authorized State and not by EPA. Note that if
the State has not yet adopted the TC rule and a facility with
Federal interim status due only to TC wastes wants to make
changes to add non-HSWA wastes regulated under the authorized
Mil
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- 3 -
State program, this may be viewed by the state as a "new"
hazardous waste operation since the facility would not have
inter in status tinder State law. In this case, the State might
require a RCRA permit prior to receipt of the wastes.
If you have any questions, please contact me (202-382-2223)
or Wayne Roepe of my staff (202-475-7245).
Frank McAlister
Acting Chief, Permits Branch
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(®j
9523.1991(03)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
AUG I 9 1991
O** ICE Of
SOUO WASTE AND EMERGENCY RESPONSE

TO:	Janes J. Scherer
Regional Administrator
FROM: Don R. Clay, Assistant Administrator
Office of Solid Haste and Emergency Respons
SUBJECT: Interim Status under the Boiler and
Industrial Furnace Rule
Thank you for your memoranda of April 16 and Hay 2, 1991,
in which you described your strategy for addressing boilers and
industrial furnaces (BIFs) seeking interim status as "existing
facilities" under EPA's BIF rule.
I appreciate your concern about BIFs seeking interim
status without any history of hazardous waste management, or
any documented commitment to such activities. Further,
I commend your efforts to ensure that interim status is
reserved for those facilities that, under the regulations,
are legitimately entitled to such status. At the same time,
our decision on whether a specific facility has met the standard
should be consistent with our past decisions and with our
established regulatory interpretations.
In an attachment to this memorandum, I address the specific
points you raised in some detail. In any decision on a
particular facility, however, you need to keep in mind what we
believe is the general intent of both the statute and our
implementing regulations: that facilities with a history of
handling hazardous waste at the time the waste becomes subject to
regulation, or that have made a substantial commitment to handle
the waste in the near future, be allowed to continue their
activities under interim status. Where a facility has actually
handled hazardous waste before the effective date of the
regulation (that is, August 21, 1991, for the BIF rule), the
facility is clearly eligible for interim status. Where the waste
has not yet been handled by the effective date, we agree that the
case becomes more complex, and its resolution depends on the
Printadm Aaeyctotfft
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ability of a facility to demonstrate a substantial commitment
to hazardous waste management within the near future. Criteria
for making this decision are discussed in more detail in the
attachment to this memorandum. Clearly, these criteria must be
applied on a case-by-case basis considering the particular
circumstances at each facility.
In your April 16 memorandum, you made an important point:
that BIFs seeking interim status may be underestimating the
potential costs for corrective action. We agree that the costs
could be high and that BIFs may not have adequately taken them
into account. I suspect that if the potential liabilities are
clearly pointed out to BIF owner/operators, those who have not
already made a substantial commitment to managing hazardous
waste may have second thoughts about entering the business.
Additionally, BIF facilities should clearly understand that
gaining interim status, by itself, does not convey the right to
burn hazardous waste. It is likely that other federal, state,
and local requirements must also be met, and the conferring of
interim status does not extinguish any other legal obligations.
I trust that the attached response will assist you in
implementing the BIF rule in your region. If you have any
questions regarding these criteria, please feel free to contact
Devereux Barnes at (202) 475-7276.
Attachment

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ATTACHMENT
Clarification of Xataria Status critaria for BIF Facilities
Background
The basic requirements for obtaining interim status were
established by section 3005(e) of RCRA, as amended by HSWA, which
specifically grants interim status to "any person who is in
existence on the effective date of statutory or regulatory
changes under this Act that render the facility subject to the
requirement to have a permit." In the legislative history
accompanying this provision, Congress indicated that "existing
facilities" would include types of facilities that were
previously exempted from certain RCRA requirements but
subsequently became subject to those requirements. (See 50 £E
28723, July 15, 1985.) We have consistently taken this position
in the case of new waste identifications (e.g., see the Toxicity
Characteristic rule, 55 11798). EPA has also acknowledged on
several occasions that non-hazardous waste management facilities
that are converting to hazardous waste management but have not
yet begun hazardous waste management by the effective date of a
regulation could qualify for interim status (see 46 £B 2346).
One of the three basic prerequisites for obtaining interim
status pursuant to $3005 of RCRA is for a facility to be "in
existence" on the effective date of any statutory or regulatory
amendments that render the facility subject to the requirement to
have a RCRA permit (§270.70(a)). Two kinds of facilities are
deemed to be "in existence": (1) a facility that is "in
operation" on the effective date of a regulatory or statutory
change that renders a facility subject to the permit requirement
(i.e., treating, storing, or disposing of hazardous waste), or
(2) a facility that is "under construction" on the effective date
of such a change. For a facility to be considered "under
construction," $260.10 (under the definition of "existing
facility") requires that the facility must have all permits and
approvals necessary for physical construction and either: (1) an
on-site construction program has begun, or (2) the facility has
accepted substantial contractual obligations for such
construction, to be completed within a reasonable time.
We understand that several BIFs in Region VIII have already
been constructed and may wish to begin hazardous waste operations
after the August 21 date. EPA has interpreted the term
facilities "under construction" also to include facilities that
have completed construction on the relevant date if they cam
demonstrate the intent to commence hazardous waste operations
within a reasonable period of time (i.e., through a trial bum or
agreements with suppliers to receive hazardous waste derived
fuels), and if the facility meets the other relevant standards
for "in existence." The Agency's interpretation of what

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2
constitutes being "under construction" is discussed in detail in
the January 9, 1981,	Register (46 £B 2344).
1.	What State and local approvals or permits are necessary to
meet the definition of "existing facility"?
One requirement for a facility to be considered "under
construction" is that it possess "the Federal, State, and local
approvals or permits necessary to begin physical construction."
As defined in §260.10 (under the definition of "Federal, State,
and local approvals or permits necessary to begin physical
construction"), these permits or approvals are those required
under hazardous waste control statutes, regulations, or
ordinances. Air pollution control permits that must be obtained
prior to facility construction or modification under Federal or
state laws would not be needed for interim status if the purpose
of the legislative provision is to regulate air emissions in
general, and not specifically to regulate the treatment, storage,
or disposal of hazardous waste, or the siting of a hazardous
waste management facility. Similarly, state or local building or
zoning permits would be included only if they specifically
address hazardous waste management. Of course, the facility
remains responsible under state or local law for obtaining
relevant building and zoning permits and approvals, even though
the failure to obtain them will not prevent a facility from
obtaining interim status.
It is important to recognize that the requirement relating
to approvals and permits refers to approvals or permits necessary
to begin Physical construction. Since the Region VIII BIFs have
already been constructed, the requirement should be read to apply
to approvals for any physical modification needed to receive
hazardous waste. Of course, if the physical modification has
already been completed, the need for preconstruetion permits
would not arise as an issue (unless it could be argued that the
-construction took place illegally in the absence of a necessary
permit).
2.	What constitutes a "substantial loss due to a contractual
obligation"?
To be considered "in existence," a facility not already
handling hazardous waste and not yet under construction must have
"entered into contractual obligations — which cannot be canceled
or modified without substantial loss — for physical construction
of the facility to be completed within a reasonable period of
time." As one way of demonstrating substantial loss, EPA has
in the past used cancellation contract clauses. Thus, EPA has
interpreted "substantial loss" as being at least 10 percent of
the total project cost for physical construction. Physical
construction means fabrication, erection, installation, or
modification of a facility. The term does not refer to all costs
•-j7G
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3
that nay be associated with a construction project; for example,
options to purchase, contracts for feasibility, or engineering or
design studies would not constitute an eligible contractual
obligation. (See 46 EE 2346, January 9, 1981.) In the case of
BIFs that have not burned hazardous wastes before, the total
project cost for physical construction refers to the
modifications necessary for the BIF to manage hazardous waste.
Although the 1981 preamble does not specifically address when
meeting the 10 percent threshold would not be sufficient, we
believe that if the loss to the facility of canceling the
construction were minimal, the loss could not be considered
substantial, even though it exceeded 10 percent. For example, if
the total cost of kiln modification were $5,000, a 10 percent
loss ($500) would not be viewed as substantial. In contrast, for
a project that would exceed $250,000, we believe that 10 percent
would represent a substantial amount.
Of course, contract cancellation clauses with higher
percentages, or other approaches to a demonstration of
substantial loss, could be considered by the Regions as well.
In that regard, we note the unique circumstances presented by the
BIF rule for cement kilns that will be modified to burn hazardous
waste. Even though the contractual cost of installing such
modifications can be relatively low, the Regions can take into
account other economic factors and actions showing substantial
loss insofar as they provide evidence of a bona fide substantial
commitment to managing hazardous waste in the near future.
You should also note that the "substantial loss" criterion
must be met only at facilities where construction (i.e., facility
modifications to receive hazardous waste) has not begun. Where
physical construction is underway or completed, a facility is
not required to show "substantial loss," but rather objective
indications of a bona fide intent to manage hazardous waste.
3. What constitutes a "reasonable time to complete
construction"?
The regulations do not define the term "reasonable time to
complete construction," nor do they define a "reasonable time" to
begin management of hazardous waste, in the case of an already
constructed facility. To determine what is a reasonable time,
Regions must make a case-by-case decision. Generally, if a
facility is undergoing a continuous process to initiate or
complete construction activities, and arrangements are in place
to ensure that such construction can be carried out on a schedule
that is typical of similar construction activities, then
completion of construction should be considered to be within a
"reasonable time." The same rule of thumb applies to the
definition of a "reasonable time" to begin management of
hazardous waste.
tfll
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4
4.	Effect of a state moratorium.
In your memorandum of April 16, 1991, you discuss the
possible effect of the Utah moratorium on the ability of cement
kilns in the state to qualify for interim status. Since the Utah
moratorium only prohibits the burning of hazardous wastes in
cement kilns, it is still possible for a facility to meet the
fundamental criteria for gaining interim status. Of course,
gaining interim status does not affect the legal status or
applicability of Utah's moratorium. In contrast, there could be
other situations where a moratorium could prevent a facility from
meeting one of the "in existence" criteria. For example, if the
facility were unable to obtain a required approval for
construction due to a moratorium on hazardous waste
preconstruction permitting, interim status would be precluded.
5.	Section 3010 notification requirements for BIPs.
It is likely that very few BIFs were required to submit a
section 3010 notification on May 22, 1991. One reason is that
this notification requirement only applied to facilities actually
handling hazardous waste fuel on February 21, 1991. (See 45 ZE
76631, November 19, 1980.) This section 3010(a) notification is
intended to be a "snapshot" of hazardous waste management
practices at the time a rule is promulgated. Therefore, if a
facility is "under construction" a Section 3010 notice is not
required. (See B.R. Rep. Ho. 198, 98th Cong., 1st Session, 40
(1983).) Another possibility is that the facility might have
already submitted a notification previously either for the
burning of hazardous waste fuel under 5266.35, or for some other
hazardous waste activity, in which case the 1IF is not required
to renotify.
6.	Pre-Compliance certification.
The BIF rule does not require facilities to submit a pre-
compliance certification by August 21, 1991, to attain interim
status. Once a facility meets the statutory and regulatory
requirements, interim status follows automatically. However, if
a facility fails to submit such a certification (or if the
facility fails to comply with subsequent interim status
compliance schedule requirements), it loses its ability to manage
hazardous waste in the BIF unit, unless and until it receives a
Fart B permit.

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Volume 11
Inserts
Place the Attached
Memos at the End of
the Appropriate
Category Number in
Volume 11
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DEC 3 199!
9534.1991(01)
MEMORANDUM
SUBJECT: RCRA Regulations Applicable to Control Devices Required
by the Organic Air Emission Standards (40 CFR Parts 264
and 265 Subparts AA and BE)
FROM: James Michael, Acting Chief
Assistance Branch (QS-343)
Office of Solid Waste
TO:
Catherine Massimino
Senior RCRA/Superfund
Technical Specialist
Region 10
In your memorandum of June 19, 1991, you ask for clarification
as to the standards that apply to control devices required by the
Organic Air Emission Standards for Process Vents and Equipment
Leaks, promulgated pursuant to RCRA Section 3004(n) on June 21,
1990 (55 FB 25454). This rule is codified at 40 CFR Parts 264 and
265 Subparts AA and BB. You identify potential ambiguity as to
what standards are applicable when the control device meets the
definition of a regulated unit under another portion of the
regulations. You provide the example of a control device at a
permitted facility that fits the definition of an incinerator and
ask what standards apply — the requirements of the organic air
emission rule (e.g., to reduce total organic air emissions from all
affected process vents at a facility by 95 percent weight or
greater), or the Part 264 Subpart 0 incinerator requirements (e.g.,
the requirement to achieve a destruction or removal efficiency
(DRE) of at least 99.99%). My office, in conjunction with the
Office of General Counsel, has concluded that, as a general master,
the Subpart AA and BB standards govern such control devices.
Of course, the air emission rule does not limit EPA's
"omnibus" authority under RCRA Section 3005(c), 40 CFR Section
270.32(b), to impose, on a case-by-case basis, any permit
conditions regarding air emissions that are determined to be
necessary to protect human health and the environment. In
addition, the Subpart AA and BB standards address only the
performance that must be achieved by a control device with respect
to organic air emissions from process vents and equipment leaks
covered by the air emission rule. If the device is a separate unit
that is also treating separate hazardous wastestreams, the unit
mngf nf r!miT*se comply withcotqiimiBCBiopriate Part 264 or 265 unit
standards.£or itd tcejrtmerit of tho^e wastestreams.
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The June 21, 1990 organic air emission rule required the use
of control devices to reduce emissions from certain types of
process vents and equipment leaks and required that the devices
meet standards specified in the rule, such as the requirement in 40
CFR Section 264.1033(c) that enclosed combustion devices reduce the
organic emissions vented to them by 95 percent or greater by
weight. IPA recognized in promulgating the rule that incinerators
might be among the devices that would be used to achieve the
standards imposed, see, e.g., 55 FR 25455. Nonetheless, the
discussion and analyses accompanying the rule — including, for
example, the health impact and cost impact analyses — are based on
the premise that the devices installed pursuant to the rule will
achieve the standards established by the rule, not the general Part
264 and 265 standards. See 55 £R 25486-25489, 25462, and 25477
(June 21, 1990).
The conclusion that the organic air emission rule standards
govern the performance of the required control devices is
consistent with the purpose and context of the rule. A facility
that, pursuant to the organic air emission rule, installs a control
device that appears to fit the definition of an incinerator is not
getting a "break" by being subject to the air emission rule
standards rather than the Subpart 0 standards. On the contrary,
the air emission rule for the first time requires the reduction of
gaseous emissions from certain equipment leaks and process vents
that were previously unregulated (except to the extent they were
regulated on a case-by-case basis pursuant to the omnibus
authority). The standards imposed by the organic air emission rule
are those which EPA determined to be protective. See 55 FR 25486-
25488 (June 21, 1990).
There is one caveat to this conclusion. You had expressed
concern that there may be instances in which a facility attempts to
use the organic air emission rule as a means of subjecting itself
to less stringent standards than it would otherwise be subject to -
- where, for example, a facility constructs a treatment train in
which an incinerator is preceded by a unit with regulated process
vents or equipment leaks in an attempt to characterize the
incinerator as a Subpart AA or BB control device. In such
circumstances, permit writers may conclude that the device is not
a bona fide Subpart AA or BB control device and impose the general
incinerator standards. These decisions will have to be made on a
case-by-case basis. Headquarters will assist permit writers in
these decisions upon request.
If you have any questions or concerns, please call me at FTS
260-1206, or Brian Grant of OGC at FTS 260-6512.
cc: Permit Section Chiefs, Regions I-X
Frank McAlister, PB, PSPD, OSW
Brian Grant, OGC
w
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
9541.1984(09)
erne* or
MEMORANDUM
SUBJECT:
APR t S84
FROM:
TO:
Status of Federal Permics in
States Which Have Received RCRA
Final Authorization
Gail B. Cooper 7	, 1
Attorney
Bruce Weddle
Director
Permits and State Programs
Division (WH-563)
In August 1982, OSV issued a Program Implementation
Guidance memorandum (PIG-82-5) on the status of federal
permits after a state receives interim authorization. You
have asked us whether the same guidance may legally apply
to final authorization. In addition, you requested that we
commit to writing the legal advice we gave you orally when
PIG-82-5 was being developed.
Background and Conclusion
Under RCRA S3006 and 40 C.F.R. Part 271, a state which
has received interim or final authorization operates the RCRA
^.program in lieu of EPA. Among other things, upon approval
of a state program, EPA suspends the issuance of Federal
permits for those activities included in the authorized state
program. 40 C.F.R $S271.1(f) and 271.121(f). The status of
existing federal permits after authorization is less clear,
however. In 1982, the following question arose: if state
RCRA permits comparable to existing federal permits are not
issued at the same time the state receives interim authorization,
do existing federal RCRA permits remain in effect? We concluded
then that the more persuasive interpretation of RCRA was
that federal permits remain in effect until terminated in
compliance with 40 C.F.R. Parts 270 and 124. Because the
4U
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-2-
pertinent statutory and regulatory provisions are the same
for interim and final authorization, the same conclusion
would hold for final authorization.
Discussion
Sections 271.8(b)(6) and 271.126(c)(1) of the RCRA state
authorization regulations provide that the Memorandum of
Agreement (MOA) between the state and EPA must contain provisions
specifying a procedure for transferring the administration
of existing federal permits to the state. They further provide
that if na state lacks authority to directly administer permits
issued by the Federal government, a procedure may be established
to transfer responsibility for these permits." An example of
such a procedure is provided in a note to S271.8(b)(6): the
state, EPA and the permittee could agree that "the State would
issue a permit(s) identical to the outstanding federal permit
which would simultaneously be terminated.*1 1/
This provision clearly provides that EPA-state procedures
on the transfer of permits must be established but is silent
on whether such transfers must be effective on the date of
authorization. This issue was addressed for interim authorization
on August 9, 1982 by a Program Implementation Guidance memorandum
(PIG-82-5). The memorandum concluded that federal permits remain
in effect after Phase II authorization until the state issues a
RCRA permit or assumes responsibility for administering the
federal permit if it has the authority to do so. According to
the memorandum, federal permits do not terminate automatically
but must be terminated according to the procedures in §270.43 or
by agreement of the permittee and EPA. To avoid the need for
EPA administration and enforcement of federal permits in authorized
states, the memorandum strongly encouraged the states to issue
state RCRA permits or administer federal RCRA permits as soon as
possible.
As we indicated to you, it is conceivable that someone
' ^could challenge the policy reflected in the memorandum in a
permit or enforcement proceeding by arguing that since section
3006 provides that the State carries out the RCRA program
"in lieu of the federal program" upon authorization, federal
permits terminate automatically upon a state's authorization.
Following that interpretation, the state would have to be
1/ Section 124.5(d) provides that EPA does not have to
~ issue a notice of intent to terminate a permit in
this situation.
3
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able to assume or administer che Federal permit (or issue
its own RCRA permit) at the time it was authorized in order
for the facility to continue to have a RCKA permit.
We do not find that argument persuasive. Many states do
not have the statutory or regulatory authority to administer
federal permits or to issue their own RCRA permits as of the
date of authorization. If federal permits automatically expired
upon a state's authorization, a facility could be left without
any permit (if there were no state permit for that facility)
or eould continue to operate under a state permit with less
stringent requirements than were contained in the federal RCRA
permit. Given Congress* general goal of providing for the
effective regulation of hazardous waste and the "no less stringent
requirement" is Section 3009 in particular 2/, it is difficult
to conceive that Congress would have' intended that the transfer
of authority from EPA to a state result in a decrease in
environmental protection. In our view, PIG-82-5 is a reasonable
interpretation of our legal authority, designed to assure that
authorization of a state program does not cause a facility to
lose its permit or allow a facility to benefit from relaxed
permit requirements. 2/
The analysis is supported by a case dealing with the KPDES
program under the Clean Water Act (CWA). In Central Hudson
Gas and Electric Corporation v. U.S.E.P.A.. 587 F.2d 549, 560
(2nd Cir. 1578) , EEa had Issued a mU permit which was partially
contested. Before the Fart 124 adjudicatory hearings began on
the contested provisions, the State MFDES program was approved
by EPA. The State and EPA arranged for EPA to continue to
handle the adjudicatory hearings and any subsequent litigation.
The permittee challenged EPA's authority to do so, pointing to
the CWA provision which states that when a state program is
" I/ Section 3007 provides that ... "no state or political
subdivision may impose any requirements less stringent
than those authorized under [subtitle C] respecting the same
matter as governed by such regulations ..."
2/ EPA does not have the same leeway if the federal permit has
not yet been issued. 40 C.F.E. 271.1(f) specifically
provides that "Upon approval of a State permitting program,
the Administrator shall suspend the Issuance of Federal permits
for those activities subject to the approved State program.1*
Thus, even if EPA has already issued a draft permit and held
public hearings, it may not proceed to issue a final RCRA permit.
This obviously makes it essential for EPA and the state to allocate
permitting resources efficiently in the period before a state
receives authorization.
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approved by EPA, the EPA must "suspend the issuance of permits.
33 U.S.C. 51342(c)(1). EPA argued that the permit had been
issued, so that this provision did not govern.
The court deferred to EPA's position that the permit had
been "issued" and did not get into the broader issue of what
happens to EPA permits after NPDES approval. To that extent,
the decision does not address the same legal issues we might
confront. However, the court's reasoning is relevant; it
concluded that the statutory policy of having states implement
the NPDES permit program was outweighed by the Act's primary
objective to restore and maintain water quality. The court
was persuaded by EPA's argument that the permittee's
interpretation would produce duplication, waste, and delay,
and disrupt the state program because the state would not be
prepared to bear the sudden transfer of the permit. The Court
did not wish to discard the transition mechanism EPA and the
state had worked out. While there are differences between
the CVA and RCRA, the similar statutory goals and problems
of transitions from EPA to state regulation make this case
a helpful precedent for PIG-82-5.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9541.1991(01)

MEMORANDUM
SUBJECT: Pilot Delegation of RCRA Subtitle C State Program
Revision Authorizations to the Regions
FROM: Don R. Clay
Assistant Administrator
E. Donald Elliott
General Counsel
TO:	Regional Administrators, Regions I-X
In response to a request made by the Regional Waste
Management Division Directors as well as the recommendation of
the RCRA Implementation Study, ve are fully delegating the
responsibility for RCRA Subtitle C State program revision
application review and authorization decisions to the Regions on
a two year pilot basis. We look upon this delegation as an
opportunity to make EPA more responsive in authorizing RCRA State
programs while, at the same time, developing an expanded
cooperative role between the Regions and Headquarters. This
pilot delegation will allow the Regions to review and make
decisions on program revision applications without HQ
consultation or concurrence. However, Headquarters review and
concurrence will still be required for those few States, and in
-the future, Indian Tribes, applying for base RCRA program
authorization. This delegation is effective March 1, 1991.
In setting up the Subtitle C program, Congress envisioned
the Agency would expeditiously authorize qualified States. A
quality authorization program requires a significant commitment
to enhance State capability and actively delegate programs to the
States. In order to support this commitment, we are asking that
each Region submit an annual "State Enhancement and Authorization
Plan" outlining what the Region is doing to build State
capability and encourage authorization. Guidance for developing
this plan will be in the FY 92 RCRA Implementation Plan to be
issued by April 1, 1991, and will indicate when these plans will
be due.
U; ^
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Each Region will be fully responsible for maintaining the
integrity of the authorization decision process, including
explaining those decisions to the public and Agency oversight
bodies such as Congress. In addition, delegation of this
authorization responsibility to the Regions is contingent on
Regional commitment to raise issues of national significance to
Headquarters on a timely basis and to adhere to basic guidance
and policy as well as to the underlying statutory and regulatory
requirements for authorization. To that end, each Regional Waste
Management Division Director must certify prior to the Regional
Administrator approving an application that national issues have
been brought to Headquarters1 attention.
As it is critical that the Office of the Regional Counsel be
fully involved, the Regional Counsel must also provide assurances
that all legal issues have been reviewed and satisfactorily
addressed. The Offices of Regional Counsel and the Office of the
General Counsel will share responsibility for any defensive
litigation arising from delegated approvals. The Offices of
Regional Counsel must notify OGC promptly when litigation is
filed. OGC will determine whether the case raises any issues of
national significance and retain responsibility for litigating
such issues. The Offices of Regional Counsel will be responsible
for all other issues.
Headquarters will issue broad national guidance outlining
potential issues of national significance. However, since many
of the issues that arise in a revision application are of first
impression, increased Regional alertness to potential national
issues is critical and Regions should err on the side of prudence
in raising issues to Headquarters.
At the end of the two year delegation pilot, we will decide,
based on our review of each Region1s authorization performance,
whether to continue the delegation. In the near future,
Headquarters will establish oversight criteria by which we will
measure Regional success in achieving the national authorization
-<• goals of enhancing State capability and delegating programs to
the States is attached. There will be regular evaluation of
Regional performance, possibly through annual audits and
Headquarters attendance at end-of-year and mid-year state
evaluations. Regions will also be expected to maintain accurate
and timely authorization data.
Each Region undertaking this delegated review and
authorization role must fully recognize the significantly
increased responsibility of Regional authorization program staff
and the need for active ORC involvement. In addition, each
Region is responsible for providing adequate staffing and
training for authorization. Headquarters will provide two
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authorization training workshops beginning in the Spring of 1991
and be available for technical (policy and legal) assistance to
the Regions upon request.
The success of this delegation is dependent upon all of us
taking our responsibilities seriously, in full realization of the
critical implications of authorization decisions. We know we can
count on you and your staff to give RCRA authorization careful
attention so that we can all be proud of our accomplishments and
maintain a track record that withstands careful public and
Congressional scrutiny.
cc: Hazardous Waste Management Division Directors, Region I-X
Regional Counsels, Regions X-X
Sylvia Lowrance, OSW
Bruce Diamond, OWPE
Lisa Friedman, OGC
3
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^ \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/	WASHINGTON. O.C. 20460
.v
«'•"	9542.1982(03)
AUG -S 1982
v ,w°4	PIG-82-5
SPViCC 09
SOLID WASTC AMS IMtftOENCY MCS'Cr
MEMORANDUM
SUBJECT: Status of State Permits Issued Before a State
teceives RCRA Phase II Authori zation
FROM: Rita M. lavelle . -St ~>P'
Assistant Adrainistrator for
Solid Waste and Emergency Response (WH-562-A)
TO:	Program Implementation Guidance Addressees
ISSUE
Once a state is authorized for a component of Phase II,
what is the status of hazardous waste facility permits which
the state issued prior to being authorized for the component?
*an they be considered RCRA permits? What is the status of
an EPA-i ssued federal permit in a state authorized for a
component of Phase II?
DISCUSSION
Prior to being authorized for a component of Phase II a
state may require facilities that treat, store, or dispose of
hazardous waste to obtain a state permit. There are no pro-
visions within RCRA or the federal hazardous waste regulations
for-designating ihese pre-authorization state permits as RCRA
permits. RCRA permits can be issued only by EPA- or an autho-
rized state. Authorization requirements ensure that an autho-
rizes state will be using procedures substantially equivalent
to the federal permitting procedures (state procedures must,
of course, meet the requirements of Secti on 7004(b) of RCRA)
and will be requiring compliance with standards providing
substantially the same degree of protection as the federal
technical standards (See 40 CFR 123.129).
Before a state is* granted Phase II authorization, five
situations are possible for a hazardous waste management facility
operating in a particular state. In all of these situations
lift
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vCRA Section 3005(a) applies. That is, owners and operators of
facilities that treat, store, or dispose of hazardous waste can
legally do so only when they have a RCRA permit. Also, RCRA
Section 3005(e) applies, allowing qualified facilities to continue
to operate under federal "interim status". When the state receives
interim authorization different results occur in each of the five
situations as described below.
1)	A facility has neither a sta.te permit nor a federal
a	/ w	•	*
•*	L I w ^	« «•**«»«# *•«»•*> • %»«»«*< » » »»#•**» t Mi «# «« W« « /f
This situation is very strai ghtforward. The state must
eventually issue the facility a state RCRA permit. Of
course, before the stitM could have obtained Phase I
interim authorization, it must have had some mechanism
in place to apply standards substantially equivalent
to federal interim status standards to all of the hazard-
ous waste management facilities within its borders.
2)	A facility has a state-issued permit but no federal
RCRA permit (but does have federal interim status)
This situation is also fairly straightforward; the state
must eventually issue a RCRA permit to the facility.
The facility can continue to operate lawfully until that
time, provided the facility will be subject to state
standards substantial 1y equivalent to the federal
interim status standard!. The timetable for reissuance
can be negotiated between the Regional Administrator and
the State Director and is to be delineated in the Memorandum
of Agreement and discussed in the Program Description,
legally, the state permit cannot- tre considered a RCRA
permit even if the state permit was issued using standards
and procedures that were eventually authorized. However,
under these circumstances there would be very little reason
to reissue the permit in the near future, and the state
could plan to reissue the permit at the end of the current
, " permit term or at some other convenient time.
3)	A facility has a federal RCRA permit but does
not have a state permit
In this situation the state can assume responsibility
for the admi m stration of the RCRA,permit if 11 has
explicit authority allowing it to directly administer
and enforce permits issued by the federal government.
As an alternative, the state can issue a RCRA permit to
the facility. Where the state issues a RCRA permit, EPA
should suggest to the federal permittee that the permittee
should agree to the termination of the federal permit.
The EPA-issued RCRA permit cannot be terminated with-
out the agreement of, the permittee unless one of the
causes for termination in 40 CFR 122.16 is present.

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4) A facility has both a federal RCRA
permit and a state permit
This situation is a combination of cases (2) and (3),
above. The state oust eventually issue a state RCRA
permit to the facility or can assume responsibility to
administer the federal permit if it has the authority
to do so. The schedule for reissuance of the state
n» rmi £ i c tn h» e no r i -f •* mti im tK»	A ««¦»«»««>•»<« «» _
Since the facility has a federal RCRA permit, the urgency
for sT3tt rei ssuance of a stiffe P.CRA perrr.it disir.ishss.
This would be 'especially true if the previous state
pern it was issued using standards and procedures that
were eve-ntaTly authorized.
5) A facility has identical federal RCRA and
state permits that were Issued- jointly
In those situations where both permits are Identical and
were issued jointly, EPA can propose its intent to con-
sider as RCRA permits the jointly-issued or identical
state permits when the Agency announces receipt of the
state's complete Phase II application. In this last
situation, the RCRA permit can be terminated with the
agreement of the permittee (or for one of the causes
for termination in 40 CFR 122.16). If the RCRA permit
is not terminated, then the facility will operate under
two identical permits.
The assumption underlying all of the above scenarios is that
any EPA-issued permit continues in full force and effect after
Phase II authorization. EPA-issued permits continue in
force until terminated either unJer 40 CFR 122.la [see 40
CFR 123.6 (b)(1), 123.126 (c)(1) and 124.5(d)] or by the
agreement of EPA and the permittee. Permittees with EPA-issued
permits thus would be subject to the requirements of 40 CFR
Paxts 122 and 124 until their EPA-issued peraits are terminated.
The permit terms and conditions, as well as the applicable
requirements of Part 122, would be the "requireraent of
this subtitle" (Subtitle C) which EPA could enforce under
Section 3008 of RCRA.
EPA would prefer not to be administering and enforcing federal
permits in authorized states. Thus, it 1s extremely desirable that
EPA and a non-authorized state coordinate their permitting activitii
so that whenever possible they hold joint hearings and issue identi-
cal or nearly identical permits. Then, upon authorization, those
state permits can be considered RCRA penults. Alternatively, it
would be extremely desirable for those states that are currently

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making legislative or regulatory changes to Incorporate in their
legislation (or in their regulations, if their legislative author-
ity is already broad enough to allow it) a provision allowing them
to summarily transform federal RCRA permits into state RCRA permits.
That is, the state would want-to be able, through some very simple
procedure, to issue state RCRA permits i ncorporati ng all the terms
and conditions of the federal permits.
m, m + -m ¦+ m
All facilities that treat, store, or dispose of hazardous
waste can do so legally only under a state or federal RCRA permit,
1 interim status, or a state analogue to interim status.
The only instance where a state permit that was issued prior to
Phase II authorization can constitute a RCRA permit is where the
state permit was Issued jointly with and is identical to a federal
RCRA permit. In such a case, when EPA receives the state's appli-
cation for Phase II, EPA should announce {as part of the Federal
Rec;ister notice of receipt of a complete Phase II application) its
intent to consider the identical, jointly-1ssued state permits to
-be RCRA permits and .take comment on that intention. At the tine of
joint permit processing, EPA should also announce such an Intent
1f the state is one that may seek Phase II interim authorization.
Except for the above situation where joint identical state and
federal permits occurred, all state permits will need to be modified
or reissued by the state as RCRA permits once the state is author-
ized. The schedule for reissuance can be negotiated between the
state and the Region and must be delineated in the Memorandum of
Agreement and described 1n the Program Description. In those cases
where there are previously-issued federal RCRA permits, the state
may possess the authority to assume the administration of those
permits, thereby negatirg the need for issuance of a state RCRA
permit. EPA-i ssued RCRA permits cannot actually be terminated
without the agreement of the permittee unless one of the causes
for termination in 40 CFR 122.16 is present.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1988(15)
JAN 2 I 1988

BMMM
SUBJECT: Headquarter*s Clarification of the Regulatory
Status of Drainage Water Beneath Land Treatment
' Units and Integration of the Region's Permitting
Activities with the "No Migration" Petition Program
FROM: Marcia E. Williams, Director
Office of Solid Waste
TO:	Charles E. Findley. Director
Hazardous Waste Division-Region 10
This memorandum responds to your December 4, 1987,
memorandum in which you raised several issues on permitting of
land treatment units at oil refineries in Region 10.
Your first question was whether ground water which is
seasonally drained from beneath land treatment units
constitutes a hazardous waste. You concluded that the
situation is roughly analogous to situations described in the
1985 policy memorandum clarifying application of the derived
from and mixture rules to petroleum refinery wastewater
treatment systems. Based on that 1985 policy, you concluded
that the drainage water is not a hazardous waste by
definition.
While we agree that ground water pumped from beneath a land
treatment unit is not necessarily hazardous, we do not agree
that ground water contaminated with hazardous waste leachate
from a land treatment unit can be categorically deemed
non-hazardous. The 1985 policy on wastewater treatment systems
does not address releases to ground water. The regulatory
status of contaminated ground water is addressed more directly
in Marcia Williams' memorandum of November 13, 1986, which
states that ground water contaminated with hazardous waste
leachate must be managed as if it were a hazardous waste. This
applies equally to land treatment units and other RCRA units.

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You also questioned whether the drainage water, which is
returned to an NPDES treatment system, must be addressed in a
"no migration" petition. Under the "no migration" standard,
there can he no migration from the unit. If the drainage water
is to be excluded from the "no migration" petition, the
petitioner must demonstrate that the drainage water is not
being contaminated by hazardous constituents migrating from the
land treatment unit. However, for a leachate collection system
that is considered part of the unit (e.g. , it is above a
liner), and where leachate is pumped directly to a wastewater
treatment plant, the leachate would not be considered to be
migrating from the unit. However, any ditches or pipes used to
conduct leachate from a leachate collection system, or runoff
from the unit must meet the "no migration" standard, since
these conduits could be extensions of the unit.
With respect to your suggestion that a Part B land
"treatment demonstration can be used in lieu of a "no migration"
petition covering subsurface transport, we do not believe that
an approved Part B land treatment demonstration can replace a
"no migration" petition. Although it is true that the
subsurface transport demonstrations for the permit and the
petition are very similar, the statutory standard that must be
met for a "no migration" demonstration is more stringent. For
example, "no migration" must be demonstrated for "as long as
the waste remains hazardous," and not just for the permitted
life of the facility. Thus, a "no migration" demonstration may
have to meet a standard for a much longer time than the land
treatment demonstration. In addition, "no migration" must be
demonstrated for all media, including soil, surface water and
air. We realize that much of the information contained in a
Part B application is relevant to "no migration"
demonstrations. Thus, we have been encouraging potential
petitioners to attach a summary of all relevant Part B data
and/or specific sections of the Part B application. We are
planning to work very closely with both the Regions and the
States when reviewing "no migration" petitions, since the
permit writers can offer invaluable technical and historical
information on the site.
In response to your suggestion that a determination made
under a RCRA Facility Investigation (RFI) can replace an
evaluation of air emissions addressed in a "no migration"
petition, we do not believe that such a determination can
automatically substitute for a "no migration" demonstration.
The standard that must be met for no migration from the unit
will likely be more stringent than the demonstration required
under the RFI. We are continuing to evaluate the best way to
handle the air pathway for "no migration" demonstrations, and
propose to use health or environmentally-based exposure levels
at the edge of the unit. For the air pathway, we have not yet
defined what this will be, but one option is that the edge of
the unit be defined as the surface of the waste. In defining
the "no migration" standard the Agency must determine how this
2
^4
-------
standard relates to the section 3004(n) standards which win
control air emissions from treatment, storage, and disposal
facilities as "may be necessary to protect human health and the
environment." Finally, RPI information may not be available at
the time a "no migration" petition is submitted. When it is
available, it will be considered. We are encouraging the use
of all relevant site data in the "no migration" petition,
including information collected for permitting or corrective
action purposes.
In your memorandum you requested that authority to grant
"no migration" petitions be delegated to the Regional
Administrators. We are planning to propose an interpretation
of the "no migration" language in the Federal Register for
public comment. Because of the controversy surrounding the
interpretation of the "no migration" statutory language, and
the potential for changes in policy, we believe that
Headquarters should evaluate the initial set of "no migration"
petitions received. We will consider delegation to the regions
after the program is developed and initial petitions have been
evaluated to assess issues and establish precedent. Therefore,
you should advise facilities to submit petitions to the
Administrator. It would also be advisable to send a copy of
the petitions to the Assistance Branch of the Permits and State
Programs Division, which will have the lead on reviewing the
petitions. We will coordinate individual petition reviews on a
case-by-case basis. The Agency expects to receive relatively
few viable petitions. The petition approval process should not
affect the November 1988 permitting deadline, since petition
approval is not a prerequisite for Part B permit approval.
In addition, you asked Headquarters to have a staff person
devoted primarily to covering land treatment issues for the
Permit Assistance Team (PAT). We understand your concern
regarding the need for technical expertise in this subject
area. Unfortunately, we do not have the resources to assign an
individual to land treatment on a full-time basis. We will
continue to use the technical staff available, and supplement
with contractual support when necessary. If you need
assistance or wish to discuss this, please contact Elizabeth
Cotsworth on (FTS) 382-4206.
For further clarification on these issues, please contact
Stephen Weil at (FTS) 382-4770.
3 u|Ct4
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UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
9551.1990(04)
Mr. Joseph J. Zimmerman
Sachs & Taylor
1140 Connecticut Avenue, N.W.
Washington, D.C. 20036-4002
Dear Mr. Zimmerman:
Thank you for your recent correspondence dated August 20,
1990 concerning the prohibitions on land disposal of untreated
hazardous waste and the prospect of a "no migration" variance for
your client, Giant Industries Arizona, Inc. (Giant).
In that letter, you correctly stated that the land disposal
prohibitions become effective for refinery hazardous wastes
(K048-K052) on November 8, 1990, after being extended from the
original effective date of August 8, 1990. You also correctly
reiterated EPA's advisory that the processing of "no migration"_
petitions, from the date of receipt by EPA, through internal *
review, notification of any petition deficiencies, statutorily $
mandated publication of a proposed decision in the Federal 1
Register. and public comments, to publication of the final
decision in the Federal Register, is likely to take approximately
12-18 months. (EPA records indicate that Mr. Jim Michael of my
staff discussed this issue with Mr. John Stokes of Giant in a
December 13, 1989 telephone conversation.) Finally, your
correspondence refers to EPA's policy, where a national lack of
BOAT treatment, recovery, or disposal capacity can be
demonstrated, for granting a one-year, case-by-case extension to
the land disposal prohibition effective date, for provision of
alternative protective treatment, recovery, or disposal. (See 40
CFR 268.5.) However, you should be aware that the statutory
provisions under RCRA Section 3004(h)(3) require that the
applicant make several demonstrations, among them that a binding
< "contractual commitment has been made to construct or otherwise
provide alternative treatment, recovery, or disposal capacity
that protects human health and the environment. In order to
address this requirement, the Agency has indicated that this
provision may be satisfied by a Federal Register notice wherein
the Agency proposes to grant either a "no migration" or a
treatability variance. (See 55 £R 22673-4, June 1, 1990.) The
Agency believes that once we have proposed to grant either a
treatability or "no migration" petition, the petitioner has made
a good faith effort to commit to obtaining alternative protective
	 0l" 3 ©go
jj O.-j;
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2
disposal capacity. In addition, the Agency's action in proposing
to grant the petition serves as a preliminary determination that
the disposal unit is protective; the mere filing of a
treatability or "no migration" petition provides no such
indication of protectiveness and thus, cannot be deemed to
satisfy the statutory requirement.
However, contrary to statements in your letter, regulations
and draft guidance on the content and evaluation criteria for "no
migration" petitions are currently available to the public, and
have been for some time. Regulations currently exist at 40 CFR
268.6 describing the requirements for petitioning EPA to receive
a "no migration" variance. These regulations were promulgated
on November 7, 1986, and June 4, 1987, and since have been
amended on July 8, 1987 and August 17, 1988. EPA also antici-
pates proposal of another "no migration" rule in 1990 that would
further define "no migration" and would create new procedural and
substantive petition requirements. Furthermore, a draft guidance
document entitled "No Migration Variances to the Hazardous Waste
land Disposal Prohibitions: A Guidance Manual for Petitioners"
has been available to the public upon request during the past two
years. It also is available from the National Technical Informa-
tion Service (NTIS, telephone number 703-487-4650), document
number PB90204736. EPA records indicate that Mr. Michael of my
staff responded to a January 16, 1990 request from Ms. Kim
Bullerdick of Giant for a copy of this draft guidance. A copy
of the latest draft of this guidance, dated March 1990, also is
attached for your convenience.
EPA recognizes the situation land disposers face as the
land disposal prohibitions become effective. However, the
prohibition of land disposal of K048-K052 hazardous wastes
prevents the continued land disposal of these wastes past
November 8, 1990. Land disposal is prohibited until the "no
-migration" variance has received final approval.
Although a "no migration" variance could be granted to Giant
after November 8, 1990, Giant is advised to be actively arranging
for other treatment or disposal after November 8, 1990. Should
Giant decide to petition EPA for a "no migration" variance, that
petition should be submitted to: U.S. Environmental Protection
Agency, Permits and State Programs Division, 401 M Street S.W.,
Washington, D.C. 20460. As Mr. Michael discussed previously with
Mr. Stokes of Giant, EPA strongly recommends that potential
petitioners meet with the Agency prior to development and submit-
tal of "no migration" petitions. You may contact Mr. Michael of

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3
my staff at 202-382-2231 to arrange such a meeting, or if you
have specific questions concerning the "no migration" petition
process.
Sincerely,
\*l
Sylvia K. Lovrance, Director
Office of Solid Haste
Attachment

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9551.1990(05)
OCT 91990
MEMORANDUM
SUBJECT: Replacement of Contaminated Soil and Debris
Treated under a Treatability Variance
FROM:	Sylvia K, Lowrance, Director
Office of Solid Waste
TO:
David Ullrich, Acting Director
Waste Management Division, Region V
This memorandum is in response to your correspondence of
April 25, 1990, in which you requested guidance in relation to six
specific questions dealing generally with how the RCRA land
disposal restrictions may affect certain remedial situations. We
offer the fpllowing response to those six questions:
1. Q: Can soil and debris which has been treated in a tank
within the area of contamination (AOC) in accordance
with a treatability variance be replaced within the area
of contamination without meeting any additional 40 CFR
Fart 264 requirements?
A: If contaminated soil and debris is treated to meet
standards specified in a treatability variance that has
been approved by the Agency, the treated soil/debris may
then be placed in any treatment, storage or disposal
unit that is in compliance with RCRA Subtitle C. This
could include an "area of contamination" (i.e., a RCRA
landfill) that has been designated by the Regional
Administrator for the purpose of remediating the
facility or site. Thus, as a regulatory matter, there
would be no real distinction between soil/debris that is
treated to the standard(s) set in the treatability
variance and then placed in another unit, as opposed to
"pure" hazardous wastes that are treated to the
applicable Part 268 standards, and placed in another
unit, except as discussed in the response to Question *5
(concerning contaminated media which no longer contains
any waste) .
By^feating in your question that the treated wastes
are to'redeposited into the AOC, we assume there is an
implied question as to what design and operating

-------
implied question as to what design and operating
standards would then be applicable to the AOC itself.
This is discussed in our response to question #6, below.
Has the policy set forth on Page 5.12 of the document
TrrolPtnpnt.ino t:hp Land Disposal Besf.rier.ions. October
1989, been revised?
This policy has not been revised. The policy states
that once an owner/operator receives a treatability
variance, completes treatment, and has a treatment
residual to be land disposed, the residue can be
directed to any permitted or interim status unit.
For the purpose of land disposal, is the residue of soil
treated under a treatability variance to be
distinguished from the residue of waste treated
according to treatment standards?
No. See response to Question 1, above.
For the purpose of land disposal, is the residue of soil
treated under a treatability variance in a tank within
the area of contamination to be distinguished from the
residue of soil treated under a treatability variance in
a tank outside of the area of contamination?
No. The location of the tank in relation to the "area
of contamination" would not create a distinction as to
how or where the treatment residuals could be land
disposed. This assumes, of course, that the wastes have
been treated to the standards specified in the
treatability variance. A tank cannot be considered a
part of the AOC (landfill), regardless of where it is
physically located; thus, its location would have no
bearing on the standards that would apply to management
of the contaminated soils (or other hazardous wastes,
for that matter) after they have been treated in the
tank.
Is a treatability variance for soil and debris to be
considered in effect a delisting? Do the principles of
the "contained in" policy for the treatment of
contaminated ground water have any applicability to the
treatment of contaminated soil and debris?
A treatability variance for soil/debris does not have
the effect of a delisting approved for the waste. The
treated residuals typically will still contain hazardous
wastes, and thus must be managed as such. In contrast,
when wastes are delisted they are generally no longer
subject to .Subtitle C regulation.
The "contained in" policy applies to ground water
/-s /"\
-------
and other contaminated media such as soil which are
contaminated with listed hazardous wastes. Thus, if
ground water or soil are treated such that
concentrations of the listed wastes are at or below
health based levels, the ground water or soil
would no longer "contain" the hazardous wastes, and
would therefore be no longer subject to Subtitle C
regulation. Enclosed is a recent memorandum which
provides a more detailed explanation of the contained-in
policy.
Q: If an AOC can be considered a RCRA unit for the purpose
of closure, would an AOC ever be considered equivalent
to a RCRA compliant unit for the purpose of disposal?
(See page 6 of OSWER Directive 9234.2-04FS RfRft
Toeus on rinsurP	i rpmont g . 1
A: As outlined in the cited ARARs manual, the AOC is a
concept which can be applied in the context of
remediation under CERCLA response actions or RCRA
corrective actions. It is in many ways analogous to
situations where two or more regulated surface
impoundments would be treated as one unit in the context
of closure of the impoundments.
When applied in the context of RCRA corrective
actions or CERCLA remedial actions, the AOC concept
would allow the Regional Administrator to designate a
broadly contaminated contiguous area to be a RCRA "unit"
(i.e., a landfill) for the purpose of implementing the
remedy. In an existing landfill, the movement or
consolidation of hazardous wastes within the
designated area would not by itself trigger Subtitle C
requirements (including the land disposal restrictions
and the RCRA minimum technology requirements) since that
movement or consolidation does not constitute
"disposal" for Subtitle C purposes. If, however, wastes
are excavated from the designated area, treated in
another unit, and subsequently redeposited into the same
area or unit# disposal has occurred, and the landfill
would have to comply with applicable Part 264 or 265
requirements,including the LDRs, MTRs, closure standards
(264.310), and the ground water monitoring requirements
of Subpart F, Part 264 or 265.
The proposed Subpart S corrective action rule
esqjlains the AOC (described therein as the "corrective
action management unit") concept in more detail.
However, if you have more specific questions or issues
regarding AOCs, we will be glad to work with you or your
staff to resolve them.
If there are any questions on the above responses to your
5D!
-------
questions, please contact Dave Fagan (FTS 382-44 97) or Judy
Goldberg (FTS 382-4534).
Enclosure
cc: Regional RCRA Branch Chiefs
PSPD Branch Chiefs

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9551.1990(06)
OCT I 4 1990
;t%is
BMSHM
SUBJECTS Guidance from Headquarters to Help Determine Possible
Violation of the Land Dispo^fcl Restrictions
FROM: Jeffery D. Denit, Deguty
Office of Solid Waste
TO;	Bruce ^5mith, Director 'J
Office of Hazardous Waste Programs (3HW03)
Region 111
This memorandum is written in response to your request for
assistance from EPA Headquarters in making a Land Disposal
Restrictions (LDR) determination for the Rhone-Poulenc facility
located in Institute, West Virginia. As stated in your
August 17, 1990, memorandum, Region III is concerned that the
facility may be impermissibly diluting several vaste streams
subject to the LDR requirements. The restricted wastes of
concern are: (1) F039 multi-source leachate wastewater streams
from the Goff Mountain RCRA Landfill, from the site of Union
Carbide's Private Trucking Operation, and from recovery well
(RW-l); and (2) U025 dichloroethyl ether "chlorex" from the RW-1
well. The characterization data provided by Rhone-Poulenc show
the F039 wastewaters as generated (prior to mixing) exceed both
organic and metal LDR treatment standards, and U025 wastewaters
as generated exceed the LDR treatment standard for dichloroethyl
ether.
As described by Rhone-Poulenc in the document entitled
"Treatment of Multisource Leachate in Rhone-Poulenc's Institute,
West Virginia WWTU" submitted to EPA Region III on June 14, 1990,
the treatment system consists of primary treatment (e.g., mixing,
equalization, emergency diversion, neutralization and
clarification) in tanks and secondary treatment (biotreatment and
clarification) in surface impoundments. Before entering the
primary treatment tanks, approximately 15,000 gallons per day
(GPD) of F039 and U025 wastewaters subject to the LDR are mixed
with approximately 4.5 million GPD of process water not subject
to the LDR. The resultant wastewater mixture apparently meets
the LDR levels for F039 and U025 wastewaters before entering the
secondary treatment system. Rhone-Poulenc did not analyze for
all regulated constituents or properly justify the selected
constituents.
-------
We believe that the facility may be violating the dilution
prohibition. They have not provided evidence supporting that
legitimate treatment for LDR organic or metal constituents is
occurring in their treatment system. We also believe that the
facility may be in violation of land disposing nonwastewaters
that exceed the U025 treatment standards because the facility
appears to have interpreted a portion of the LOR requirements for
nonwastewaters incorrectly. Our analysis is summarized below.
Possible LDR Dilution Prohibition Violation
Rhone-Poulenc argues that its system consists of an initial
aggregation point which equalizes wastes, followed by legitimate
centralized treatment in section 3005(j)(3) aggressive biological
treatment impoundment. (Chambers letter, pp. 4-5.) He discuss
this argument below with respect to organic and metal
contaminants.
Organics
The Agency's discussion of this issue appears at 55 FR
22666. In general, we determined that initial aggregation of
similar wastes followed by legitimate centralized treatment may
be permissable (i.e., may not constitute impermissible dilution),
even if treatment occurs in a surface impoundment or other land
disposal unit (provided, of course, that the waste meets the
treatment standard before land disposal occurs, or that disposal
occurs in a section 3005(j)(ll) impoundment). (Thus, the issue
of treatment of organics in aggregation tanks is not relevant.)
In determining what constitutes legitimate centralized treatment,
we indicated that the clearest indication was use of the same
type of treatment as that on which the treatment standard for the
prohibited waste is based. Id. col. 2. While biological
treatment was one of the treatment technologies relied upon by
the Agency in establishing treatment standards for multi-source
leachate, it is not the only treatment and is clearly not
appropriate for all F039 constituents. (See Background Documents
on BOAT for F039.) In addition, combination of leachate
' "" containing organics with process wastewater containing organics
for biological treatment could be permissible aggregation,
because it appears that the facility could be combining different
wastes amenable to the same type of treatment technology. Id.
col. 1. Before a final assessment could be made, Rhone Poulenc
would need to submit characterization data demonstrating
similarities in gpppgsjtion between leachate and process
wastewaters (e.g., indicating biodegradable constituents at
approximately the same concentration levels). A demonstration
would also be needed indicating that the treatment impoundment is
capable of treating toxic organics in the commingled wastewaters,
i.e., that levels of these toxic organics are not so low as to go
untreated in the Rhone Poulenc impoundment. Absent such a
showing, EPA could not conclude that the impoundment is
legitimately treating the organics in the prohibited wastes.
5oH
-------
Assuming that the leachate is commingled with similar plant
wastewaters and that biodegradation is the appropriate treatment
for all of the F039 organics and for the plant wastewaters, the
treatment of organics would be permissible.
Petals
It appears that Rhone-Poulenc is impermissibly diluting
metals in its system. The same analysis used for organics would
indicate that biological treatment is inappropriate for metals
(1&*. col. 1-2 ("An example of a type of treatment that is
inappropriate for treatment of certain prohibited wastes would be
biological treatment standards for metals. In these systems,
metal removal is incidental and nowhere as efficient as systems
designed to treat metals...")). The initial aggregation step, in
which metals are removed by settling, likewise probably does not
constitute proper treatment of metals. As Rhone-Poulenc states,
it is an aggregation step, not a treatment step; it achieves a
homogenous mixture that allows optimization of biological
treatment of organics. Adequate treatment of metals vould
require chemical precipitation or some other type of comparable
treatment. (See Background Documents on BDAT for F039.) At the
least, Rhone-Poulenc has not yet demonstrated that it can meet
the F039 wastewater metals standards by use of primary treatment
(i.e., settling in tanks for short periods of time).
Consequently, Rhone-Poulenc is taking a prohibited waste
with treatment standards for metals, which does not meet those
treatment standards as generated, mixing it with a large volume
of wastewater, and introducing it to a system that does not
provide anything more than incidental removal of metals. This
appears to constitute impermissible dilution. Id. at 22666 col.
1-2. (Rhone-Poulenc1s argument that the leachate does not differ
significantly from its process wastewater which is only treated
by biological treatment does not prove anything; it may be that
Rhone-Poulenc is not adequately treating the metals in its
process wastewater either. The key here is that there are metal
standards for multi-source leachate, Rhone-Poulenc1s leachate as
generated does not meet those standards, and the leachate only
meets those standards after it is mixed in a treatment system
that at no point does proper treatment for metals.)
Rhone-Poulenc submitted influent and effluent data from a
lab-scale model in an attempt to demonstrate the applicability
and treatment performance of the primary treatment system. The
data submitted show only some reduction for a fev regulated
organic constituents and no data is provided to demonstrate
removal rates for any metal constituents. While the final
determination on a case-specific dilution issue should generally
be made by the Region (or State), you should be aware of our
concerns with these data submitted by Rhone-Poulenc. (In many
-------
instances, our concerns are similar to those presented in a
memorandum from Region III to Rhone-Poulenc on July 30, 1990.)
The facility incorrectly labels their lab-scale experiment as a
more stringent test criteria than that required by the Agency to
demonstrate treatment performance and refers to the November 1989
proposal for the Third-Third rule. EPA proposed to require a
reduction of at least one BDAT list constituent at the point of
aggregation to demonstrate that the aggregation did not
constitute impermissible dilution (54 48372, 48494-48496).
The reason the Agency did not finalize this criteria is because
it was not stringent enough to provide the adequate information
needed to make a reliable determination of legitimate treatment
(55 IB 22665).
He believe that the lab-scale data are inadequate to
demonstrate that appropriate treatment for F039 and U025
wastewaters is achieved before disposal into the surface
impoundments. Not only should data from the actual full-scale
treatment system be used to make a demonstration of treatment
performance, but it should include removal rates for all
regulated constituents determined to be present in the wastes.
(For F039, the regulated constituents include over 200
constituents, regardless of the original constituent listings of
wastes disposed in the landfill and surface impoundments.) Based
on our experience, the type of treatment used by Rhone-Poulenc
will likely not provide removal rates comparable to the levels
otherwise needed to legitimately treat the metals present in the
F039 wastes to BDAT levels; consequently, it appears the facility
is diluting metals impermissibly to achieve the LDR levels for
F039 wastewaters.
Possible Nonwastewater LDR Violation
It also appears that Rhone-Poulenc is in violation of
various standards for nonwastewaters. First, with respect to the
sludge derived from treating F039 wastewaters, the sludge
received a two-year national capacity variance and consequently
can only be disposed of in a minimum technology surface
, - impoundment during that period or must comply with F039
nonwastewater standards. See Section 268.35(h). Section
3005(j) (3) impoundments do not meet the minimum technology
requirement provisions unless they have received one of the
section 3004(o)(2) or (3) waivers. See 53 FR 31185-186 (August
17, 1988) ("although many commenters stated that the retrofit
waivers granted under 3005(j)(3) ... should also be recognized
under the land disposal restrictions, the Agency disagrees. EPA
believes that Congress would have included these waivers had it
intended to do so.n) Thus, absence compliance with a waiver from
minimum technology requirements (the section 3004(o)(2) waivers
are codified in 264.221(d) and (e) and 265.221(c) and (d)), the
sludge cannot be placed in the surface impoundment.
With respect to the treatment standard for U025, the
standard must be met before land disposal of the waste. API v.

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EPA, 906 F. 2d 729, 735-36 (D.C. Cir. 1990). Consequently, the
sludge in the impoundment must meet the nonwastewater U025
standard. In addition, further placement of the sludge in the
Goff landfill is acceptable only if that landfill is a subtitle C
unit (and the sludge would have to meet the U025 treatment
standards before that land disposal as well).
Should you require additional information, please contact me
at FTS 382-4627 or Richard Kinch at FTS 382-7917.
Attachments
50 "J
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9551.1990(07)
OCT I 4 1990
Mr. 6. A. Vogt, Manager
Environmental Compliance & Plant Services
Thompson Consumer Electronics, Inc.
P.O. Box 2001
Marion, Indiana 46953-4399
Dear Mr. Vogt:
This letter is in response to your July 10, 1990, letter
regarding clarification of the national capacity variance for
inorganic solids debris under EPA's Land Disposal Restriction
Regulations for Third Third Wastes. In general, your letter
questioned the scope of the definition of inorganic solids debris
as well as its application. The delay in responding to your
letter results from the myriad related questions that the Agency
has received concerning these issues. The Agency can now offer
the following clarifications for your situations
For the purposes of determining the applicability of the
capacity variance extension, the waste in question must only be
specified as a D004, D005, D006, D007, D008, D009, D010, or DO11
waste and must meet all the criteria listed in the definition of
inorganic solids debris in 268.2(g). (See 55 £B 22686 (June 1,
1990).) It must also exactly fit one of the eight specific
categories of inorganic solids debris listed in 268.2(g)(l)-(8}.
While some wastes may appear to fall under one of these
categories (e.g., 268.2(g)(6) and (7) include wastes identified
" as containers, drums, pipes, valves, appliances, or industrial
equipment), they must first meet the criteria in the preceding
portion of the definition that clearly indicates that these
wastes must be inorganic or metal materials. In the June 1, 1990
rule, the Agency also gave specific examples of organic solids
debris (55 22555) in order to help clarify the classification
of a waste as organic versus inorganic. These examples of
organic debris included: rags, paper, cardboard, clothes, gloves,
paints, paint chips, wood, grubbing materials, blankets, hoses,
bags, resins, plastic liners, and FVC piping. (Please see also
the discussion of inseparable mixtures of inorganic and organic
debris later in this letter.)
In response to your question on metal-contaminated cloth
filters, they would be classified as organic solids debris
because cloth is typically comprised of organic materials. EPA
5:- i
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2
has granted a national capacity variance for soil and debris for
which the underlying standard (i.e., waste code-specific
standard) is based on incineration, vitrification (D004 arsenic
wastes), or mercury retorting (DO09 mercury wastes with greater
than 250 mg/kg total mercury). While the underlying standards
for most D004—D011 metal wastes were generally based on
stabilization rattier than incineration, the Agency did state, at
55 II 22555 (June 1, 1990), "as a matter of treatment policy
prohibited metal wastes that are generated as an organo-metallic
or in an organic matrix can be incinerated ... , prior to
subsequent treatment of the ash (if necessary), in order to
comply with a concentration-based standard or to comply with a
technology-based metal treatment standard." and that "... much of
the DO04—DO 11 organic debris may be treatable by washing or
extraction rather than incineration." Thus, only organic solids
debris that must be treated by incineration, vitrification, or
mercury retorting in order to comply with the metal standards,
received a variance. If the metal-contaminated cloth filters
cannot be decontaminated to below the appropriate treatment
levels by washing or extraction with acids (or other appropriate
media) and would therefore have to be incinerated, they are
subject to the national capacity variance.
During a follow-up telephone conversation with my staff, you
also indicated that one of the wastes on which you were seeking
guidance consists of broken color picture tubes made primarily of
glass. While EPA has specifically identified glass as one of the
specific types of inorganic debris according to 268.2 (g)(3), one
needs to evaluate the applicability of the rest of the definition
of inorganic solids debris. One must first determine if the
waste is friable (i.e., easily or readily crumbled). Although
broken color picture tubes would be expected to be somewhat
friable, one must also determine whether the subsequent pieces
pass the 9.5 ma sieve size. Based on your remarks, we assume
that at least some of the waste (either "as generated" or the
friable residues) will indeed pass through, but not all. Also,
additional small pieces from other similar friable materials may
be generated during transportation and handling (i.e., more
pieces may be generated that would pass through a 9.5 ma sieve).
Thus, the questions become "When does one apply the standard?"
and "Is there a percentage of the waste that must not pass
through the sieve in order to be classified as an inorganic
solids debris?"
In responding to this question, one must examine the
Agency's intent in promulgating the variance. The key to the
variance is that wastes in the inorganic solid debris categories
would have to be crushed or "otherwise reduced In size" prior to
stabilization (55 IB 22556). The Agency had determined, that „
there was inadequate capacity for "cutting, or crushing and
grinding in mechanical sizing equipment" for these wastes. Thus,
it is the link between the type of inorganic solids debris and
£0^
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the sizing equipment required as pretreatment (i.e., prior to the
stabilization process) that was the key factor in determining the
need for the capacity variance.
As a result, the Agency has determined that the point of
generation is where the waste is identified as inorganic solid
debris for purposes of the national capacity variance. If any of
the vaste material does not completely pass through a 9.5 as
sieve, then the entire quantity of waste material qualifies as
inorganic solid debris. In addition, if the vaste material is
friable (i.e., easily crumbled) but some of the pieces will not
pass through a 9.5 mm sieve, then the entire quantity of vaste
material is considered to be inorganic solid debris. Therefore,
any debris that may fall through a 9.5 mm sieve because of
transporting from the generator's site to the disposal site is
also considered to be inorganic solid debris that is subject to
the national capacity variance.
Wastes appearing to meet the definition of inorganic solids
debris under section 268.2(g)(6) (metal cans, containers, drums,
or tanks) and (7) (metal nuts, bolts, pipes, pumps, valves,
appliances, or industrial equipment) often contain organic parts
that are difficult to separate. This occurs particularly in
cases such as: 1) industrial process equipment being dismantled;
2) industrial valves comprised of composites of organic and
inorganic materials; and 3) appliances containing multiple
connected parts. Capacity for sizing and separation is also
lacking for this type of inorganic solid debris (which was the
basis of the variance is also applicable for this type of
inorganic solids debris. Thus the variance for inorganic solids
debris will apply to these inseparable mixtures except in
situations where during the dismantling, the organic materials or
a significant portion of the organic materials are manually
separable or separable by simple mechanical means. The separated
organic materials must then be treated for their metals content
and thus comply with the applicable treatment standards for DO04
— DO11 (except as noted above). Only the inorganic solids
debris that are separated from the nonhazardous organics are
subject to the national capacity variance.
I hope this letter addresses your major concerns. If you
have any further questions, please call Richard Kinch, Chief of
the Waste Treatment Branch, at (202). 382-7927.
Sylvia K. Lowrance
Director
Office of Solid Waste
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1990(08)
OCT 24 1990
Mr. Fielding Formvay
ARCO Products Company
Post Office Box 1127
Femdale, Washington 9824S
Re: No-Migration Petition submitted for ARCO Products Company's
Femdale, Washington Land Treatment Facility (F-90-NCPP-
FFFFF)
Dear Mr. Formway:
I am writing in regard to your September 5, 1989 "no-
migration" petition, which requests a variance under 40 CFR
§268.6 to allow ARCO Products Company (ARCO) to continue the land
treatment of restricted wastes (EPA Hazardous Waste Nos. K050 and
K051) at ARCO's Femdale, Washington Land Treatment Facility
No. 7 (LTF-7). After a careful review of your petition, we have
concluded that your facility does not meet the standard for a no-
migration finding. Therefore, we will recommend to the Assistant
Administrator for Solid Waste and Emergency Response that the
petition be denied.
Our decision to recommend denial of the petition is based on
several concerns:
The ground-water monitoring system is inadequate for the
purpose of a no-migration variance, because it will not
detect migration at the earliest time.
The separation between the bottom of the treatment unit and
the top of the seasonally high-water table exceeds the
minimum requirement.
Unsaturated zone monitoring for benzene, chrysene, and
selenium indicate that hazardous constituents have already
migrated beyond the unit boundary, and are likely to
continue to do so in the future.
Your air modeling shows concentrations of benzene at the
unit boundary that exceed the allowable health-based
standard.
The details of our concerns are described below.
Sit
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Ground-Water Monitoring System
We have concluded that ARCO has failed to meet the
requirements of 40 CFR 5268.6(a)(3) and (4). Specifically, we
believe that ARCO has not adequately determined background
conditions in both the ground water and soil-pore water
underlying LTF-7. First, ARCO proposed well AW-45 as an
upgradient well and wells AW-47, 48, 49, and 50 as downgradient
wells. ARCO notes elsewhere in the petition, however, that
because of the transient nature of the water table, wells 45 and
63 are considered downgradient as well as upgradient (V.l, page
5-30 and Section 6.6). We conclude, therefore, that ARCO's
ground-water monitoring system at LTF-7 does not have an
upgradient monitoring well that is capable of consistently
providing samples of ground water unaffected by the treatment
unit.
Second, we question whether ARCO can collect samples of
soil-pore water which are representative of background
conditions, as required by 40 CFR 5264.278(b)(1). Specifically,
ground-water contours shown in Figure 3-7 of the petition
indicate a ground-water divide trending generally to the west
across Plot-7C. Although ground water is shown to flow generally
to the northwest under LTF-7, the presence of the ground-water
divide, as well as the southwesterly ground-water flow shown for
LTF-45 and LTF-47, indicate that ground water may flow to the
southwest from LTF-7 to the background plot and, thus, to the
background lysimeters located south of the southwest corner of
Plot—7C, (Figure 5-1 on page 5-14). (This means that one of the
background lysimeters may be downgradient of LTF-7.) We are
concerned that this flow pattern may be present since only the
general direction of ground-water flow is shown (e.g., an annual
average) and not its seasonal patterns. If ground water
periodically flows from LTF-7 to the background lysimeters for
" Plot—7C, soil-pore water samples taken from these lysimeters
could not be reliably used to establish background
concentrations.
Maintaining Minimum Separation
Federal regulations require that the depth to ground water
at land treatment facilities should be no less than three feet
from the bottom of the treatment zone to the seasonal high water
table (see 40 CFR 51264.271(c)(2)). As ARCO acknowledged in its
petition (V.l, page 3-12), the ground water beneath LTF-7
sometimes rises to a level that is within the lower treatment
zone of LTF-7 (i.e., above a depth of five feet) due to the low
permeability of the subsoil and the area • s humid climate. Figure
3-8 of the petition displays the results of bi-weekly readings of
water levels in three sets of paired, shallow piezometers
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conducted from July 1988 to April 1989. These data show that
ground water was present during this period at depths in the
treatment zone as high as 2.8 feet below the ground surface and
that, in general, ground water was present at depths at or above
five feet below the ground surface between November and April of
the sampling period.
ARCO's inability to maintain the minimum separation between
the bottom of the treatment zone and the top of the seasonally
high ground-water table is further supported by information
presented in Table E-4 of ARCO's petition. Our evaluation of the
data presented in Table £-4 revealed that between January and
April 1987, ground water beneath LTF-7 was measured at depths
ranging from 0.89 to 6.1 feet below "top of casing." Although,
ARCO did not provide information on the distance between the
ground surface and the "top of casing," typical distances from
the ground surface to the top of the well casing are generally
between one and three feet.1 Thus, even if the distance between
the ground surface and the "top of casing" was three feet, the
water table would only have been 3.89 to 9.1 feet below the
around surface during the January - April 1987 period.
Presence of Constituents Below the Treatment Zone fBTZI
Various data indicate that migration of hazardous
constituents below the treatment unit has recently occurred. The
petition noted (V.l, page 5-18), that chrysene was detected in
ground-water monitoring well No. 43 in January, 1988 at 3.3 ppb,
which is in excess of the health-based level (HBL) of 0.2 ppb
used in no-migration decisions. Furthermore, correspondence
between ARCO and Washington Department of Ecology (WDOE)
(November 6, 1989 and January 24, 1990) that has been shared with
us indicates that benzene, chrysene, and selenium have also been
detected in soil-pore liquids beneath the treatment zone at
-• hazardous concentrations. He present these data below in
Table 1.
1 Table 1-5 of Appendix A presents for monitoring wells
other than those listed on Table E-4, elevation measurements made
at the top of casing and surface grade. These data indicate that
the distance between the ground surface and the top of the well
casing ranged from a low of 0.59 feet (well number AP-46) to a
high of 2.15 feet (well number AP-64).
11
o
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TABLE 1
Soil-Pore Liquids Monitoring Data
Constituents Lysimeter No. HBL(ppb) Concentration(ppb) Date
Benzene
22
5
6.4
7.4
10.0
8/89
9/89
12/89 1/
Chrysene
Composite 2J
0.2
1.4
9/88
Selenium
Composite 2/
10
H
Jt-
•
O
2/87
1/ Composite sample (Based on page 1-5 of ARCO's January
24, 1990 letter to Mr. Richard A. Burkhalter, Washington
Department of Ecology).
2J Composite sample containing samples collected from
lysimeter numbers 21GB, 22GB, and 23GB.
1/ Composite sample containing samples collected from
lysimeter numbers 2IPC, 22PC, and 23PC.
As shovn above in Table 1, benzene, chrysene, and selenium
have migrated past the unit boundary at concentrations in excess
of the HBL used in no-migration petition decision-making. We
note that concentrations of the above constituents may actually
have been detected at an individual lysimeter at concentrations
higher than those reported, due to the averaging effect obtained
from compositing the lysimeter samples.
ARCO's January 24, 1990 letter also stated that toluene,
ethylbenzene, and xylene were detected in lysimeters, which
"indicates a problem with the current operating practices for
landfarm Plot-7B." ARCO indicates that hairline fractures in the
clay may be aiding contaminant transport from Plot-7B (Attachment
page 1-4} but also suggests that these hairline fractures are a
local phenomenon because similar lithology vas not detected in
other borings. Because the petition states that fractures in the
clay are a source of recharge for the underlying ground vater, ve
conclude that future migration will continue to occur. ARCO
believes it can address this concern by decreasing waste loadings
made to Plot-7B. If this leads to am increase in waste loadings
made to Plots-7C and 7A, we are concerned that this increase may
cause additional migration.
lastly, data presented in Table 5-8 of the petition, show
that chrysene was detected below the treatment zone at
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concentrations of 130 ppb for separate sampling periods in July,
1987 and January, 1988. We do not believe that ARCO can explain
the presence of chrysene as resulting from a recent, one-time
overapplication and the recurring presence of chrysene beneath
the treatment unit at concentrations in excess of the health-
based level of 55 ppb is a further basis for petition denial. The
presence of chrysene beneath the treatment zone, will also
obscure future determinations of whether chrysene is continuing
to migrate.
Air Monitoring
In its petition, ARCO stated that the CHEKDAT6 model
predicted concentrations of benzene at the unit boundary in
excess of the health-based standard by a factor of 1.4;
therefore, ARCO is "exploring waste minimization, pretreataent,
and operation modifications which can effectively reduce the
predicted emissions for benzene to meet appropriate standards if
necessary" (V.l, Executive Summary, pages 6-7). In fact, the
petition indicates (V.l, page 8-12) that the predicted annual
average concentration of benzene in the air at the unit boundary
is 1.0 ug/m , which exceeds the health-based level of 0.12 ug/m
Elsewhere in the petition (V.l, page 7-11), the average
concentration of benzene in the air at the unit boundary is
reported as 1.56 ug/m (including a May 1985 waste sampling
event), which also exceeds the health-based level. Therefore,
ARCO's predicted benzene concentrations (1.0 ug/m ) at the unit
boundary fail to satisfy the no-migration standard of 0.12
ug/m3.2
Finally, our review indicates that the petition is
incomplete and that information and clarification in areas beyond
those highlighted above, would be needed to complete the
petition. However, because of the problems above, we believe we
have enough information at this time to move toward a denial of
your petition.
It is our practice to give petitioners the option of
2 Based on our review of Tables E-24 through E-27, it
appears that the values of predicted maximum long-term ambient
air concentrations in Table 7-3 were not corrected based on the
results of the confirmatory monitoring program discussed in
Appendix E. If corrected for monitored concentrations, the
predicted concentrations of benzene at the unit boundary actually
may be higher than reported in the petition. In addition, it is
likely that ARCO*s confirmatory monitoring program may not have
been performed during worst-case emission and dispersion
conditions. As a result, the concentration of benzene may
actually be higher than measured and an even higher correction
factor may be warranted.
r \ I
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6—
withdrawing their petitions to avoid a negative publication in
the Federal Eesis^SE. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions scheduled
to be effective November 8, 1990. This letter should be
forwarded to the following address within two weeks of the date
of receipt of today's correspondence:
Elizabeth A. Cotsworth, Chief
Assistance Branch (OS-343)
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
If you choose not to withdraw your petition, we will
recomend that a proposed denial decision be published in the
Festera! Register.
Any questions regarding our findings nay be submitted in
writing to Mr. James Michael of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
cc: Michael Gearheard, Region X
Carrie Sikorski, Region X
Dave Bartus, Region X
Kim Anderson, WDOE
Elizabeth Cotsworth, EPA HQ
James Michael, EPA HQ
Terry Keidan, EPA HQ
S):J>
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•7-
bcc: Newman Smith, AB, PSPD, OSW
Dave Reeves, HMD, OSW
Richard Kinch, WMD, OSW
Kathy Stein, GE
Wanda Levine, WMD, OSW
Howard Finkel, ICF Incorporated
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NOV E I39Q
9551.1990(09)
Mr. David R. Saad
Environmental Coordinator
Marathon Petroleum Company
Marathon Avenue
Robinson, Illinois 62454
Re; No-Migration Petition submitted for Marathon Petroleum
Company's Robinson, Illinois Land Treatment Facility and
Storage Surface Impoundments (F-9O-NMFP-FFFFF)
Dear Mr. Saad:
I am writing in regard to your December 5, 1989 "no-
migration" petition, which requests a variance under 40 CFR
§268.6 to allow Marathon Petroleum Company (Marathon) to continue
the land treatment and storage of restricted wastes (EPA
Hazardous Waste Nos. K048 - K052) at Marathon's Robinson,
Illinois land treatment facility (I*TF) and storage surface
impoundments. After a careful review of your petition, we have
concluded that your facility does not meet the standard for a no-
migration finding. Therefore, we will recommend to the Assistant
Administrator for Solid Waste and Emergency Response that the
petition be denied.
Our decision to recommend denial of the petition regarding
the land treatment facility is based on several concerns:
•	Ground water and unsaturated zone monitoring data
indicate that hazardous constituents have already
migrated beyond the unit boundaries.
The ground-water monitoring system for the land
treatment facility is inadequate for the purpose
of a no-migration variance because it will not
detect migration at the earliest practicable time
due to the presence of hazardous constituents
beneath the land treatment units.
*	The separation between the bottom of the land
treatment unit an^oteawfcftls ot the seasonally high
water tfebl*>e*ce£cis the minimum rejjuxrementjs.
J Reproduced from	^; %
[ besf available copy,
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2
We also recommend denial of the petition for the storage surface
impoundments because Marathon will not be able to differentiate
between past releases from the previously unlined surface
impoundments and possible future releases from the retrofitted
units. The details of our concerns are described below.
Land Treatment Facility
Presence of Constituents Below the Treatment Zone fBTZ^
Ground-water and soil-pore monitoring data provided in
Marathon's petition indicate that migration of hazardous
constituents below the treatment units has already occurred.
Specifically, analyses of ground-water samples collected during
May 1989 (Appendix C, V.3, Appendix E, Table E-14) have indicated
the presence of bis (2-ethylhexyl)phthalate in three monitoring
wells (P6B, F7C, and P12B) at concentrations ranging from 20 to
47 ug/1. These data indicate that bis(2-ethylhexyl)phthalate is
present in the ground water at concentrations in excess of the
health-based level of 3 ug/1 used in no-migration petition
decision-making. In addition, results from six other monitoring
wells (P3D, P4C, P5C, P8B, P8C, and P12A) show the use of higher
than normal detection limits (20 or 36 ug/1 rather than 10 ug/1)
for this same parameter, indicating this compound's possible
presence at similar concentrations in the ground water at these
other locations.
In addition, benzene was detected at a concentration of 33
ug/1 in the soil-pore liquid collected from lysimeter L-3 on
July 6, 1989 (Appendix C, V.3, Table E-14). (The health-based
level for benzene is 5 ug/1.) Marathon infers that benzene is
commonly found in the air at refineries, and therefore, spurious
contamination of the sample may have occurred (Appendix C, V.l,
page 2-16). However, Marathon did not provide the necessary data
, - to support their speculation. Therefore, we can only conclude
that these data provide evidence of migration from the unit.
Detecting Migration at the Earliest Practicable Time
We have also concluded that Marathon1s groundwater
monitoring system will not be able to detect migration at the
earliest practicable time. Therefore, it failed to meet the
requirements of 40 CFR 1268.6(a)(4). Specifically, we are
concerned that Marathon will be unable to differentiate between
past releases from other sources and past, present, and future
releases resulting from the operation of the LTF. We also are
concerned that Marathon's unsaturated zone monitoring system will
not be able to detect potential migration in the northern section
of the West land treatment unit. We discuss our conclusions
below.

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3
Soil-core data provided by Marathon indicate that hazardous
constituents are present below the West land treatment unit.
Specifically, based on the presence of benzo(a)anthracene,
benzo(a)pyrene, benzo(b)fluoranthene, bis(2-ethylhexyl)phthalate,
chrysene, and pyrene in below treatment zone (BTZ) soil cores,
Marathon has concluded that a "historical waste body" which
predates operation of the West land treatment unit, exists
beneath the unit (see Attachment I). Of these constituents,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, and
chyrsene were detected below the treatment zone at concentrations
exceeding the health-based levels used in no-migration petition
decis ion-making.
Marathon states that these data do not conclusively prove
that constituents are migrating below the treatment zone.
Rather, Marathon argues that the presence of the above
constituents is due to past operations at this same site.
Marathon, however, has not explained how and when this
"historical waste body" was deposited. Therefore, we conclude
that Marathon has not conclusively proven that the constituents
detected below the treatment zone did not occur as a result of
land treatment operations.
Regardless of whether the contaminants beneath the
treatment unit resulted from a "historical waste body" or from
current operations, we believe that Marathon will be unable to
determine whether releases occurred because the waste
constituents detected below the treatment zone have also been
detected in the wastes managed at the land treatment unit. Due
to Marathon's inability to differentiate between past releases
from other sources and past, present, and future releases (if
any) resulting from the operation of the LTF, we conclude that
Marathon has failed to meet the requirements of 40 CFR
§268.6(a)(4).
Lastly, in 1988, Marathon expanded the 17-acre West land
treatment unit to include an adjacent three acres (the northern
expansion). Run-off from both the East and West land treatment
units drain into this area and are routed to storage tanks and
the refinery's wastewater treatment system. During storms,
however, the run-off does not drain as fast as it accumulates,
and the northern expansion area floods. As a result of the
ponding, a temporary hydraulic head is formed, increasing the
potential for migration of hazardous constituents. Although
Marathon recently installed new lysimeters in the northern
expansion, samples have yet to be collected. Marathon has
collected soil core samples from this area, but results have not
been submitted. Marathon, therefore, is unable to demonstrate
that there has been, or will not be migration of hazardous
constituents from this area of the West land treatment unit.
<^0
-------
4
Maintaining Minimum Separation
Federal regulations require that the depth to ground water
at land treatment facilities should be no less than three feet
from the bottom of the treatment zone to the seasonal high water
table (see 40 CFR §§264.271(c)(2)). Data provided in the
petition indicate there may be a seasonal high water table or
perched water table within the till layer beneath the LTF, or at
least near the northern part of the LTF, that encroaches into the
three foot thick buffer zone required below the treatment zone.
Specifically, some of the monitoring wells screened in the till
and at the till/sandstone interface were found to have depth-to-
water level measurements of less than eight feet. The water
level measurements were taken during relatively dry months
(August and November) in which ground water is at a low level.
Marathon's inability to demonstrate that it is maintaining the
minimum separation between the bottom of the treatment zone and
the top of the seasonally high ground-water table is a basis for
denial of the no-migration petition.
Surface Impoundments
We have concluded that Marathon has failed to demonstrate,
to a reasonable degree of certainty, that constituent migration
from the three storage surface impoundments will not occur. We
note that it is difficult to evaluate the long-term performance
of the liner system installed in the three surface impoundments
for the storage of both liquid wastes and bulk dry wastes.
Discussed below are the reasons why we have concluded that
Marathon has failed to demonstrate that there will be no-
migration of constituents at hazardous concentrations from the
three impoundments.
First, we are concerned that Marathon will not be able to
differentiate between past releases from the previously unlined
^.impoundments and future releases (if any) from the new lined
' impoundments. Specifically, between 1980 and 1988, Marathon
operated the three surface impoundments without liners and leak
detection systems. After eight years of operating without
liners, we believe that it is likely that some contamination of
the subsoils has occurred beneath these impoundments. According
to the Geological Engineering Report for the three surface
impoundments (Appendix D, V.l, Attachment V, page 3-2), soil
borings taken from areas near the pits showed a layer of soil
with strong odor and appearance of hydrocarbons. The presence of
contaminated soils beneath the impoundments will hinder
Marathon's ability to determine whether constituents are
migrating from the impoundments and affect Marathon's ability to
detect constituent migration at the earliest extent practicable.
Second, on June 19, 1990, the Illinois Environmental
Protection Agency (XEPA) conducted a site visit at the Robinson
5-1
-------
5
Refinery. During the site visit, it was apparent that waste
overtopping had occurred as evidenced by the dead vegetation and
stained soil on the south side of the impoundment. In the
petition, Marathon has claimed that, to prevent overtopping, they
designed the impoundments with adequate freeboard (two-feet). As
overtopping, induced by local meteorological conditions, recently
occurred, Marathon's design of the impoundments is insufficient
to prevent future occurrences of overtopping. As a result,
Marathon has failed to prove, to a reasonable degree of
certainty, that there will be no migration.
Third, Marathon stated that the Oily Sludge Pit had leaked
due to a one-inch tear in the upper flexible membrane liner in
the center of the pit, which "appeared to have been caused by
some external mechanism and was not the result of material
failure." Marathon does not know how the liner was damaged.
Without this knowledge, Marathon can not guarantee that such an
event would not occur in the future. In addition, the petition
indicated that the bulk waste pit will be manually cleaned out
every one-to-five years, depending on the waste accumulation
rate. Without knowledge of how or why the impoundment liner was
damaged, Marathon will not be able to guarantee that the bulk pit
liner will not be damaged when personnel remove solids.
Completeness of Petition
Finally, our review indicates that the petition is
incomplete and that information and clarification, in areas
beyond those highlighted above, would be needed to complete the
petition. However, because of the problems noted above, we
believe we have enough information at this time to move toward a
denial of your petition.
It is our practice to give petitioners the option of
* "withdrawing their petitions to avoid a negative publication in
the Federal Register. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Land Disposal prohibitions scheduled to be
effective November 8, 1990. This letter should be forwarded to
the following address within two weeks of the date of receipt of
today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
*K csr*.
-------
6
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal pegjster.
Any questions regarding our findings may be submitted in
writing to Mr. James Michael of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Haste
Attachment
ccj Karl Bremer, EPA Region V
George Hamper, EPA Region V
Gale Hruska, EPA Region V
Larry Eastep, Illinois EPA
Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
Terry Keidan, PSPD, OSW
-------
7
ATTACHMENT I
Summary of Constituents Detected in the BTZ (mg/kg)
Constituents
D»t«
Saapla
Ntsrtscr
Concentr»t)on
H«alth-B«S4
Laval
B«nto(a)arithrac«rw
07/11/89
LTD-5-2
20
0.0S5

07/11/19
LTD-51-2
120


04/18/89
LTD-12C
0.83

8*nzo<«}pyr«f»
07/11/89
ITD-K-2
a
0.055
8«nxo(b)fluoranthen«
07/11/89
LTD-SE-2
52
0.055
Bis(2EH)phthalate
08/10/88
*1-170
0.68
50
Citryscnt
08/10/88
HI-SO
0.41
« V

07/11/89
LT0-50-2
110


04/19/89
ITB-5I
0.095


07/11/89
LTO-5E-2
650


08/09/88
*1-1®
1.3


08/10/88
H-12D
0.35


04/18/89
LT0-12D
3.4


04/18/89
LTD-12E
0.99

Pyraiw
07/11/89
LTtt-5-2
27
32,000

07/11/89
IT0-SE-2
160


04/16/89
ire-120
0.63

1/ Calculated by Marathon using the RFI Guidance Manual.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1990(10)
Mr. R. G. Soehlke
Plant Manager
Star Enterprise
Delaware City Refinery
2000 Wrangle Hill Road
Delaware City, Delaware
NOV 7 1990
19706
Re: No-Migration Petition submitted for Star Enterprise's
Delaware City, Delaware Land Treatment Unit
(F-90-NSEP-FFFFF).
Dear Mr. Soehlke:
I am writing in regard to your December 26, 1989 "no-
migration" petition, which requests a variance under 40 CFR
§268.6 to allow Star Enterprise to continue the land treatment of
restricted wastes (EPA Hazardous Waste Nos. K048 - K051) at
Star's Delaware City, Delaware land treatment unit (LTD). After
a careful review of your petition, we have concluded that your
facility does not meet the standard for a no-aigration finding.
Therefore, we will recommend to the Assistant Administrator for
Solid Waste and Emergency Response that the petition be denied.
Our decision to recommend denial of the petition is based on
two main concerns:
Unsaturated zone monitoring for lead and nickel
indicate that hazardous constituents have already
migrated beyond the unit boundary.
Ground-water monitoring for arsenic, chromium, lead,
selenium, and vanadium indicate that hazardous
constituents have already migrated beyond the unit
boundary.
, The details of our concerns are described below.
Presence of Constituents Below the Treatment Zone (BTZ)i
Analyses performed on the soil-pore liquids indicate that
lead and nickel have migrated out of the treatment zone. Soil-
pore samples taken during the first three quarters of the land
treatment demonstration (12/88 - 5/89) show the exceedance of
lead and nickel above their respective health-based levels. Lead
showed concentrations in excess of the health-based level of 0.05
mg/1 for 13 out of the 34 samples taken, while nickel showed
concentrations in excess of the health-based level of 0.1 mg/1
-------
2-
for 15 out of the 35 samples taken. These data demonstrate that
both lead and nickel have migrated below the treatment unit at
concentrations in excess of their respective health-based levels.
(See Attachment, Table 1).
Presence of Constituents in the Ground Water
Results of ground-water monitoring analyses also indicate
the presence above health-based levels of metals in the ground-
water at the LTU boundaries. Specifically, arsenic (125 ppb),
selenium (up to 50 ppb), lead (up to 208 ppb), chromium (up to
320 ppb), cadmium (up to 122 ppb), and vanadium (455 ppb) were
shown to exceed their respective health-based levels. (The
health-based level for arsenic, lead, and chromium is 50 ppb; for
selenium and cadmium, the health-based level is 10 ppb; and for
vanadium the health-based level is 240 ppb). While background
may have contributed somewhat to the measured levels of the
hazardous constituents, the differences between the upgradient
monitoring well concentrations and the downgradient monitoring
well concentrations exceeded the health-based levels. Therefore,
these data demonstrate that arsenic, selenium, lead, chromium,
cadmium, and vanadium have migrated to the ground-water above
their respective health-based levels. (See Attachment, Table 2).
Incomplete petjtjpn
Finally, our review indicates that the petition remains
incomplete and that information and clarification in areas beyond
those highlighted above would be needed to complete the petition.
However, because of the problems above, we believe we have enough
information at this time to move toward a denial of your
petition.
It is our practice to give petitioners the option of
withdrawing their petitions to avoid a negative publication in
, - the Federal Register. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions scheduled
to be effective on November 8, 1990. This letter should be
forwarded to the following address within two weeks of the date
of receipt of today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
Office of Solid Waste
V.Sm Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
br-'-J
-------
-3
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal Register.
Any questions regarding our findings may be submitted in
writing to Mr. James Michael of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
Attachment
cc: John Humphries, EPA Region III
David Turner, EPA Region III
Guy Lee, DKREC
Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
5^1
-------
-4-
bcc: Terry Keidan, AB, PSPD, OSW
Allyson Ogarte, AB, PSPD, OSW
Dave Reeves, AB, PSPD, OSW
Richard Kinch, WMD, OSW
Kathy Stein, OE
Nikki Roy, WMD, OSW
Howard Finkel, ICF Incorporated

-------
ATTACHMENT
TABLE 1
Summary of Soil-Pore Monitoring Data
For Lead and Nickel

First Quarter
Second Quarter
Third Quarter

(12/15/88-3/6/WJ
<3/13/89-5/1/89)
(5/8/89-7/3/89)
Call Ho.
lead Mick* I
Lead Nickel
lead Nickel
1
<0.1
0.29
0.17
0.07
0.1 •
0.05
2
<0.1
0.18
0.1
0.04
0.1
0.16
3
<0.1
0.08
<0.1
0.06
0.1
0.11
4
<0.1
0.2
<0.1
0.09
<0.1
0.1
5
<0.1
0.15
0.12
0.18
0.14
0.12
6
<0.1
0.08
<0.1
<0.04
<0.1
<0.04
7
<0.1
0.12
<0.1
0.05
<0.1
0.05
8
<0.1
0.08
0.12
0.14
0.17
0.16
9
<0.1
0.12
<0.1
<0.04
MA
NA
10
<0.1
<0.04
<0.1
<0.04
<0.1
<0.04
11
HA
0.31
0.21
0.25
0.17
0.2S
12
<0.1
0.06
0.11
<0.04
0.1
0.05
BL-t
NA
MA
<0.1
0.06
<0.1
<0.04
Triple Blank
<0.1
<0.04
<0.1
<0.04
<0.1
<0.04
-	All units are in ppa.
-	The health-based level for lead is 0.05
is 0.1 ppa.
-	No-Migration Petition, Volume 1, Tables
ppa, and for nickel it
4-1 to 4-3.

-------
TABLE 2
GROUND-WATER MONITORING DATA
YEAR
Arsenic
Selenium
Lead
Chromium
Cadmium
Vanadium
BKG*
<50
<10
<50
<50
90
130
HBL
50
10
50
50
10
240
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
125
50
15
173
96
136
208
60
230
320
73
55
104
122
455
* Background values shown record the highest reported value.
Background value for cadmium (well no. 26) was taken 9/86, and
for vanadium (well no. 36D) was taken 6/89.
-	Downgradient values are taken from well numbers 18, 19 and 41.
-	All units are in ppb.
-	Only the highest values detected are shown in this table.
-	No-Migration Petition, Appendix B, Volume 3, Section E-2.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9551-1990(11)
NOV 7 1390
Mr. D. D. Smart
Manager of Health, Safety, and Environment
Shell Oil Company
Anacortes Refinery
P.O. Box 700
Anacortes, Washington 98221
Re: No-Higrration Petition submitted for Shell Oil Company's
Anacortes, Washington Land Treatment Facility
(F-90-NSAP-FFFFF).
Dear Mr. Smart:
I am writing in regard to your January 17, 1990 "no-
migration" petition, which requests a variance under 40 CFR
§268.6 to allow Shell Oil Company to conduct the land treatment
of restricted wastes (EPA Hazardous Waste Nos. K049, K051, K052,
and WP03) at Shell's Anacortes Refinery land treatment facility
(LTF). After a careful review of your petition, we have
concluded that your facility does not meet the standard for a no-
migration finding. Therefore, we will recommend to the
Assistant Administrator for Solid Waste and Emergency Response
that the petition be denied.
Our decision to recommend denial of the petition is based on
several concerns:
•	Soil-pore and soil-core monitoring indicate that
hazardous constituents have already migrated beyond the
unit boundary.
•	Shell will not be able to detect migration at the
earliest time because Shell has indicated that ground-
water monitoring wells will not be used to demonstrate
no-migration.
The details of our concerns are described below.
Presence of Hazardous Constituents Below the Treatment Zone fBTZ^
Soil-pore and soil-core monitoring data provided in Shell's
petition indicate that migration of hazardous constituents below
the treatment unit has already occurred. Specifically, analyses
of soil-pore data collected from 1987-1990 have indicated the
presence of antimony, benzene, benzo(a)anthracene,
benzo(b)fluoranthene, benzo(k)fluoranthene, and chrysene above
551
-------
2
health-based levels used ill no-migration decision-making. The
results of these analyses are presented in Attachment 1.
In addition, several soil samples from beneath the treatment
zone indicated the presence of antimony, benzo(a)anthracene, and
benzo(b)fluoranthene above health-based levels. The results of
these analyses are provided in Attachment 2. Shell personnel, in
the course of a March 1990 site visit by EPA representatives,
suggested that the presence of certain of these contaminants may
be due to cross-contamination in the coring process. However,
since these contaminants were found beneath several management
sites within the land treatment facility, we question Shell's
explanation. Furthermore, many of these contaminants are also
present in the soil-pore water, which could not be attributed to
cross-contamination during coring activities.
Detecting Migration at the Earliest Practicable Time
We have concluded that Shell has failed to meet the
requirements of 40 CFR 5268.6(a)(4). Specifically, Shell has
stated in the petition that ground-water monitoring wells are not
part of the no-migration monitoring plan. Shell's determination
is inconsistent with 40 CFR §268.6(a)(4) which requires a
monitoring plan that detects migration at the earliest
practicable time. In addition, Shell has not provided any
ground-water monitoring data more current than 1985. Due to
Shell1s failure to provide this data, the petition is incomplete
and significant amounts of information and clarification would be
needed to complete the petition. However, because the technical
basis for denial already exists, we are not requesting you to
provide further information.
It is our practice to give petitioners the option of
withdrawing their petitions to avoid a negative publication in
the Federal Register. If you prefer this option, you must send
^ us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions scheduled
to be effective November 8, 1990. This letter should be
forwarded to the following address within two weeks of the date
of receipt of today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal Eegjstejr.
w
-------
3
Any questions regarding
writing to Mr. James Michael
our findings may be submitted in
of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Haste
Attachments
cc: Michael Gearheard, Region X
Carrie Sikorski, Region X
Kim Anderson, Washington DOE
Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
Terry Keidan, AB, PSPD, OSW

-------
Attachment 1
Soil-Pore Results

Units
Lysimeter
1
2
3
4
5
6
7
8
April 11,1987
Antimony
mg/I


*0.65





July 23,1987
Antimony
mg/1


•0.78





Oct 19,1§67
Antimony
mg/1




0.77



Jan 20,1988
Antimony
m g/1




0.32



May 1989
Antimony
mg/i
0.047
0.012


0.7



September 1989
Antimony
mgn
0.05



0.8



December 1989
Antimony
Benzene
Benzo(a)anthracene
Benzo(b)fl uoranthene
Benzo(k)fluoranthene
Chrysene
mg/1
mg/l
mg/1
mg/1
mg/1
mg/I
0.0017
0.0022
0.0022
0.0072
0.064
0.4
0.3
0.5
0.3


March 1990
Antimony
Benzene
mg/1
mg/1
1.2
0.038






* Composite sample with lysimeter 5 -
- Health-based levels:
Antimony - 0.01 mg/1
Benzene * 0.005 mg/1
Benzo(a)anthracene * 0.0002 mg/1
Benzo(b)fluoranthene « 0.0002 mg/1
Benzo(k)fluoranttiene « 0.0002 mg/1
Chrysene « 0.0002 mg/1
J
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1990(12)
NUV 8 1990
Mr. Joel Rich
Sinclair Oil Company
902 West 25th Street
Tulsa, OK 74107
Re: No-Migration Petition submitted for Sinclair Oil Company,
Walnut Grove Land Treatment Facility, Tulsa, Oklahoma
Dear Mr. Rich:
I am writing in regard to your June 14, 1990 "no-migration"
petition, which requests a variance under 40 CFR §268.6 to allow
Sinclair Oil Company to continue the land treatment of restricted
wastes (EPA Hazardous Waste Nos. K049, K050, K051 and K052) at
the Walnut Grove land treatment facility in Tulsa, OK. We have
completed an initial review of the petition for overall
administrative and technical completeness. As you know, the
statute establishes a very strict standard for no-migration
variances. The standard to be met requires demonstration of no
migration (to a reasonable degree of certainty) of hazardous
constituents beyond the unit boundaries. Based on our evaluation
of the petition, we have concluded that Sinclair's Tulsa facility
does not meet that stringent standard. As a result, we intend to
dismiss your petition.
It is our policy to dismiss petitions that contain
deficiencies which require more than six months for the
petitioner to correct, or that show evidence clearly indicating
releases of hazardous constituents to environmental media have
already occurred, our decision to dismiss your petition is based
on the present groundwater monitoring system not being able to
detect migration at the earliest practicable time as required by
the Agency's no-migration petition requirements (see 40 CFR
§268.6 (a) (4)} and that soil-pore data provided in the petition
indicate that releases have already occurred at the land
treatment facility.
First, SPA's review of the Groundwater Assessment Plan and
the Third Quarterly Progress Report of the RFI Workplan revealed
that the current groundwater monitoring system is inadequate to
detect	the miyiaiitm o£ haiimdfl^|wma3tifcue«ifea fucim the Waltnifc	
iSiuvu l«tml .LmaUimU-^lil iat LBe eqilical pijacLiualjlf Lime, yiic

-------
Groundwater Assessment Plan was required by a Consent Agreement
between Oklahoma State Department of Health (OSDH) and Sinclair
on April 9, 1990 because of non-compliance with the land
treatment facility's (LTF) permit. The LTF's background
groundwater monitoring well (WTP-4) is located in a solid waste
management unit (SWMU-C) and is also being affected by a
hydrocarbon plume. To come into compliance, Sinclair agreed to
expand the groundwater sampling and analysis plan to meet the
requirements of 40 CFR §270.14(c)(4). Specifically, Sinclair
must develop a plan capable of determining the extent of
migration of hazardous constituents into the groundwater and the
background concentration of all Appendix IX constituents detected
at the point of compliance. A plan has not yet been approved by
OSDH.- In addition, the Third Quarterly Progress Report states
that the existing upgradient and downgradient monitoring wells at
the Walnut Grove facility may not comply with EPA's Technical
Enforcement Guidance Document (TEGD) well installation and
completion requirements. Further investigation is required to
determine if the wells are in compliance.
Second, lead has been detected in the soil-pore water
monitored at the land treatment unit. Sampling analysis data
from all the lysimeters at the Walnut Grove facility (WGL-1, WGL-
2, WGL-3, WGL-4, WGL-5, and WGL-6) from 1981 through 1988 show
concentrations above the health-based level (0.05 mg/L) for lead.
More recent data were not provided in the petition. The sampling
analysis data provide evidence that migration has already
occurred beyond the unit boundary at hazardous concentrations.
The effect of our dismissal will be to close your petition
file. If you disagree with our intent to dismiss your petition,
you may submit a letter explaining why you believe a dismissal is
not warranted. If we do not receive such correspondence within
two weeks from the date you receive this letter, the dismissal of
your petition will become effective. You may choose to submit a
new petition for this land treatment facility in the future, once
you have an approved plan for a groundwater monitoring system in
compliance with 40 CFR §265 and §270 requirements. However, the
evidence that releases of hazardous constituents have migrated
beyond the unit boundary would serve as the technical basis for
the development of a proposed Federal Register denial of the
petition.
If you have any questions regarding the dismissal of your
petition or require additional information, please contact Jim
Michael of my staff at (202) 382-2231.
Sincerely,
Don R. Clay
Assistant Administrator
-------
3
cc: Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
Terry Keidan, PSPD, OSW
Bill Honker, Region VI
Bill Gallagher, Region VI
53°
-------
4
bcc: Athena Rodbell, PSPD, OSW
Richard Kinch, WMD, OSW
Kathy Stein, OW
Nikki Roy, WMD, OSW
Howard Finkel, ICF, Incorporated
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9551.1990(13)
NOV 8 j£0
Mr. R. B. Sheldon
Manager
Amoco Casper Refinery
P.O. Box 160
Casper, Wyoming 82602
Re: No-Migration Petition submitted for Amoco"s Casper Refinery
Land Treatment Unit (F-9 0-NACP-FFFFF)
Dear Mr. Sheldon:
I am writing in regard to your October 24, 1989 "no-
migration" petition, which requests a variance under 40 CFR
§268.6 to allow Amoco Oil Company to continue the land treatment
of restricted wastes (EPA Hazardous Waste Nos. K049 and K051) at
Amoco's Casper Refinery land treatment unit (LTU). After a
careful review of your petition, we have concluded that your
facility does not meet the standard for a no-migration finding.
Therefore, we will recommend to the Assistant Administrator for
Solid Waste and Emergency Response that the petition be denied.
Our decision to recommend denial of the petition regarding
the land treatment facility is based on two main concerns;
•	Ground-water monitoring data indicate that hazardous
constituents have already migrated beyond the unit
boundaries.
•	The ground-water monitoring system for the land
treatment facility is inadequate for the purpose of a
no-migration variance because it will not be able to
detect migration at the earliest practicable time due
to the presence of hazardous constituents beneath the
land treatment units.
The details of our concerns are described below.
5.3^
-------
2
Presence of Hazardous Constituents Below the Treatment Zone
Our review of Amoco*s 1989 ground-water monitoring report
for the LTU submitted subsequent to its petition indicates that
migration of hazardous constituents beyond the unit boundaries
has already occurred. Attachment 1 indicates that exceedance
criteria values were surpassed on 54 occasions, and, on 11
occasions, concentrations surpassed both the exceedance criteria
and the health-based level for the following analytes: antimony,
beryllium, chromium, and lead. Respectively, the maximum
downgradient concentration as compared to the health-based level
for each metal is (in mg/1): 0.26 vs. 0.005, 0.03 vs. 0.002,
0.327 vs. 0.035, and 0.07 vs. 0.002. Therefore, we can only
conclude that these data provide evidence of migration from the
unit.
Benzene was also found above the health-based level of 5
ug/1 in downgradient well LF-43 during the second and fourth
quarters at concentrations of 17 and 6 ug/1, respectively.
Because benzene was not reported in any of the upgradient wells,
we have concluded that benzene has migrated beyond the unit
boundaries.
Detecting Migration at the Earliest Practicable Time .
We believe that Amoco is unable to detect migration from the
treatment unit to the ground water at the earliest practicable
time and therefore has failed to meet the requirements of 40 CFR
§268.6(a)(4). Specifically, we are concerned that Amoco will be
unable to determine the occurrence of migration directly beneath
the LTU and that Amoco has not identified an acceptable method of
differentiating between "background" contamination and releases
from the LTD.
Analysis of ground-water monitoring data indicates the
presence of contaminants in upgradient, as well as downgradient,
wells near the LTU. In addition, Amoco has suggested that prior
tank farm activities in the vicinity of the LTU, particularly on
the eastern side, may contribute to downgradient contamination.
Several problems arise from these conditions which contribute to
the deficiency of Amoco1s monitoring program.
Amoco speculates that petroleum contamination in the ground
water and soils both upgradient and downgradient of the LTU (and
The RORA permit for the facility establishes exceedance
criteria for compliance purposes; these include
"critical values'* for metals and "reporting limits" for
organics (page 6).
5q0
-------
3
possibly beneath the plots as well) is derived from leakage from
petroleum storage tanks that previously occupied the area.
Amoco, however, has provided neither analytical results that
describe the possible source(s) nor an adequate plan to
differentiate releases from the LTD from such a source. Because
the constituents of a weathered petroleum product plume would
likely be very similar to a release from the LTD, it would be
difficult to discern one from the other. Furthermore, since the
concentration of a contaminant from an upgradient source would be
higher closer to the source, the dilution effect as the plume
moves downgradient would likely mask concentrations due to a
release from the LTD, making a statistical comparison
meaningless.
Amoco has suggested that because the ground-water samples
show similar characteristics, they are most likely derived from a
common, upgradient source. As noted by Amoco, similar
characteristics are to be expected in the various fractions of
crude and refined oil found within the refinery. However, the
samples from the downgradient wells indicate a wider variety of
benzene, ethylbenzene, toluene, and xylene than the upgradient
samples, an observation that is contrary to what would be
expected from a common source.
Completeness of Petition
Finally, we have found that the petition is incomplete and
that information and clarification, in areas beyond those
highlighted above, would be needed to complete the petition.
However, because of the problems noted above, we believe we have
enough information at this time to move toward a denial of your
petition.
It is our practice to give petitioners the option of
^.withdrawing their petitions to avoid a negative publication in
' the Federal Register. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions scheduled
to be effective November 8, 1990. This letter should be
forwarded to the following address within two weeks of the date
of receipt of today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W. •
Washington, D.C. 20460
-------
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal Register.
Any questions regarding our findings may be submitted in
writing to Mr. James Michael of my staff.
Attachment
cc: Carol Campbell, Region VIII
Felix Flechas, Region VIII
Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
Terry Keidan, PSPD, OSW
-------
Attachment 1
SUMMARY OF DOWNGRADIENT GROUND-WATER MONITORING DATA
AMALYTE
>
EXCEEDANCE
CWTETOA'
>EXCEE&*NCE
CfVTEMA AND
MCLa
MOETimiMATE2
LOW
CONCENTRATION*
Antimony

3
20

Arsame
3


9
Baiylfa'uffi

3
17

Cobalt



5
Cadmium




Chromium
1
1
9
4
Coppar



5
laad

4
21

Marcuiy



1
Salanium
10



SiNar



1
Vanadium


I

a«c
13

7
3
Baroana
3



Sthylbanana
3



Tohiana
8



Xylana
9


|
2-IMhyl
naphthalana
2



NaphJhaJana
2



Z*-Oimathyl
phanol
1



erttana* lor eomammamt that mduda cnttc«l value* tor
inof^mftic# «nd wpoftng fifnfci tof Of^trk*. Thi» column grad*nt
wa«» that vio<«ad *a axcaadanca crtarta lor » particular ma»yta. Vioiabon* ot brth ma axeaadaoca critana and tha
MCL ara eountad aapanMy.
2	Nuwbfi in tfaa eotunwi raflact viotabona at bed tha a«caadanca ctftaria and tha MQ_
3	f* 		 		 * mi	» ¦ - - «— 		¦¦ ¦* ¦ J — -»•• 	 HAMa	/a			*- -— *• • ouBji It	Aflfc
V/MWMNM MVHI tMCI fflpOflM OI«)f M T®®» Mn (8	VMNJ, mKi R GSffW O® OWmo wntffUr Wiy *V
M0ftar or lew*r Stan ttw axcaadanca cfftaria aiMVor MCL
4	Although wot in viotetfon o< a«&aadanca oOarta or MCL conaa dwwpadlai* aamplaa
Mtang that imgntion m taking ptaoa.
5q3
-------
9551. iyytAi'O
xltO »w
.r
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9551.1990(14)
WASHINGTON, D.C. 20460
DEC I I ino
opfice op
SOLID WASTE AMD EMERGENCY RESPONSE
Hr. Garth Dull, Director
Department of Transportation
State of Nevada
1263 South Stewart Street
Carson City, Nevada 89712
Dear Mr. Dull:
Thank you for your letter of November 21, 1990, requesting a
written confirmation that the asbestos/lead/soil/debris material
on property intended for highway construction is classified as
inorganic solids debris. In previous letters, you have described
this material as lead dross, concrete hooker cell, metal drums,
masonry and refractory bricks, scrap metal, carbon anode blades,
and concrete pipes.
The Environmental Protection Agency (EPA) has defined
"inorganic solids debris" as wastes contaminated with
characteristic metals that are nonfriable and that do not pass
through a 9.5-mm sieve tray. These wastes fall into eight
classifications, such as bricks, metal cans, metal pipes, and
scrap metal. Based on the description you provided, your waste
falls under the inorganic solids debris treatability group. EPA
has determined that this treatability group has a two-year
capacity extension of the effective date of the land disposal
restrictions. Therefore, this material currently does not need
to be treated to comply with the treatment standard for lead, and
. can be disposed of in a Subtitle C landfill that meets minimum
'" technological requirements.
If you have further questions, please do not hesitate to
call Richard Kinch at (703) 308-8434.
Sincerely yours
Sylvia K. Lowrance, Director
Office of Solid Waste1
Mm*dm
-------
9551.1990(15)
DEO 20 I960
Mr. Douglas MacMillan, Director
Hazardous Waste Policy
National Solid Wastes Management Association
Suite 1000
1730 Rhode Island Ave., N.W.
Washington, DC 20036
Dear Mr. MacMillan:
This letter responds to your inquiry dated October 11, 1990
about several aspects of the Third Third land disposal
restrictions final rule. Your letter includes questions about
the folloving topics: lab packs, inorganic solid debris,
certification/notification requirements, and the disposal of D001
ignitable wastes. Responses to the specific questions about each
of these topics are presented below.
1.	Pfr
-------
265.316(b) does not require overpacking of fiber drums in metal
drums. The first sentence of §§ 264.316(b) and 265.316(b)
(" [t]he inside containers must be overpacked in an open head DOT-
specification metal shipping container") does not apply because
SS 264.316(f) and 265.316(f) clearly state that "[p]ersons who
incinerate lab packs according to the requirements in 40 CFR
268.42(c)(1) may use fiber drums in place of metal outer
containers." The SS 264.316(b) and 265.316(b) language that does
apply# however, is the requirement to pack a sufficient quantity
of absorbent material around the inner containers to completely
absorb all of the liquid contents of the inside containers,
making the outer container full after packing.
As you mention in your letter, the preamble language on page
22631 of the Third Third final rule explains the Agency's
decision to allow fiber drums to be used as outer containers for
lab packs being incinerated according to the requirements in
40 CFR 268.42(c)(1). The language of SS 264.316(f) and 265.316(f)
does not eliminate this decision by otherwise requiring the fiber
drums to be overpacked in metal drums.
2.
You request clarification of why containers are included in
the "inorganic solid debris" definition. You also ask when an
empty container would, be judged to carry a characteristic of
hazardous waste.
By way of background, inorganic solid debris is defined in
40 CFR 268.2(g) as nonfriable inorganic solids contaminated with
D004 - 0011 hazardous wastes that are incapable of passing
through a 9.5 mm standard sieve; and that require cutting, or
crushing and grinding in mechanical sizing equipment prior to
stabilization; and, are limited to certain types of debris
specified in subsequent paragraphs. Paragraph (g) (6) of
i 268.2 includes metal cans, containers. drums, or tanks in the
definition of inorganic solid debris.
As a further point of background, the answers to your
questions are impacted by whether the container being discussed
is empty as defined at 40 CFR 261.7(b). Under the S 261.7(b)
provisions, a container that has held hazardous waste (other than
a compressed gas or an acute hazardous waste) is "empty" if it
meets certain criteria. All wastes must have been removed that
can be removed using the practices commonly employed to remove
materials from that type of container. To assure that all waste
has been removed, there may be no more than 2.5 centimeters (one
inch) of residue remaining on the bottom of the container or
inner liner; or no more than 3 percent by weight of the total
capacity of the container remaining in the container at inner
liner if the container is less than or equal to 110 gallons in
size, or no more than 0.3 percent by weight of the total capacity
-------
of the container remaining in the container or inner liner if the
container is greater than 110 gallons in size.
In response to your first question, containers are included
in the definition of inorganic solid debris to cover the possible
scenario of a container that has been discarded by means of land
disposal (as defined in § 268.2), that does not meet the
i 261.7(b) definition of empty, and that is contaminated with a
characteristic metal waste. This scenario could occur, for
instance, during an excavation at a corrective action site. A
container might be uncovered that is damaged (e.g., crushed) so
that the hazardous waste within it cannot be removed sufficiently
to meet the § 261.7(b) definition of empty*. Such a container
(i.e., including its contents) is a hazardous waste subject to
the land disposal restrictions if it is subsequently land
disposed. Furthermore, it is likely that the disposed container
would be considered contaminated debris (such a determination may
depend upon site-specific conditions best made by an authorized
State or SPA Regional representative). If the waste
contaminating this disposed container is a characteristic metal
waste (D004 - D011), the container would likely meet the
i 268.2(g)(6) criteria of inorganic solid debris, and would thus
be subject to a national capacity variance until May 8, 1992 (see
S 268.35(b)).
In response to your second question, a container meeting the
| 261.7(b) definition of empty may be judged to be a
characteristic metal waste under two scenarios. In the first
scenario, a container that has never held any hazardous waste may
be a characteristic waste if: (1) it is being discarded; and, (2)
if the container is in itself a characteristic waste.
In the second scenario, an empty container (as defined in
I 261.7(b)) may be a characteristic waste if: (1) it is being
discarded; and, (2) if the container is in itself a
characteristic waste. It should be noted, however, that any
residue remaining in the container is exempt from regulation
, - under the provisions of S 261.7(a) that states that "(a]ny
hazardous waste remaining in either (i) an empty container or
(ii) an inner liner removed from an empty container, as defined
in paragraph (b) of this section, is not subject to regulation
under Parts 261 through 265, and Parts 268..."
3. certifigatipng
You request clarification of the record keeping requirements
for a particular scenario: A waste that the generator determines
(based on process knowledge) does not meet the treatment standard
is sent to a treatment facility. The treatment facility
determines the waste does meet the treatment standard. 1 You did
not suggest how such a determination was made. Your question is,
how would the record keeping requirements be affected?
5tp
-------
In this particular scenario, the treatment facility should
analyze the waste in order to determine that the waste meets the
treatment standard according to the provisions of their waste
analysis plan. It should be noted, however, that there is no
requirement that treatment facilities analyze each shipment of
waste received, except as specified in their waste analysis plan
(see § 268.7(b). In this particular scenario, however, the
generator has made the determination that the waste must be
treated based on his knowledge of the waste. The treatment
facility is countering the generator's determination with a
determination that the waste meets the treatment standard as
generated? therefore, the Agency believes that it is appropriate
to ask the treatment facility to support their determination with
analytical data. The treatment facility also must complete a
certification that the waste met applicable treatment standards
as generated (see § 268.7(a)(2)(ii), supported by the general
principle expressed in I 268.7(b)(6) requiring treatment
facilities to comply with notice and certification requirements
applicable to generators).
The treatment facility must send the waste analysis data
(see § 268.7(b)(4)(iv)), the certification, and a notification
(either the generator's notification may be sent, or the facility
may create a new notification) to the disposal facility. Copies
of the waste analysis data, the generator's notification (as well
as the treatment facility's notification if a new notification
was created), and the certification must be kept as records in
the treatment facility's files.
y
-------
recycling facility to the TSD facility). The TSD facility must
comply with the requirements of § 268.7(b). Questions on how
frequently the required paperwork should be sent from the
recycling facility to the TSD (i.e., what constitutes a
"shipment") should be directed to the EPA Regional land disposal
restrictions contact.
5. D001
The question is whether 40 CFR 264.312 allows for the land
disposal of a D001 waste. Until promulgation of the Third Third
final rule on Hay 8, 1990, 40 CFR 264.312 (and § 265.312) set out
special management requirements for ignitable or reactive wastes
that were disposed in a surface impoundment, waste pile, land
treatment unit, or landfill. On page 22553 of the final rule,
however, the Agency explained that these management requirements
are superseded by the treatment standards promulgated in the
Third Third final rule. This means that "facilities handling
ignitable and reactive wastes will have to comply with the
promulgated treatment standards for these wastes in order to land
dispose them." The Agency made changes to the regulatory
language of §§ 264.312 and 265.312 in the Third Third final rule
to incorporate the requirement that the treatment standards for
ignitable and reactive wastes must be met prior to land disposal.
Furthermore, the Agency's intent is clearly expressed in the
preamble (55 FR 22553).
Therefore, land disposal is allowed only for those D001
wastes that meet the treatment standard. (The treatment standard
for D001 wastes containing less than lot total organic carbon
(TOC)s deactivation; for D001 containing greater than 10* TOC:
incineration or fuel substitution; see 40 CFR 268.42, Table 2.)
1 hope you find these answers to be helpful. If you have
any further questions, please feel free to contact
Matthew A. Straus at (703) 308-8414.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste

-------
9551.1990(16)
RCRA/SUPERFOND HOTLINE MONTHLY SUMMARY
DECEMBER 1990
1. LDR Requirements During National Capacity Variances
During a corrective action removal, a RCRA permitted treatment facility generates
a contaminated soil that is characteristic for arsenic (D004). The generator
determines that the waste has a treatment standard established in 40 CFR 268.41 of
the Land Disposal Restrictions (LDR) Third Third Final Rule. (55 FR 22520)
However, Section 26835(e) of the final rule also establishes a 2-year variance from
the land disposal prohibitions for D004 nonwastewaters due to insufficient
treatment capacity. What LDR requirements remain in effect during the period in
which a waste is granted a national capacity variants?
Section 3004(h)(2) of RCRA provides EPA with the authority to grant national
capacity variances from the statutory effective dates upon which land disposal
prohibitions become effective if there is insufficient alternative treatment,
recovery or disposal capacity for the wastes subject to the prohibition. In
determining whether a variance is warranted, EPA compares the nationally
available treatment capacity that will be in operation on the prohibition
effective date with the volume of wastes generated. If a significant shortage
exists, an alternate effe&ive date will be established based on the earliest date
such capacity will become available. (55 FR 22526)
-------
1. LDR Requirements During National Capacity Variances (Cont'd)
Although a national capacity variance temporarily extends prohibition effective
dates, it does not supersede the requirements applicable to hazardous wastes
that are "restricted", (see 55 FR 22592) Effective May 8,1990, all hazardous
wastes, except those identified or listed after the enactment of HSWA, are
"restricted" and therefore subject to certain provisions. (55 FR 22521) These
include three major requirements. First, generators of such restricted wastes
must comply with applicable waste analysis and recordkeeping requirements
established in Section 268.7, including the special notifications found at
268.7(a)(3) for wastes subject to a national capacity variance that are sent off-«'*e
for treatment, storage or disposal. (53 FR 31208)
Second, in addition to fulfilling relevant recordkeeping requirements/
generators of hazardous wastes subject to a national capacity variance must
evaluate their waste against the California list prohibitions. (55 FR 22529) The
California List establishes treatment standards and land disposal restrictions for
certain liquid wastes containing free cyanides, metals, corrosives and PCBs, and
for HOCs in either solid or liquid form [See Section 26832 and RCRA Section
3004(d)]. In the interim period in which a national capacity variance is in effect,
the California List requirements apply. (53 FR 31118)
Finally, if the generator determines that no other land disposal prohibitions are
applicable, the waste may be managed in a landfill or surface impoundment
provided the waste is placed in a unit that meets the minimum technology
requirements set out in 2683(h)(2). After the national capacity variance has
expired, such restricted hazardous waste may be land disposed only if the
applicable treatment standard is attained or disposal occurs in a unit that
satisfies the "no migration" demonstration found at 40 CFR 268.6. (55 FR 22521)
Please note, however, for wastes that axe subject to more than one treatment
standard, that during a national capacity variance for one of the wastes, the
treatment standards for any of the other waste codes that have not received
such a variance most be met (55 £R 22660)
Source:	Rhonda Craig, OSW	(703) 308-8451
Research: Stephen Buchanan
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1991(01)
JAN 3-19^
Mr. John R. Kampfhenkel
Chief Environmental Engineer
Koch Refining Company
P.O. Box 2608
Corpus Christi, Texas 78403
Re: No-Migration Petition submitted for Koch Refining*s Corpus
Christi, Texas Land Treatment Unit (F-90-NKCP-FFFFF)
Dear Mr. Kampfhenkel:
I am writing in regard to your April 26, 1990 "no-migration"
petition, vhich requests a variance under 40 CFR §268.6 to allow
Koch Refining Company (Koch) to continue the land treatment of
restricted wastes at Koch*s Corpus Christi, Texas land treatment
unit (LTD). After a careful review of your petition, we have
concluded that your facility does not meet the standard for a no-
migration variance. Therefore, we will recommend to the
Assistant Administrator for Solid Waste and Emergency Response
that the petition be denied.
Our decision to recommend denial of the petition is based on
the following concerns:
Soil-pore and soil-core monitoring indicate that
hazardous constituents have already migrated beyond the
unit boundary.
• Ground-water monitoring for vanadium indicates that
this hazardous constituent has already migrated beyond
the unit boundary.
Presence of Hazardous Constituents Below the Treatment Zone f BTZ1
Soil-pore and soil-core monitoring data provided in Koch's
petition indicate that migration of hazardous constituents below
the treatment unit has already occurred. Specifically, analyses
of soil pore liquid samples collected during August and September
of 1988 and in February, April, May, June, and October of 1989
indicate the presence of beryllium, cadmium, chromium, lead,
nickel, selenium, toluene, benzene, styrene, 2-butanone, 1,2-
dichloroethane, and ethyl benzene in excess of their respective
S/"
-------
health-based levels used in no-migration decision-making. The
results of these analyses are presented in Attachments l and 2.
Analyses of soil core monitoring data collected in December
1989 indicate that beryllium was detected at concentrations
exceeding the health-based level (HBL) of 0.2 mg/kg for soil
ingestion in Bores 1, 2, 3, 4, and 6. Antimony was also detected
at a concentration exceeding the HBL of 30 mg/kg for soil
ingestion in Bore 6 during December 1989.(See Attachment 3.)
Furthermore, Attachment 3 also shows that several organic
constituents were detected in the BTZ. Concentrations of
benzo(a)pyrene (6.5 mg/kg) and methyl chrysene (4.4 mg/kg) were
detected in Bore 1 (December 1989) above their respective HBL's
of 0.055 mg/kg for soil ingestion. Oil and grease levels in two
of the soil bores averaged 4,500 mg/kg for Bore 1 and 193 mg/kg
for Bore 4 in December 1989. The individual values for the BTZ
samples from Bore 1 were 1,900 mg/kg (5.0-5.5 feet)? 7,000 mg/kg
(5.5-6.5 feet)j and 4,600 mg/kg (6.5-7.5 feet). The presence of
benzo (a) pyrene and methyl chrysene and elevated levels of oil and
grease beneath the treatment zone further demonstrate that
hazardous constituents have migrated below the treatment unit.
Ground-Water Monitoring Data
Ground-water monitoring data presented in Koch's petition
indicate that migration of hazardous constituents to the ground
water has already occurred. Specifically, a review of the August
1988 ground-water monitoring data indicate the presence of
vanadium in downgradient wells LE-3 (0.39 mg/1) and LE-5 (0.28
mg/1) in excess of the HBL (0.24 mg/1) used in no-migration
petition decision-making. (See Attachment 4.)
In addition, total organic carbon (TOC) levels were
significantly higher in downgradient wells LE-3, LE-4, LE-5, and
LE-6 than in upgradient wells in September of 1988. However, we
are unable to determine whether organics are present at levels of
concern because Koch did not provide a fractional analysis of the
constituents in the TOC samples. Lastly, although the difference
between the downgradient and upgradient monitoring wells did not
exceed the health-based levels, the downgradient concentrations
for arsenic (LE-3 and LE-4), mercury (LE-6), and selenium (LE-6)
did exceed the upgradient concentrations during August of 1988.
Incomplete Petition
Finally, our review indicates that the petition is
incomplete and that information and clarification in areas beyond
those highlighted above would be needed to complete the petition.
However, because of the problems discussed above, we believe we
have sufficient information at this time to move toward a denial
of your petition.
5JH
-------
It is our practice to give petitioners the option of
withdrawing their petitions to avoid a negative publication in
the Federal Register. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions. This
letter should be forwarded to the following address within two
weeks of the date of receipt of today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Eegistsz.
Any questions regarding our findings nay be submitted in
writing to Mr. James Michael of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
Attachments
cc: Bill Honker, IPA Region VI
Tony Robledo, IPA Region VI
Minor Hibbs, Texas Water Commission
Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
-------
-4-
bcc: Terry Xeidan, AB, PSPD, OSW
Jeffrey Gaines, AB, PSPD, OSW
Dave Reeves, AB, PSPD, OSW
Richard Kinch, WMD, OSW
Kathy Stein, OE
Hikki Roy, WMD, OSW
Howard Finkel, ICF Incorporated
-------
ATTACHMENT 1
SoLI-Pore Liquids - Inorganic Constituents (ag/1)

AS
Ba
B*
Ccf
Cr
PD
Hfl
Ni
s«
TOC
a/8a










LY-1
0.89





0.13



LY-5N
0.0072





0.0055

0.019
31
9/88










LY-1
0.19


0.03


0.053

0.09

LY-2N
0.013

0.021



0.0034

0.018
54
LY-3N
0.021

0.0093
0.19
0.11
0.36
0.0045
0.51


LY-4N
0.02


0.13
0.075
0.17
0.0057
0.34


LY-5N
0.013


0.046

0.076
0.0069
0.13

19
LY-5S
0.069

0.0093
0.12

0.099




11/88




1




LY-2N
0.029


0.03
j
0.0016

0.011
57
LY-5S








31
2/89










LY-2N

0.04







29
LY-4N

0.23


0.097


0.12

33
LY-5N

0.07


0.055




13
3/89










LY-2N

0.16







80
LY-3N










LY-4N

0.24


0.092


0.086


LY-5N

0.14


0.059




15
LY-SS

0.19





0.037


4/89










LY-4N

0.018





0.11

38
LY-SN

0.021








6/89










LY-2N










LY-3N










LY-5N










LY-SS
0.047
0.047

0.013
1

0.29
0.0061

10/89




|

I

LY-3S

0.066


1


10
HBLS
0.05
1
0.001
0.01
0.05 | 0.05
0.002
0.1 | 0.01

•LY-1 is. ibe background iysuaeter

-------
A.TTACHMEFT 2
Soil-Pore Liquids - Organic Constituents (ug/1)

Xylene#
Toluene
Benzene
Styrene
2-Butanone
1,2-Dlcffloroettiane
Etfiytoenzem
9/88







LY-2N
4,200
2,100
1,600
110
14,000
950
2.800
LY-3N
28
6




13
LY-5N

7





11/88







LY-2N
9
5
6




6/89







LY-2N
8
6





LY-3N
5




i
LY-SN
19
6



j
HBLs
10,000
2,000
S
5
2,000
5 1 700
* Organic Constituents have not Been tound in the Background Lysmeter (IY-1)
-------


ATTACHMENT 3



Soil Core
Data from
the BTZ -
LTU Expansion*-*


Bar* i
Boca 1
Boza 2
Bos* 3 Sera 4
Bora 6

(«/29/893
(12/14/89)
(12/13/89)
(12/13/89) (12/13/89!
(12/13/893
pfi (ras«a)
9.1-9.*
8.1-B.2
7.9-8.0
8.1-8.2 7.8-8.0
...
Oil and Qtaaaa Coa*
B) <10
*,590
<10
<10 193
<10
Barylliua
	
o.si/o.«ee
0.5/0.8
0.36/0.** C.57/0.72
2.S/Q.65
Antuaony
	
—
	
	
16.8/32c
Banzasa
13.0
—
	
---
	
Toluae*
13.0
	
	

	
1-Ma thyl&spthalana
—
*.3
	
	
	
Aathracana
—
*.2
	
	
	
Banto(«)Pyr«oa
—
6. J
	
	
...
Mathyl Chrysana
—
*.*
	
	
...
Phanaathraaa
—
2*.0
	
	
...
Th«»« data ar* itmiaxlzod fras thraa t«pin Croa thraa BIZ depths at sack soli borUx: J.0-3.5 :««t;
5.S-*.5 fast; «i«l 4.5-7.S faat. A total of 12 soil born wtr# takas durtn* 1989 in th* LTtJ £*pans»on.
Six earai w«c* celiactad is 3mm 19B9, and tlx ccr»s wti coilactod is Jam 19$9.
Although uaita a*a net spoelttad Is Tabla *-1 of tba gMtitim (V.l, pas* 4-3 through *-:J) .*
assunad that tha data art raportad in ualts of at/k*. "1th th* a*captioo of pB sad ori«nic» 2:itr.,c
eorcantratioaa «•» appaxaatly raportad as *»/k* xs labia *-i aad «ara eoswartad to «¦/*« for
•xhibit.
Th« valuta is this row rapraaaat tha 112 aaac tzem tha thraa dapths, ZaUmmi by tba maxiom	;taa
the thraa BIX dapths,		 	
-------
ATTACHMENT 4
Ground-Water Monitoring Data (ag/1)

TOC
Be
Cd
Ni
Ss
V
AS
Hfl
8/88








LE-O
9.1
aoi4
O.OS7
ait


aoi
0.0007
LE-1
14

0.027
0.12
0.014


0.0006
LE-3
13
0.009

0.055
0.0C66
0.39
0.011
0.0008
LE-4
12



0.0059

0.012
0.0009
LE-5
8.8

0.018
0.12
0.0092
0.28
0.0093
0.001
LE-6
8.9


0.055
0.01S

0.009
0.0008
9/88








LE-O
5.4


0.11




LE-1
&8


&07E




LE-3
48







LE-4
54







LE-5
29


0.078




LE-6
9.8


0.05




1/89








LE-O
&2<


6.17




LE-t
*3


at)63




LE-3
5.1


0.084




LE-4
2.7


0.084




LE-5
2.6


0.15




LE-6
4.4


0.084




3/89








LE-O
1.9




6.029


LE-1





0.044


LE-3





0.044


LE-4





0.057


LE-5
1




0.029


LE-6





0.018


em








LE-O
1J5







LE-t








LE-3
1.3







LE-4
1J







LE-5
1.2







LE-6








12/99








UE-O
¦ • 2.1







LE-t








LE-3
&4







LE-4
1.5


0.073




LE-5
1







LE-6
2.4







HBL

0.001
0.01
0.1
0.01
0.24


bb§
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1991(02)
JAN I 7 1991
Mr. W. Thomas McColiough
Refinery Manager
Sun Refining and Marketing Company
P.O. Box 2039
Tulsa, Oklahoma 74102
Re: No-Migration Petition submitted for Sun Refining and
Marketing Company's Tulsa, Oklahoma Land Treatment Facility
(F-90-NMSP-FFFFF)
Dear Mr. McColiough:
I am writing in regard to your March 16, 1930 "no-migration"
petition, which requests a variance under 40 CFR §268.6 to allow
Sun Refining and Marketing Company (Sun) to continue the land
treatment of restricted wastes at Sun's Tulsa, Oklahoma land
treatment facility (I.TF). After a careful review of your
petition, we have concluded that your facility does not meet the
standard for a no-migration variance. Therefore, we will
recommend to the Assistant Administrator for Solid Waste and
Emergency Response that the petition be denied.
Our decision to recommend denial of the petition is based on
the following concerns:
•	Soil-pore monitoring indicates that benzene has already
migrated beyond the unit boundary.
•	Ground-water monitoring indicates that hazardous
constituents have already migrated beyond the unit
boundary.
•	The required minimum separation between the bottom of
the treatment unit and the top of the seasonally high
water table has not been demonstrated.
•	Air modeling shows concentrations of arsenic at the
unit boundary that exceed the allowable health-based
standard.
The details of our concerns are described below.
-------
Presence of Hazardous Constituents Below the Treatment Zone fBTZ)
Soil-pore liquids monitoring data collected from lysimeter
14 indicate the presence of benzene (33.4 ppb) beneath the
treatment zone at concentrations above the health-based level
(HBL) of 5 ppb used in no-migration decision-making. Sun
explained that during the installation of lysimeter 14 (in March
1987), the borehole had been contaminated by a load of spent jet
fuel filter clay dumped nearby. We, however, question whether
the contamination can be attributed to nearby applied spent jet
fuel filter clay for the following reasons.*
First, it stands to reason that if the borehole were
contaminated during the installation process, then the first-
quarter soil pore-water sample taken between March and April of
1987 should have shown high levels of benzene (which is very
mobile). However, elevated levels showed up only after the
third-quarter samples were taken in October 1987. (No second-
quarter data was provided in the tables.) Thus, the
contamination occurred at a later date rather than during initial
installation.
Secondly, the results from analyses of the spent jet fuel
filter clay reported benzene as "HP" (not present) and the
petition stated that "the other [non-hazardous, including the
spent jet fuel filter clay] wastes, in comparison, are
insignificant in oil/organic content and/or annual quantity
disposed of; the presence of various specific organic compounds
in these wastes would have little or no impact on the overall
soil/waste system at the LTF" (V. 1, pages 4-11 and 4-15).
Therefore, Sun, in one instance claimed that they did not have to
analyze the non-hazardous wastes for organic constituents, yet in
another instance, claimed that the bore hole was contaminated by
the spent jet fuel filter clay.
Lastly, benzene has been detected in both background and
active LTF area lysimeters. (See Attachment I.) The continuous
detection of low levels of benzene, especially at lysimeter 15,
indicate that benzene has migrated below the treatment zone. We,
therefore, believe both that Sun has failed to demonstrate that
the benzene detected at lysimeter 14 is due to contamination and -
that the presence of benzene in the soil-pore liquids clearly
demonstrates that this constituent has migrated below the LTF at
hazardous concentrations.
Ground-Water Monitoring and Detecting Releases at the Earliest
Extent Practicable
As shown in Attachment IZ, ground-water monitoring between
May 1984 and January 1990 indicate that barium, chromium,
mercury, lead, and benzene were detected at concentrations above
their respective health-based levels. Sun claims that these
-------
exceedences are attributable to naturally occurring levels,
laboratory error, or broken product lines manning beneath the
LTF. We believe that Sun has failed to prove conclusively that
the migration did not, in part, result from LTF operations.
Additionally, we believe that Sun has failed to meet the
requirements of 40 CFR 1268.6(a)(4). Specifically, Sun has not
demonstrated that the ground-water monitoring system at the LTF
is capable of detecting (and differentiating) releases at the
earliest extent practicable. Sun's 1990 annual report on ground-
water monitoring (dated July 19, 1990) presented a map showing
three pipelines buried approximately three feet below the ground
surface within the treatment zone of the Central treatment area
of the LTF. These pipelines transport a wide range of petroleum
products from crude oil to gasoline, jet fuel, and diesel. The
map also showed that the downgradient wells of the Central and
West areas are located adjacent to these pipelines. Sun stated
that these pipelines could leak and that several leaks, which
were indeed identified during 1989, could have influenced ground-
water monitoring results, as with MW32 where the concentration of
total organic carbon (TOC) has consistently increased from 20 ppm
in 1986 to 79 ppm in 1988.
The ramifications of the contamination from ruptured product
lines in regard to ground-water monitoring of the LTF are
unclear. Sun has not provided detailed analytical results that
describe the known contamination, nor have they proposed an
adequate plan whereby releases from the LTF can be differentiated
from the known contamination. Because the constituents of a
weathered petroleum product plume would be very similar to a
release from a LTF that contains petroleum wastes ( e.g.,
benzene, toluene, and xylene), it will be difficult to
differentiate between the two releases and therefore, conclude
that Sun's ground-water monitoring system will be able to detect
constituent releases at the earliest extent practicable.
Maintaining Minimum Separation
Federal regulations require that the depth-to-ground water
at land treatment facilities be no less than three feet from the
bottom of the treatment zone to the seasonal high water table (40
CFR 264.271(c)(2)). Based on the discussion below, we do not
believe that Sun has demonstrated that the required minimum
separation is maintained throughout the entire year.
Sun stated that the ground-water table can fluctuate up to
four feet in elevation in a year, and that the seasonal high
water table is more than eight feet below ground surface at the
LTF. Although Sun supported its claim by providing the ground-
water elevation profiles in Exhibits 3.3-1 to 3.3-3 (V.l, pages
3-28 to 3-30), the changes in ground-water table, as reported in
Exhibit 3.3-1* were based on observations recorded in a period
-------
'4-
from 1983 to 1984. We believe that data taken in this relatively
short period is not sufficient to represent the long-term,
temporal variation of the water table beneath the LTF- In
addition, the average depths to ground-water table at MW15 and
MW17 were shown to be 8.2 feet and 8.5 feet, respectively (V.l,
Exhibit 3.3-2, page 3-29). Since Sun has stated that the
potential fluctuations of the water table could be four feet over
the course of a year (or roughly ± two feet from the mean), it is
possible for the water table at these two wells to rise to an
elevation within six feet of the ground surface.
Furthermore, Exhibit 3.3-2 (V.l, page 3-29) presents average
depths to ground water using measurements made in August 1984,
May 1985, and December 1986. As stated above, the depth to
ground water during this period in the East LTF ranges between
8.2 and 8.5 feet. We note, however, that the petition stated
that the ground-water table is at the highest levels during April
- June (V.l, page 3-27). The petition also stated that the level
of the ground-water table fluctuates with rainfall. Because the
greatest amount of precipitation generally occurs during Hay,
June, and September, ground-water table elevation measurements
collected during these three months may show that the minimum
required separation of three feet between the bottom of the
treatment unit and the top of the seasonal high water table is
not maintained (V.l, page 3-33).„
He are also concerned that the aquifer beneath the LTF is
hydraulically linked to the Arkansas River, and the ground-water
table can be further affected by the water level variations in
the river. A 100-year flood could cause "underground flooding"
at the LTF due to its proximity to the river and the moderately
permeable alluvial soils in the unsaturated zone. That is, the
excessive hydraulic head generated outside the levee by flood
waters could reverse the ground-water flow direction and cause
the water table to further rise beneath the LTF. Our concerns
" are supported by Sun's acknowledgment that during heavy flooding
in October of 1986, the Arkansas River level was at the same
elevation as an abandoned waste site adjacent to the West unit
for at least a week, temporarily reversing the ground-water flow.
We, therefore, conclude that the minimum separation between the
treatment zone and the water table is affected by water level
variations occurring in the Arkansas River.
biz flofleUpg Arsenic
Sun performed air modeling to predict the airborne
concentrations of arsenic at the unit boundary. This modeling,
based on historic and projected data, showed that arsenic would
be found at the unit boundary at a concentration of 1.2 x 10*4
#xg/m3 and 1.0 x 10 ftg/m , respectively. Sun compared these
predicted concentrations to a health-based level (KBL) for
arsenic of 2.3 x 10*3 jig/m3 (for inhalation) as reported in Table

-------
9.5-3 of the petition. However, the HBL value cited in the
petition bv Sun is higher than that found in EPA's IRIS database
(7.0 x 10~T nq/wr) . Since both the historic and projected
concentrations modeled for arsenic exceed the HBL of 7.0 x 10
ng/w, Sun has failed to demonstrate that this constituent will
not migrate at hazardous concentrations beyond the unit boundary.
Incomplete Petition
Finally, our review indicates that the petition is
incomplete and that information and clarification in areas beyond
those highlighted above would be needed to complete the petition.
However, because of the problems discussed above, we believe we
have sufficient information at this time to move toward a denial
of your petition.
It is our practice to give petitioners the option of
withdrawing their petitions to avoid a negative publication in
the Federal Register. If you prefer this option, you must send
us a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions. This
letter should be forwarded to the following address within two
weeks of the date of receipt of today's correspondence:
Patricia Cohn, Acting Chief
Assistance Branch (OS-343)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal lesi£££Z.
Any questions regarding our findings may be submitted in
writing to Mr. James Michael of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
Attachments
cc: Patricia Cohn, PSPD, OSW
James Michael, PSPD, OSW
Fenton Rood, Oklahoma State Department of Health
Bill Honker, Region VI
-------
ATTauMENT I
\
toil-Pot* MonitorInf Mher* Benitna mm Detected at tacks rood and Active Area lyalast era
tm«M Coneairtrotlon (ppb)

Background iyslMtcrs


Monitoring Nrlod
W-1 w*s
l*-4
W-li
If-IF
Harch-Aprlt 1967
0.97 It
0.5
0.6
0.8
Cv


Active Area LyalaMtera






Nonltorlna Period
Uf-l IH I*-*
t*-r
ITI
tf-11
1V-H
IV-15
I*-18
March-Apr It 1987
0.8 0.8

o.r


1.2
0.6
J una
1988
33.1
June
1989
4.0


s.o

S.O

August
1989


3.6


2.6

Octototr
1989

4.0



5.0

-------
^	ATTACHMENT I
foil-for* Monitoring tlwr* Imtni mm Datected at tacfcground and HctlM Ant lysfaeter*
•mm Coneant ration (|fb)

Mcfcjrowl
Lyslmtars


Monitoring Parlod
it-i if-§
IT-*
IT-16
lf-1?
March-April 1987
0.97 12
0.5
0.6
0.8


Actlva Arm Lyalaatars






Monitoring Nrlod
lt-I If-S l?-4
If-F
LV-8
lf-11
If* 14
W-W
LT-18
March-April 1987
0.8 0.8

0.7


1.2
0.6
J una
1988
33.4
J una
1989
4.0


3.0

5.0

August
1989


3.6


2.6

Octobar
1989

4.0



5.0

-------
UNITED STATES ENVJROHMEKTAI. PROTcCTiOM AGcNUi
JAN 2 9 f99l
9551.1991(03)
Mr. David R. Chapman
Exxon Research and Engineering Company
P.O. Box 101
Florham Park, NJ 07932-0101
Re: Exxon, Baytown, TX No-Migration Petition (F-91-NMEP-FFFFF)
Dear Mr. Chapman:
At our meeting, September 26, 1990, to discuss EPA's
technical evaluation of the no-migration petition submitted for
the Baytown Refinery's North Landfarm, you requested some
documents and further clarifications of a few issues. In
response, I have enclosed copies of the Federal Register notices
for the §3004(n) rule (June 21, 1990, 55 fS 25454) and the
Benzene NESHAP (March 7, 1990, 55 IB 8292) and provided below
additional information on static fracturing and the use of
indicator chemicals in risk assessment. We are presently
developing information that will address the third issue, metals
mobility, and will provide it to you as soon as it is completed.
Static rgagoring
The term "static fracturing," although not a formal term, is
used to describe the cracking of earthen materials without
significant movement along the crack (plane of failure). It is
used in contrast to dynamic fracturing (e.g., faults) where the
fracture is related to shear or slip along the plane of fracture.
, " The terms are not mutually exclusive as many small fractures with
only slight movement can make up zones of slip (e.g., shear
zones) that are associated with dynamic processes.
Static fracturing in relation to no-migration petitions is
usually limited to shrinkage cracks. Three examples of static
fractures are described below for your information. However, the
first (desiccation cracks) is the only one that would possibly
apply to the Baytown landfarm.
Desiccation cracks - These cracks form as a result of
shrinkage from drying. The simplest example is the
formation of mud cracks. Soils and sediments that contain
expandable clays routinely arpand during rainy pariada and
shrink and araek (f raaififfigf *Smrlng dry pogiedai i Although,
in. host..case ;A. the .frirt^M_eteend...
depth, depenfiincr on tie makeusi of the soil and uhderlvinc

-------
2
sediments, they are reported to exist at depths in the tens
of feet. In areas where montmorillonitic shales weather
from surface soils, desiccation cracks can be exceptionally
deep.
Coolino fractures - These fractures are common in basalts
and are almost characteristic of plateau basalts. Commonly
referred to as "joint sets" or "columnar jointing," fracture
patterns developed in cooled lava, are widespread. These
fractures result from shrinkage in the lava as it cools to
basalt rock, and often penetrate the entire layer.
Tension fractures - Any rock unit subjected to structural
tension may fracture in a direction perpendicular to the
tension. This is very typical of folded units where rock
layers on the outside of the fold undergo tension relative
to rocks along the inside of the fold. Subsequent leaching
by downward movement of surface waters can enlarge
fractures. This is typical of limestone terrains.
Indicator Chemicals in Risk Assessment
EPA's recent guidance - Risk Assessment Guidance for
Superfund - Volume 1: Buman Health Evaluation Manual (Part A)
Interim Final (EPA/540/1-89/002) - defines the indicator chemical
approach in more detail than the 1986 Superfund Public Health
Evaluation Manual, which was used by Exxon in its environmental
risk assessment. The methods used to select indicator chemicals
for a no-migration petition are similar to risk assessments
performed for Superfund sites. However, it appears that Exxon
did not completely apply the Superfund approach. EPA's position
is described below and an example of how this approach could be
applied to the environmental risk assessment in your no-migration
petition is presented.
Most Superfund sites have a few chemicals that are usually
present in concentrations that present much higher risks (i.e.,
three or more orders of magnitude or higher) than the remaining
chemicals at the site. Based on this experience, EPA suggested,
at Superfund sites, that between 5 and 10 chemicals with the
highest individual risk factors would be manageable and possibly ¦
sufficient for a human health risk assessment. The selection of
indicator chemicals is not a process'of selecting a single
chemical to represent each class of chemicals that may be
expected to exhibit similar fate and transport characteristics
and similar toxicities, but rather, it is a process to exclude
from further consideration, those chemicals that are unlikely to
contribute significantly to risk. Use of the Superfund approach
with wastes placed at refinery landfarms may result in a list of
more than S or 10 indicator chemicals, but it is likely to
eliminate from further consideration some of the chemicals that
have been detected in the waste.

-------
3
The selection of indicator chemicals is optional; it is
often prudent to consider all chemicals. If there are clear
reasons to believe that not all chemicals are likely to
contribute significantly to the total risks, the number of
chemicals carried through the risk assessment modeling may be
reduced using a concentration-toxicity screen.
The indicator chemical selection procedure is a quantitative
approach that requires an evaluation of each chemical detected at
concentrations above background levels: specifically, one must
compare the concentration of the chemical in a medium to a
toxicity benchmark for that medium. Other considerations such as
persistence, solubility and bioaccumulation are included in the
final selection of chemicals.
To select indicator chemicals, each chemical is assigned a
score by dividing the concentration (C) of the chemical in a
medium by the toxicity benchmark (TB). The medium may be a
source medium (e.g., applied wastes), or a transport medium
(e.g., surface water), depending on the availability of
measurement data. The source of the toxicity benchmarks are
dependent on the potential receptors (e.g., recommended criteria
values for the protection of freshwater aquatic life can be
calculated from Ambient Water Quality Criteria documents). The
scores are then summed for all chemicals to estimate a "total
risk factor" to serve as an initial screen. After consideration
of other factors (e.g., persistence, bioaccumulation), one may
eliminate from the risk assessment chemicals with C/TB values
that are very low compared with C/TB values for other chemicals
of the same class in that medium. "Very low" may be defined as a
lower limit to the percentage of the total risk factor accounted
for by a single chemical. For Superfund sites, the remedial
project manager may choose a "cutoff" for "very low" of one
percent of the total risk factor screen, or a lower value if the
' site risks are expected to be high.
In the no-migration petition, it appears that Exxon did not
follow the indicator chemical selection approach as described
above. The concentrations of the chemicals in the composite
waste sludge were discussed with qualitative statements about
relative aquatic toxicity of the chemicals rather than comparing
them to numeric toxicity benchmarks. When the appropriate
application of the indicator chemical approach is followed, there
appears to be no justification for Exxon's exclusion of any of
the VOCs and most of the PAHs from further analysis. To assist
Exxon, we have prepared a couple of exhibits applying the
suggested indicator chemical selection approach using the same
organic waste constituents information provided in the risk
assessment section of the no-migration petition. The same
principles also apply to inorganic constituents, but are not
illustrated in the example. Note that Exxon should begin the

-------
4
risk assessment by evaluating comprehensive waste
characterization data from all the wastes applied to the
landfarm, not just the listed hazardous wastes.
Exhibit 1 shows the aquatic toxicity values that are
recommended for the particular organic constituents in the waste
as identified by Exxon in the petition. Please contact EPA if
you need assistance in determining appropriate toxicity benchmark
values for additional chemicals if they are detected in the
waste. Calculations for the indicator chemical selection process
are presented in Exhibit 2. In this exhibit, column 1 is the
reported concentration of the chemical in the composite sludge
waste that Exxon used to select waterbome indicator chemicals
for the no-migration petition? column 2 lists the aquatic
toxicity benchmarks shown in Exhibit 1; and column 3 is the ratio
of waste constituent concentration to the aquatic toxicity
benchmark, or the chemical-specific risk score. The chemical-
specific risk scores are then summed for all chemicals within a
chemical class to estimate a "total risk factor" for the medium
and the chemical class. The chemical classes are evaluated
separately because they are likely to exhibit different fate and
transport characteristics.
Zn this example, if one follows the guidance for Superfund
sites, four chemicals (anthracene, benzo(b)fluoranthene, pyrene,
and fluoranthene) each have a total risk factor of less than one
percent (1%). These chemicals could probably be eliminated from
further consideration if there are no other reasons for retaining
the chemical (e.g., high bioaccumulation potential). However, we
need to stress that the risk assessment report should include a
discussion of each chemical that is eliminated from further
modeling, indicating that other characteristics of the chemical,
such as bioaccumulation and persistence, have been considered.
1 hope this information will be useful in the preparation of
. " Exxon's response to EPA's technical evaluation of the no-
migration petition. If you need additional assistance, please
contact Athena Rodbell of my staff at (202) 382-4519.
Sincerely,
James F. Michael, Chief
Disposal Technology Section (OS-343)
Office of Solid Waste
Attachments (2)
ccs Dave Reeves, PSPD, OSW
Athena Rodbell, PSPD, OSW
Terry Keidan, PSPD, OSW
Howard Finkel, XCF
571
-------
Exhibit 1
Recommended criteria Values for the Protection of Aquatic Life
Chemical
Toxicity Type of Recommended
Value	Value Criterion Rationale
tas/L)	<*s/to
benzene
5,300
EPA
LCso
110
(a)
ethylbenzene
32,000
EPA
LCse
640
(a)
toluene
17,500
EPA
LCso
350
(a)
xylene
3,185
LIT
LC50 t
64
(a)
anthracene



800
(b)
benzo(a)anthracene
1*2
EPA
CC sed
1.2
(c)
benzo(b)fluoranthene
300
EPA
PAH LOEL
60
(d)
benzo(a)pyrene
1.2
EPA
CC sed
1.2
(c)
chrysene
1.2
EPA
CC sed
1.2
(c)
1-methylnapthalene



120
(e)
naphthalene
620
EPA
LOEL
120
(f)
phenanthrene
300
EPA
PAH LOEL
60
(d)
pyrene
300
EPA
PAH LOEL
60
(d)
fluoranthene
3,980
EPA
LOEL
800
(f)
EPA values are those identified in the chemical-specific Ambient
Water Quality Criteria Documents. "CC sed" is EFA's chronic
criterion for PAHs in pore vater of sediments as identified by
Exxon.
(a)	EPA or literature (LIT) LCM value divided by a factor of 10
to extrapolate from an acute to chronic value and a factor
of 5 for variation in species sensitivity.
(b)	Assume toxicity value equal to that of fluoranthene (could
use a more conservative assumption than this).
(c)	EPA chronic criterion for benzo (a) pyrene in water pore of
sediments, as identified by Exxon
(d)	EPA LOEL (Lowest Observable Effect Level) identified for
PAHs in general, divided by a factor of 5 for variation in
species sensitivity.
(e)	Assume toxicity value equal to that of naphthalene.
(f)	EPA LOEL (Lowest Observable Effect Level) divided by a
factor of 5 for variation in species sensitivity.
-------
Exhibit 2
Indicator Chemical Approach Examples for Exxon, Baytown, TX
Constituent
Waste
Concentra-
tion
(at/kt)
[C]
CD
Aquatic
Toxicity
Benchmark
(b»/L)
CTB]
(2)
Chemical
Specific
Risk
Factor
[C/TB]
(3)
Percent of
Total
Risk
(4)
In
-------
UNITED STATES EN VIS OXmEHT AL PROTECTION ACfewcT
JAN 30 1991
9551.1991(04)
Mark J. Lupo, Ph.D.
Manager, Applied Sciences
K. w. Brown & Associates, Inc.
500 Graham Road
College Station, TX 77845
RE: Standards for Air Pathway for Ketals and Organic Chemicals
Dear Dr. Lupo:
We have reviewed Tables 1 and 2 and the information you
provided in your letter of January 11, 1991. In the tables,
three of the columns (TWA, STEL, and Ceiling) are only applicable
to OSHA standards. Although a petitioner does not have to make a
demonstration of no-migration for the short term events, they
must still certify compliance with the OSHA requirement.
Attached are the most current levels for metals in the air phase.
The Health Based Level (HBL) for chromium is based on
hexavalent chromium which is carcinogenic when inhaled. SPA
determines exceedance based on the total volume of chromium using
the hexavalent HBL. Zf BP Oil is to use only the amount of
hexavalent chromium to determine exceedance, they must
substantiate how these values are separated from total chromium.
Also attached are the most current standards for organics in
the air phase. Three of the compounds in Table 2 do not relate
to no-migration and have been deleted. l-Methylnaphthalene and
Indene are not Appendix VIII or IX compounds and 3-Methyl-
cholanthrene, while an Appendix VIII compound, is not on the
Modified Skinner List. These three compounds do not have Health
Based Levels (HBL). Although Benzidine is not on the Modified
Skinner List, it is an Appendix VIII constituent and has a HBL
, "• and is therefore included in the attachment.
Sincerely,
cc: Terry Keiden, AB, OSW
Athena Rodbell, AB, OSW
Newman Smith
Disposal Technology Section
Office of Solid Waste

-------
UNITED STATES fcNViROuacHl al. r^KOl fcCTiON A&fcNWJ
9551.1991(05)
FEB - 5 1991
Mr. Gregg L. Lorimor
Refinery Manager
Kerr-McGee Refining Company
P.O. BOX 305
Wynnewood, Oklahoma 73098
Re: No-Migration Petition submitted for Kerr-McGee Refining
Company's Wynnewood, Oklahoma Land Treatment Facility
(F-91-NWOP-FFFFF)
Dear Mr. Lorimor:
I am writing in regard to your June 22, 1990 "no-migration"
petition, which requests a variance under 40 CFR §268.6 to allow
Kerr-McGee Refining Company (KMRC) to continue the land treatment
of restricted wastes at KMRC's Wynnewood, Oklahoma land treatment
facility (LTF). After a careful review of your petition, we have
concluded that your facility does not meet the standard for a no-
migration variance. Therefore, we will recommend to the
Assistant Administrator for Solid Waste and Emergency Response
that the petition be denied.
Our decision to recommend denial of the petition is based on
the following concerns:
•	Soil-pore monitoring indicates that hazardous
constituents have already migrated beyond the unit
boundary;
•	The ground-water monitoring system is inadequate for
the purpose of a no-migration variance, because it will
be unable to detect constituent migration at the
earliest time practicable; and,
•	The required minimum separation between the bottom of
the treatment unit and the top of the seasonally high
water table has not been demonstrated.
We discuss our concerns below.
-------
Presence of Hazardous Constituents Below the Treatment Zone fBT2)
Soil-pore liquids monitoring data collected from the active
LTF and from the land treatment demonstration (LTD) plot indicate
that constituents have already migrated beyond the unit boundary
at hazardous concentrations. As shown in Attachment 1, soil-
pore monitoring data collected during the LTD (November, 1988 -
February, 1989) indicate that antimony, arsenic, barium, benzene,
and 2,4-dimethylphenol were detected at concentrations in excess
of their respective health-based levels. Additionally, as shown
by Attachment 2, soil-pore monitoring data collected from the LTF
between December 8, 1983 and November 12, 1986 indicate that lead
has migrated beyond the unit boundary at hazardous concentrations
above the health-based level (0.05 mg/1). We, therefore,
conclude that the presence of these constituents in the soil-
pore liquids clearly demonstrates that these contaminants have
already migrated below the LTF at hazardous concentrations.
Ground-Water Monitoring Data and Detecting Releases at the
Earliest Time Practicable
As shown by Attachment 3, benzene was detected in shallow
well IMW-5-0 at concentrations exceeding the health-based level
of 0.005 mg/1 during four ground-water sampling events between
February and November, 1989. KMRC claims that the benzene
detected in this well was attributable to a soil-core sampling
event in January, 1989, when LTD soil-core samples were augered
through nine inches of standing water (precipitation). KMRC
states that this enabled water to run down the boreholes,
carrying hazardous constituents to a depth of at least 5.5 feet
below the surface. However, KMRC has failed to prove
conclusively that the soil-core sampling event is directly
related to the presence of benzene in shallow well LMW-5-0. For
example, the benzene levels found in the sampling events have
fluctuated (0.310 mg/1 in February, 1989; 0.130 mg/1 in May,
1989; 0.240 mg/1 in August, 1989; and, 0.130 mg/1 in November,
1989). If the soil-core sampling event was directly related to
the presence of benzene in the shallow well, it would stand to
reason that the benzene concentrations would have peaked, then
tapered off. However, since the benzene concentration has
fluctuated, we have concluded that the operations at the LTF are -
contributing to the to the presence of benzene in shallow well
IMW-5-0.
Additionally we believe that KMRC has failed to meet the
requirements of 40 CFR 1268.6(a)(4). Specifically, KMRC has not
demonstrated that the ground-water monitoring system at the LTF
is capable of detecting (and differentiating) releases at the
earliest extent practicable.
KMRG's current ground-water monitoring system consists of
seven pairs of wells, each pair consisting of a shallow well
570>
-------
(indicated by a "-O" suffix) and a deep well. Free hydrocarbon
products were detected in the ground water at LWM-1 during the
first sampling event on November 17, 1981 (LMK-6 replaced LMW-1
in 1984). According to KMRC, this was the first indication of
the existence of a liquid hydrocarbon plume on the refinery
property. Ground-water monitoring between November 1988 and
November 1989 at deep wells LMW-2, LMW-4, UfW-5, LMW-6, and RW-2
indicated the presence of benzene above health-based levels,
which KMRC attributed to impacts from the hydrocarbon plume.
We believe that the locations of the monitoring wells are
generally adequate, provided that the local ground-water flow
pattern will not change in the future. However, given the
proposed free oil recovery and ground-water remediation to be
carried out in the next few years by KMRC, the local
hydrogeologic regime may be drastically altered because of the
hydraulic drawdown (to remove free products) in the currently
upgradient processing area. In response to the planned
remediation activities, some of the upgradient wells may become
temporarily downgradient (e.g., RW-2 and RW-2-0) to those wells
that are currently downgradient.
Lastly, the ramifications of the contamination resulting
from the underlying hydrocarbon plume in regard to ground-water
monitoring of the LTF are unclear. KMRC has not provided
detailed analytical results that describe the extent of the known
contamination beneath the LTF and KMRC is relying on the shallow
wells to differentiate between releases from the LTF and the
underlying hydrocarbon plume. Shallow well LMW-5-0, however, is
already contaminated with benzene. We, therefore, believe that
KMRC will be unable to differentiate between the two releases and
therefore, conclude that the ground-water monitoring system will
not be able to detect constituent releases at the earliest extent
practicable.
- Maintaining Minimum separation
Federal regulations require that the depth-to-ground water
at land treatment facilities be no less than three feet from the
bottom of the treatment zone to the seasonal high water table
(see 40 CFR 264.271(c)(2)). Based on the discussion below, we
have concluded that KMRC has not demonstrated that the required
minimum separation of three feet between the bottom of the
treatment unit and the top of the seasonally high water table is
consistently maintained.
KMRC stated that during the LTD in 1988-89, the water table
beneath the LTF averaged from 9.2 to 11.9 feet, with seasonal
fluctuations ranging from 1.22 to 1.82 feet. Given this range,
the water table can rise to 7.38 feet of the surface, or 2.88
feet below the treatment zone. Historically, however, the water
table at the LTF has shown much more fluctuation than observed
571
-------
during the LTD, In June, 1985, a depth of 4.92 feet was recorded
at well KW—1, and in March, 1987, depths of 5.03, 5.82, and 6.01
feet were recorded at I2W-3, LMW-6, and IHK-2, respectively (Part
B Permit Application, pages £-38 to E-41). These data indicate
that fluctuations ranging from 0.42 to 1.51 feet of separation
between the treatment zone (4.5 feet deep) and the water table
have occurred, showing that the required three foot separation is
not maintained.
In
-------
Terry Keidan, AB, PSPD, OSW
Jeffrey Gaines, AB, PSPD, OSW
Dave Reeves, AB, PSPD, OSW
Richard Kinch, WKD, OSW
Katby Stein, OE
Nikki Roy, WMD, OSW
Howard FinJcel, ICF Incorporated
-------
ATTACHKEST 1
Summary of Soil-Pore Liquids Monitoring Data
For Constituents Detected Above Health-Based Levels (mg/lj
(Data from LTD Final Report, Appendix C)
Sampling Lysimeter	Health-Based
Constituents Dates Numbers Concentrations Levels
Antimony 1/
11/88
3
0.036
0.01
Arsenic 1/
11/88
3
0.06
0.05
Barium 1/
11/88
3
1.7
1.0
Benzene
11/88
2
1.3
0.005


3
2.3


01/89
3
2.1



4
0.014


02/89
2
1.5



4
0.32



bkgrad
0.011


04/89
2
2.6



4
0.36


07/89
1
0.71



4
0.42


08/89
4
0.43

2,4-Dimethyl




Phenol
11/88
2
0.044
0.02

04/89
2
0.029

2J Analyses for inorganics only performed on 11/88 samples
due to limited volume of soil-pore liquids collected
during subsequent sampling events.
-------
ATTACHMENT 2
Summary of Soil-Pore Liquids Monitoring Data
For Constituents Detected Above Health-Based Levels (mg/1)
(Data from LTF, Recon. Report, Table 3-4)
Constituents
Sampling Lysimeter	Health-Based
Dates Numbers Concentrations Levels
Chromium
06/05/84 1 (bkgrad)
2
06/12/85
05/16/86
3
4
2
2
5
0,
0.
0,
0,
0.
0,
0.
2
05
16
05
08
07
05
0.05
Lead
12/08/83
2
4
5
05/16/86 1 (bkgrad)
2
3
4
5
11/12/86 1 (bkgrad)
3
0.19
0.18
0.14
0.29
0.45
0.5
0.37
0.4
0.06
0.05
0.09
0.05

-------
ATTACHKZMT 3
8xiammry of Ground-Water Monitoring Data For Benzene Found
at Concentrations Above tbe Healtb-Based Level*
Concentration (a«/l)
DowvradKant Hells	Upgradient Hells
Date	UW-3 UU-3*0 LNI-4 UV-4-O Ui)-5 L*<-5-0 Bt-1 BM-0 UW-2 UV-2-0 LUM-6 UM-6-0 RV-2 RW-2-O
Nov.,
1988
LDb
LB
0.049
LS6
0.056
LB
tfi
LD
0.034
LD
0.049
LD
0.500
10
Feb.,
1989
LO
LD
0.033
ID
0.036
0.310
LS
LD
0.0047
LO
0.022
LD
0.150
IS
May,
1989
LS
LD
0.0073
ID
0.064
0.130
LS
LD
0.0061
LO
0.023
LD
0.180
10
Aug. i
1989
LS
ID
IS
ID
0.023
0.240
LS
LS
LD
LD
0.025
LD
0.220
.<*
NOV.,
1989
U)
LS
0.018
LD
0.140
0.130
U>
LD
ID
LO
0.017
LO
0.190
LO
Footnot*:
t. The currant health based level for benzene ft 0.005 ag/L.
b.	"LB* Mam a concentration loner than the detection Halt.
c.	"IS" scans a concentration greater than the detection I fait but less than the drinking inter standard.
d.	aasra data Has not svai labia.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1991(06)
APR 22 !99f
Mr. J. R. Mclntire
Refinery Manager
Atlantic Refining & Marketing Company Corporation
3144 Passyunk Avenue
Philadelphia, Pennsylvania 19145
Re: No-Migration Petition submitted for Atlantic Refining &
Marketing Company Corporation's Philadelphia, Pennsylvania
Land Treatment Facility (F-91-NARP-FFFFF)
Dear Mr. Mclntire:
1 am writing in regard to your May 16, 1990 "no-migration"
petition, which requests a variance under 40 CFR §268.6 to allow
Atlantic to continue the land treatment of restricted wastes at the
Philadelphia, Pennsylvania land treatment facility (LTF). After a
careful review of your petition, we have identified three major
technical problems. These are:
Evidence of releases from the LTF in excess of health-
based levels;
Inadequate ground-water and soil-pore monitoring systems
for no-migration purposes? and,
Apparent non-compliance with other regulatory
requirements.
Therefore, we have concluded that the Atlantic facility does not
meet the standard set by the statute for a no-migration variance.
We will, therefore, recommend to the Assistant Administrator for
Solid Waste and Emergency Response that a no-migration variance for
Atlantic be denied.
Each of the major technical deficiencies identified from our
^ evaluation of your petition is discussed in detail below. Any
questions concerning any of our technical analyses and findings may
be submitted in writing to Mr. James Michael of my staff.
Presence of Hazardous Constituents in the Ground-Water
Atlantic states that "ground-water will not be used for. the
purposes of no-migration" (Vol.1, section 5.3.1.2.2, page 138), and
no quantitative analysis of ground-water was provided in the
petition. Therefore, in order to conduct a complete evaluation of
51)3
-------
2
Atlantic's no-migration petition, we sought ground-water data from
the Pennsylvania Department of Environmental Resources (PADER).
Hazardous constituents above health-based levels were detected
in the 1987 and 1990 sampling events. Specifically, in 1987,
PADER detected benzene, chlorobenzene, 1,4-dichlorobenzene, and
ethyl benzene above their respective health-based levels in the
downgradient monitoring wells. In 1990, PADER again detected
ben2ene and 1,4-dichlorobenzene above their respective health-based
levels in the downgradient monitoring wells (see Table 1).
TABLE 1 - GROUND-WATER CONTAMINATION
HAZARDOUS
CONSTITUENT
(mg/1)
HEALTH-BASED
LEVEL
(®g/l)
1987: MAXIMUM
CONCENTRATION
DETECTED
(W9/1)
1990: MAXIMUM
CONCENTRATION
DETECTED
(mg/1)
is WTTmrp
o£r% ZEtNE
0.005
3.652
2.990
CHLOROBENZENE
0.100
0.675

1,4-
DICHLOROBENZENE
0.075
0.425
0.140
ETHYL BENZENE
0.700
1.825

Although Atlantic argues that the underlying ground-water has
been contaminated from other pre-existing sources, Atlantic's
petition has failed to demonstrate that the existing ground-water
contamination did not result, even in part, from LTF operations.
A comparison of PADER data for the LTF's upgradient and
^.downgradient wells shows in all cases that concentrations of
- " hazardous constituents in the downgradient monitoring wells exceed
the concentrations of the same constituents, if detected at all, in
the upgradient monitoring well. This indicates to us that
migration has already occurred that may be attributable to the
wastes in the LTF unit and not the hydrocarbon plume underlying the
general area where the LTF is located. Furthermore, we do not
believe that Atlantic's ground-water monitoring system is capable
of differentiating the source of the constituents already detected
(see discussion below). As a result, we cannot definitively
conclude that the contamination which is already evident is not due
to migration of constituents from the LTF unit. This finding is
PADER performed only a qualitative analysis of organic
constituents in 1988, and did not perform any analyses for organic
constituents in 1989.
5%lT
-------
necessary to satisfy the no-migration standard for land disposal of
restricted hazardous wastes.
Presence of Hazardous Constituents in the Soil-Pore Liquids
We understand that the LTF is divided into eight plots, A-H,
with one lysimeter located on each plot, and that Atlantic has not
applied wastes to plots G and H since 1985. The RCRA Permit
specifies that Atlantic should conduct soil-pore monitoring for
each plot on a semi-annual basis for the principal hazardous
constituents (PHC's) identified, which include volatile and semi-
volatile organics and inorganics. In contrast to this requirement,
Atlantic's petition included soil-pore monitoring data from only a
few plots. Specifically, soil-pore liquid samples were collected
from only three plots in April 1989, four plots in July 1989, and
three plots in October 1989. Moreover, even though plot H has been
inactive since 1985, only the soil-pore liquids collected from plot
H were analyzed for the inorganic indicator constituents. These
limited data showed that benzene was detected above the health-
based level of 0.005 mg/1 (see Table 2). The instances of benzene
in the soil pore liquids above the health-based level indicates
that this contaminant has migrated below the LTF at concentrations
considered hazardous by EPA.
Furthermore, because the soil-pore monitoring data provided by
Atlantic are so limited, we consider them insufficient to
demonstrate, to a reasonable degree of certainty, that inorganic
and other organic constituents have not migrated from the LTF.
TABLE 2 - SOIL-PORE CONTAMINATION OF BENZENE (ag/1)

5/21/89
7/19/89
10/24/89
PLOT H
0.013
0.010
0.007
Health-
based level
0.005 mg/1
Detecting Releases at the Earliest Practicable Time
In its petition, Atlantic has not demonstrated that the
ground-water and soil-pore monitoring systems at the land treatment
facility (LTF) are capable of detecting releases from the LTF at
the earliest practicable time, as is required by 40 CFR
§268.6(a)(4). Of particular concern is the inability to clearly
differentiate between past and present releases.
-------
4
Ground-Water Monitoring System
Atlantic stated that it developed its ground-water detection
monitoring program "in light of well-documented, pre-existing
ground-vater contamination associated with the general area where
the LTP is located" (Vol. 1, section 6, page 55). We note that
during the 1989 and 1990 compliance monitoring evaluation (CME)
inspections, approximately three feet of standing oil was observed
in the downgradient monitoring well (W6), preventing collection of
ground-water samples with a three foot bailer. In addition, older
CME monitoring results indicated the presence of significant levels
of contamination, particularly total organic carbon (TOC) in the
underlying ground-water, up to 98,000 mg/1.
Although Atlantic attributes this contamination to pre-
existing site conditions and argues the LTF has not affected
ground-water quality, we are not aware of any assessment monitoring
program conducted by Atlantic during interim status, nor did the
petition describe any facility attempt to locate the sources of the
ground-water contamination. In addition, the constituents of a
weathered petroleum product plume would be very similar to those
detected in a release from your LTF managing wastes from petroleum
refining activities. Clear differentiation between the sources of
releases is necessary to support a finding of no-migration.
However, your petition does not provide this level of certainty.
In order to determine whether migration of hazardous
constituents has occurred, Atlantic plans to perform a trend
analysis on each of the constituents detected in the ground water.
We believe, however, that the elevated levels of constituents
contributed by the "free-product plume" will mask all but massive
releases from the LTF. We are concerned that, Atlantic intends to
rely on a significant increase in the concentrations of the
volatile aromatic organic indicator compounds to provide early
detection of migrating hazardous constituents. For the purposes of
- " no-migration, we require petitioners to clearly demonstrate that
their facility is not contributing contaminants at concentrations
in excess of the applicable health-based levels. We do not believe
that a trend analysis will enable Atlantic to identify releases at
low concentrations which are frequently used as health-based levels
(e.g., 0.005 mg/1 of benzene). We, therefore, conclude that
Atlantic's ground-water monitoring system is inadequate for the
purposes of detecting constituent releases from the LTF at the
earliest practicable time.
Soil~Pore Liquids Monitoring System
Similarly, Atlantic has not demonstrated that its soil-pore
monitoring program will allow for the detection of constituent
migration at the earliest practicable time.
6%(*
-------
5
Atlantic's soil-pore monitoring program does not appear to
adequately monitor the effect of accumulated waste on localized
migration of hazardous constituents (i.e., hot-spots). Atlantic's
petition indicated that it dumps wastes at the access ramps of each
plot and does not distribute these on the plots until several loads
have accumulated. The wastes spread over the plot may not be
evenly distributed, as evidenced by the "long-term accumulation of
treated waste residues in the proximity of waste off-loading ramps"
(App.l, page LTP-18). The placement of the lysimeters was chosen
using a random number approach and are not placed near the access
ramps where the wastes are placed. It is, therefore, likely for
hot-spots to exist within the LTF, for which Atlantic's soil-pore
monitoring program does not adequately account.
Second, in the petition, Atlantic described the physical and
chemical consistency of the soils as being highly variable over
short distances. We believe that the physical heterogeneity of
soil texture in the lower treatment zone (LTZ), as described, may
establish pathways of reduced resistance to migration of hazardous
constituents. We expect these pathways of reduced resistance to
"short-circuit" the land treatment processes and facilitate the
migration of hazardous constituents below the treatment zone. In
addition, if slag, ash, bricks, large chunks of concrete, wood
timbers, wires, and construction debris are present within the LTF,
as the petition states, we are concerned that these materials also
will form pathways of reduced resistance to soil water flow, or
themselves be a source contributing hazardous constituents.
Neither Atlantic's placement of lysimeters, nor its predictive
computer modeling, accounted for the potential effects of such soil
variability or foreign material on the physical and chemical
processes within the treatment zone. We conclude, therefore, that
Atlantic's soil-pore monitoring system is not capable of detecting
constituent migration at the earliest practicable time.
' " Maintaining Minimum Separation
Federal regulations require that the depth-to-ground water at
land treatment facilities should be at least three feet from the
bottom of the treatment zone to the seasonal high water table (see
40 CFR 264.271(c) (2)). Specific depth-to-ground-water measurements
beneath the LTF have not been provided in this petition. However,
based upon topographic maps provided by Atlantic, it appears that
most of the Atlantic's LTF is at an elevation of about 20 feet
above sea level. In addition, seven to thirteen feet above sea
level was cited as the water table elevation range (Vol.1, section
4.5.1, page 4-21), therefore, we estimated the depth of the water
table as also being between seven and thirteen feet below ground
surface. This estimate indicates that portions of the LTF may not
be three feet above the seasonal high water table as is required by
40 CFR 1264.271(C)(2).
ill
-------
6
In addition, Pennsylvania State regulations define the
seasonal high water table as "the presence of mottling" (see 25
Pa.Code §75.264 (u) (5)). As is shown by Attachment I, mottles were
reported at various depths within the LTF. The presence of mottles
in the LTF indicates that there may be an insufficient separation
between the LTZ and upper saturated zone (i.e., the presence of
saturated soil conditions). We believe, therefore, that the
presence of mottles within the LTF soils further supports our
determination that Atlantic has failed to demonstrate compliance
with 40 CFR 1264.271(c)(2).
Incomplete Petition
Finally, our review indicates that the petition is incomplete
and that information and clarification in areas beyond those
highlighted above would be needed to complete the petition.
However, because of the problems discussed above, we believe we
have sufficient information at this time to move toward a denial of
your petition.
It is our practice to give petitioners the option of
withdrawing their petitions to avoid a negative publication in the
Federal Register. If you prefer this option, you must send us a
letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions. This letter
should be forwarded to the following address within two weeks of
the date of receipt of today's correspondence:
Elizabeth Cotsworth, Chief
Assistance Branch (0S-343)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.c. 20460
If you choose not to withdraw your petition, we will recommend
that a proposed denial decision be published in the Federal
Register.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
5^
-------
7
cc: Elizabeth Cotsvorth, PSPD, OSW
James Michael, PSPD, OSW
Paul Gotthold, Region III
Hon Lee, Region III
Larry Lunsk, PA DER

-------
8
bcc: Terry Keidan, AB, PSPD, OSW
Allyson Ugarte, AB, PSPD, OSW
Dave Reeves, AB, PSPD, OSW
Kathy Stein, OE
Bill Kline, WMD, OSW
Douglas Donor, Region III
Howard Finkel, ICF Incorporated

-------
ATTACHMENT I
Depth to Uppermost Occurrence of Mottles (inches)
Plot
Horizon
Depth
BTZ
Separation
A
2F1
37-48
37
None
B
2F
39-51
39
None
C
2012
11-40
40
None
D
2F2
35-44
28 "
7
1
Z0I2
10-35
35
None
F
Z0I2
10-38
38
None
G
2F1
28-32
28
None
H
4F3
48-53
28
20
Background
F1
0-28


Note: BTZ is the depth to the control area (clean
fill zone)
Source; App-3, Attachment 5-2

-------
<10 sw
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9551.1991(07)
y4V»y	WASHINGTON. D.C. 20460
•~D 'J O	'	0"ICE OF
AlT\ L O	SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Applicability of the Land Disposal Restrictions to Exported Wastes
FROM: Sylvia K. Lowrance,
Office of Solid Waste

TO:	Gerald M. Levy, Chief
MA Waste Management Branch
Region I
This memorandum responds to your March 8, 1991, request for clarification
concerning the applicability of the Part 268 Land Disposal Restrictions (LDR) program
to wastes to be exported for treatment and/or recovery; in particular, the testing and
recordkeeping requirements of Part 268.7.
	 The requirements of Part 268 are applicable to hazardous wastes (as stated at 40
CFR 268.1(b)) unless specifically provided otherwise in Part 261 or Part 268. Neither
Part 261 nor Part 268 genetically exclude the export of hazardous wastes from the LDR
requirements. Therefore, the requirements of Part 268.7(a) are applicable. However,
this is not meant to imply that the treatment standards must be met prior to disposal in
another country.
As a secondary matter, the description "corrosive, metal-containing wastes" used
in your March 8, 1991 correspondence is insufficient to make a determination regarding
the regulatory status of the secondary material when destined for reclamation.
Specifically, as presented in Table 1 of Part 261.2, a characteristic by-product or sludge
that is reclaimed is not a solid waste (and therefore not subject to the part 268
requirements); however, a characteristic spent material that is reclaimed is a solid waste
(and therefore must comply with the Part 268 requirements). In addition, scrap metal
that is hazardous solely due to a characteristic is not subject to the LDR Part 268
paperwork requirements (See 40 CFR 261.6(a)(3)(B)(iv)).
Should you have further questions, or need more information, please contact
Charles Hunt, of my staff, at FTS 475-8551.
iffi) Printed on Recyciea
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1991(08)
MAY 2 S
Mr. Glenn A. Weiss
Refinery Manager
Texaco USA
Puget Sound Plant
P.O. Box 622
Anacortes, Washington 98221
Re: No-Migration Petition submitted for Texaco's Anacortes,
Washington Land Treatment Facility (F-91-NTAP-FFFFF)
Dear Mr. Weiss:
I am writing in regard to your May 18, 1990 "no-migration"
petition, which requests a variance under 40 CFR §268.6 to allow
Texaco to continue the land treatment of restricted wastes at its
Anacortes, Washington land treatment facility (LTF). After a
careful review of your petition, we have identified three major
technical problems. These are:
*	Evidence of releases from the LTF in excess of health-
based levels;
Inadequate ground-water monitoring system for purposes
of no-migration; and,
*	Apparent non-compliance with other regulatory
requirements.
Based on these technical deficiencies, we have concluded
that the Texaco facility does not meet the standard set by the
statute for a no-migration variance. We will, therefore,
recommend to the Assistant Administrator for Solid Waste and
Emergency Response that a no-migration variance for Texaco be
denied.
Each of the major technical deficiencies identified from our
evaluation of your petition is discussed in detail below. Any
questions concerning any of our technical analyses and findings
may be submitted in writing to James Michael of my staff.
Presence of Hazardous Constituents Below the Treatment Zone
Our review of Texaco"s 1988 soil-pore monitoring data for
the LTF indicate that chromium, benzene and nickel have already
migrated beyond the unit boundary above their respective health-
based levels (HBLs). See Table 1.
-------
TABLE 1 - EVIDENCE OF MIGRATION BEYOND UNIT BOUNDARY
HAZARDOUS
CONSTITUENT
HEALTH-BASED
level
1988; MAXIMUM
CONCENTRATION
DETECTED
BENZENE
0.005 mg/1
0.019 mg/1
NICKEL
0.01 mg/1
0.263 mg/1
CHROMIUM
0.01 mg/1
0.121 mg/1
Furthermore, the analysis of soil core monitoring data
collected in 1989 indicates that benzo(a)-anthracene,
benzo(a)pyrene, and benzo(b)fluoranthene were detected below the
treatment unit in excess of their respective HBLs. See Table 2.
In addition, chrysene, fluoranthene, naphthalene, 1-methyl-
naphthalene, phenanthrene, and pyrene were detected in the soil
cores at statistically significant concentrations. Although the
concentrations detected do not exceed HBLs, statistically
significant concentrations below the treatment zone indicate that
these constituents are migrating and further add to our concern
(see Attachment 1).
TABLE 2 - EVIDENCE OF MIGRATION BEYOND UNIT BOUNDARY
HAZARDOUS
CONSTITUENTS
HEALTH-BASED
LEVELS
LYSIMETER
SAMPLE DATE
AND NUMBER
1989: MAXIMUM
CONCENTRATION
DETECTED
BENZO(A)
ANTHRACENE
0.055 mg/1
Jun/89
1.361 mg/1


Oct/89
0.993 mg/1
BENZO(A)
PYRENE
0.055 mg/1
Jun/89
0.454 mg/1


Oct/89
0.310 mg/1
BENZO(B)
FLUORANTHENE
0.055 mg/1
Jim/89
0.784 mg/1


Oct/89
1.676 mg/1
-------
3
Another indication of the migration of hazardous waste
constituents is the increase in the concentration of total
organic carbon (TOC) at the base of the treatment zone.
Attachment 2 shows the concentrations of TOC in samples collected
from the 1988 lysimeter monitoring events. The average
concentration of the background lysimeter samples in plot BG-SE
is 13 mg/1. A significant increase in TOC concentration is
considered to be the average background value plus two standard
deviations, or 27 mg/1. As can be seen from Attachment 2, the
average concentration of TOC detected from the 1988 lysimeter
system exceeds the significance level of 27 mg/1. These data
indicate to us that the LTF is not successfully degrading or
immobilizing all wastes and further support our conclusion that
the migration of hazardous constituents is occurring.
In the petition (Section 1, page 5) , Texaco attributes
the detection of constituents at the base of the treatment zone
in the West LTF (WLTF) plot #8 to wastes buried during the
terracing of the plot. There is no explanation in the petition
of how this could occur. Lacking this explanatory information,
we cannot evaluate your statement, particularly since the plot
is situated in a relatively flat area, only portions of the
surface layer were modified, and buried wastes are located 7.5
feet below the surface of the plot (i.e.. plot #8 would have
required very little cut and fill). Furthermore, Texaco*s
petition did not explain the presence of hazardous constituents
detected in the other plots, such as plot #9, also in the WLTF
(see Attachment 2).
Detecting Releases at the Earliest Practicable Time
In its petition, Texaco has not demonstrated that the
ground-water system at the land treatment facility (LTF) is
capable of detecting releases at the earliest practicable time,
as is required by 40 CFR §268.6(a)(4).
According to the petition, the depth to ground water is too
great to deem it an important factor in determining subsurface
contaminant migration (Volume 1, Table Exec-1). Texaco based
this conclusion on the historic absence of contaminants in
ground-water monitoring samples. Consequently, Texaco does not
recommend monitoring of the primary aquifer. The petition
indicated elsewhere, however, that perched water tables are
present at the facility and that saturated conditions are present
through most of the geologic units. Based on this facility
description, we consider ground-water monitoring to be important
for the purposes of a no-migration variance for the LTF.
Based on our evaluation of some of the features of Texaco's
ground-water monitoring system, we believe this system is
inadequate for early detection of migration because of well
screen location. Attachment 3 illustrates well-screen position

-------
4
for twenty monitoring wells at the East and West LTFs, nine of
which are down-gradient wells. Of those nine, six are screened
between six and twenty one feet below the top of the water table
making it possible for a shallow plume to be missed by
monitoring. In addition, as illustrated in Attachment 3, two
monitoring wells have been screened over an interval that does
not intercept ground water, and well 17 is screened above the
ground-water depth.
Maintaining Minimum Separation
Federal regulations require that the depth-to-ground water
at land treatment facilities should be at least three feet from
the bottom of the treatment zone to the seasonal high water table
(see 40 CFR §264.271 (c)(2)). We believe that Texaco has failed
to demonstrate that either the West or East Field of Texaco's LTF
has successfully maintained this minimum separation.
Unfortunately, the petition did not present a comprehensive
data set showing depths to the water table. Attachment 4,
however, displays that a sufficient amount of data was compiled
from the no-migration petition to indicate that a water table
exists within three feet of the treatment zone in the East LTF
(ELTF). If an accumulated waste layer is assumed, we estimate
the minimum acceptable -depth to the seasonal high water table to
be 9.5 to 11.5 feet below the soil surface (depending on waste
accumulation). Attachment 4 shows that at the ELTF, a separation
in that range occurs infrequently in any piezometer or monitoring
well.
Texaco indicates that the observed "perched" water table is
seasonal and confined to a shallow surface soil layer (App. I,
Vol.5, pages XIX-27 and XIX-32). Texaco, therefore, does not
consider this to be a perched water table, but rather a temporary
condition of excessive soil wetness. Texaco further associates
' "high water table readings with leakage around the piezometer
casing allowing surface water to enter the piezometers (App. I,
Vol.5, page XIX-38). Only two of the five piezometers tested,
however, showed any immediate response to a rainfall event. The
data shown in Attachment 4 indicate that this condition persists
throughout the year with slight fluctuations in level. The
hydrology section of Texaco's permit application also indicates
that saturated conditions appear continuous through zone E
(App.I, Vol.3, page XV-20) and are not restricted to a shallow
surface layer. We, therefore, do not believe that the data
support a zone of restricted downward flow. Instead, we conclude
that the data support the existence of a perched water table and
that continuous saturated conditions exist throughout the
treatment zone, particularly at the ELTF.
=-9 *
-------
5
Data supplied with the petition does not indicate that
sufficient depth to the water table exists under the West LTF
(WLTF). In fact, mottling, indicating saturated soil conditions,
was reported in the WLTF soil descriptions in all profiles and
within 9 to 34 inches from the soil surface (Sec.4, page 8).
Saturated conditions in the WLTF surface layer is also reported
in the hydrology section of the permit application (App.I, Vol.3,
page XV-35). In light of this information, Texaco did not
provide sufficient piezometric data for the WLTF to substantiate
that depth to the seasonal high water table meets the
requirements. Therefore, in regard to both the ELTF and WLTF,
the minimum separation required by 40 CFR 1264.271(c) is not
being maintained. This is a deficiency that precludes granting a
no-migration variance to the facility.
Incomplete Petition
Finally, our review indicates that the petition is
incomplete and that information and clarification in areas beyond
those highlighted above would be needed to complete the petition.
However, because of the technical nature of the problems
discussed above, we believe a technical basis already exists that
is sufficient to support a denial of your petition.
It is our policy to give petitioners the option of
withdrawing their petitions to avoid a negative publication in
the Federal Register. If you prefer this option, please send us
a letter withdrawing your petition and acknowledging that the
petitioned wastes are still considered to be restricted wastes
subject to the Third Third Land Disposal prohibitions. This
letter should be forwarded to the following address within two
weeks of the date of receipt of today's correspondence:
Elizabeth Cotsworth, Chief
Assistance Branch (OS-343)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.c. 20460
If you choose not to withdraw your petition, we will
recommend that a proposed denial decision be published in the
Federal Register.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste

-------
XTTXCHKZOT 1
Suamary of Significant BTZ Soil-Core Detections (^g/kg)
Jun » Jui 89 Oct 89 Oct 89 HMlth-
Comtftuant/Het	 < 	8 Dm	9	9 Pup	ta! iMto
Mnxo(«)Anthracarw
1361.4
1464.5
1464.5
993.4
55
t««o(a>Pyrcn*
660.1
453.8
453.8
310.4
55
Mra»
-------
ATTACH* 2
TOC Concentrations in Samples Collected
From the 1988 Lysimeter System (mg/1)
Plot
PCtJP
11/3/88
GBRICK
PCTJP
12/21/88
GBRXCK
AVERAGE
1
32
44
53
57
46
3
70
91
101
96
89
4
47
75
115
102
85
6E
82
15
106
61
66
6EC
23
28
81
79
53
6W
256
261
185
203
226
7
114
189
190
236
182
8
384
348
293
289
329
9

287


287
10W
168
248
116
194
182
11
58
47
142
60
77
BG-SE
6
24
12
19
13
BG-Tl

18
4
5
9
BG+2STD




27

-------
&T7ACHXZHT 3
Distances From Top of Well Screen to Water Table (feet)

Outer
Doptft Of
Foot to
Top of


Crowd
ttett firound
ftoptk to
Motor
•Seroori

Ground
Sottas of
Top of
trcm
to
Well He.
Surfaeo
$er«or»
~ f fM—1>
Crotrid
Uotor
1
1.49
n.79
60.79
56.49
4.3
2
1.7?
45.2?
35.27
30.12
5.15
S
2.25
75.111
65.01
43.13
21.88
4

4 - My 1916



11
2
51.14
41.14
13.09
28.05
12
1.5
39.51
29.51
MA
NA
13
1.92
30.06
20.06
3.22
16.84
14
1.92
33.03
23.03
18.34
4.69
15
2.03
51.53
41.53
22.77
18.76
1*
1.3
59.96
47.96
51.66
•10.13
17
2.01
44.1
36.1
59.14
•23.04
21
2.06
25.21
15.21
1.71
13.5
22
2.12
25.28
15.21
8.91
14.37
23
2.07
24.78
14.78
8
6.78
24
2.26
40.13
30.13
•ottOMd Out

25
1.92
36.01
26.02
34.8
-8.78
26
1.25
50.02
40.02
Ooctaaod Out

31
1.C2
27.00
17.1«
16.23
0.95
32
1.9
45.7f
35.89
38.44
-2.55
33
2.21
51.12 ..
48.22
52.37
-4.15

-------
ATTACHMENT 4
Distance froa the Soil Surface to the Piezometric Surface
Data
P4
P5
p6
P?
P8
p10a
p12a
h13
*21
h22
n23
*41
Msr*85
2.4
2.1
2.3
3.2
2.7


3.8
4.
1.4
2.3

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
29 1991
9551.1991(09)
Robert A. Olsen
Senior Process Engineer
Conoco Billings Refinery
P. O. Box 2548
Billings, KT 59103-2548
Re: Ho Migration Petition for Conoco*s Land Treatment Facility
(LTF), Billings, MT (F-91-NCBP-FFFFF)
Dear Mr. Olsen:
The purpose of this letter is to respond to issues raised by
Conoco during-EPA's site visit on May 7, 1991. Specifically,
Conoco requested guidance on how they should address
bioaccumulation in the assessment of environmental impacts at the
Billings land treatment facility. To address this issue, Conoco
should first assess the environmental threat that exists at the
LTF. An environmental threat can be assumed to exist at a LTF
only if three criteria are met. These are:
1) Sensitive environmental receptors are within the
vicinity of the site (such as aquatic ecosystems or
endangered or threatened species located within 1000
feet)f
2} There is an exposure pathway by which these receptors
may be exposed to contaminants from the site (is there
hydraulic connection between ground water and receptors
or airborne transport of contaminants); and,
3) The receptor could be exposed to the contaminants at
hazardous levels.
If any of these three conditions does not hold, then no
significant ecological threat is presumed to exist and the issue
of bioaccumulation does not need to be addressed. Zf these
conditions do exist, Conoco should:
1) Determine and state which substances present in
Conoco*s hazardous waste have a bioconcentration factor
(BCF) over 1000, particularly mercury, cadmium, lead,
and zinc. The most reliable source of peer-reviewed
BCF values are EPA ambient water quality criteria
documents;
-------
2
2)	Acknowledge those substances present in the vaste and
their potential for bi©accumulation; and,
3)	And dismiss possibilities (no hazardous constituents
leaving the treatment zone, no environmental receptors,
no surface runoff).
If you have any additional questions on this issue or
related issues, please call me at (202) 475-9712.
Sincerely,
Newman Smith
Office of Solid Waste
Disposal and Technology Section (OS-343)
cc: Mike Gansecki, Region VIII
Stephanie Wallace, Region VIII Montana Office
Duane L. Robertson, DHES
James Michael, PSPD, OSW
Terry Keidan, PSPD, OSW
Howard Finkel, ICF, Inc.
(,03
-------
UK * .0 STATES EJ€VttONK£i
-------
- - • •» . ten • ikwnabn < a*, rkw » iw . .wn	l
- 2 -
The Agency's position on the question of multiple-
constituent vaste in which some constituents meet the treatment
standards and others do not is that the waste—not individual
constituents—must be certified to meet the standards. The
phraseology is specific regarding "waste" in 268.7(a)(1) and
(a)(2)(ii). Thus, in your case, even though the Cyanides (total)
component meets the standard, you must notify the TSD that your
waste as a whole does not meet the standard because of the
Chromium (total) component. The TSD should, therefore, be told
to treat all constituents of the waste to the treatment
standards.
Should you need additional information, you may contact Pat
FOX at (703) 308-8458.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Haste

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY	9551.1991(11)
SEP 11 199'
T.L. Nebrich, Jr.
Waste Technology Services, Inc.
640 Park Place
Niagara Falls, New York 14301
Dear Mr. Nebrich:
I am writing in response to your letter of September 18, 1991
regarding the land disposal restrictions program. In particular,
you raise two 
-------
UHITED STATES ENYIRONMEHTAL PROTECTION AGENCY
9551.1991(11)
SE> 21 1991
T.L. Nebrich, Jr.
Waste Technology Services, Inc.
640 Park Place
Niagara Falls, New York 14301
Dear Mr. Nebrich:
I am writing in response to your letter of September 18, 1991
regarding the land disposal restrictions program. In particular,
you raise two questions concerning the applicability o£ California
list prohibitions following promulgation of the Third Third.
First, you ask what treatment standards must be met to land
dispose of soils or other wastes that are granted a national
capacity variance but must meet California list prohibitions? The
treatment standard that must be met depends on which California
list waste is present. Under 40 CFR 268.42(a)(1), liquid and
nonliquid PCBs of certain concentrations must be incinerated or
burned in high efficiency boilers. Under 40 CFR 268.32 and
268.43(a), numerical concentrations are specified as prohibition
levels or treatment standards. Any appropriate technology may be
used to meet numerical treatment standards.
Second, you ask whether the California list prohibitions
- "remaining in effect for HOCs apply only to characteristic wastes
or also to listed wastes containing HOCs? EPA specified in the
preamble to the California list final rule that California list HOC
standards *«rc only applicable to those HOCs that are not covered
by other Agaacy rulemakings... • 52 Fed. Reg. 25760 at 25773.
Similarly* the regulations specify at 40 CFR 268.42(a)(2) that
California list HOC standards *do not apply where the waste is
subject to a part 268, subpart D treatment standard for a specific
HOC (such as a hazardous waste chlorinated solvent for which a
treatment standard is established under [section] 268.41(a)).*
The California list HOC standards apply only to characteristic
wastes because all listed wastes either have their own treatment
standards or, because thev are newlv listed wastes, the California

-------
list prohibitions do not apply; more specific (i.e., waste code-
specific) standards have now been promulgated for all wastes listed
prior to November 1984, and the California list prohibitions do not
apply to wastes listed after November 1984. 55 Fed Reg. at 22674-
22675.
I hope you find this discussion helpful. Please feel free to
contact me at 703-308-8434 if you have any further questions.
Sincerely,
Richard J. Kinch, Chief
Waste Treatment Branch

01
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
utb i j isgj
9551.1991(12)
Mr. John R. Kampfhenkel
Chief Environmental Engineer
Koch Refining Company
P.O. BOX 2608
Corpus Christi, Texas 78403
Re: No-Migration Petition submitted for Koch Refining1s Corpus
Christi, Texas Land Treatment Unit (F-91-NKCP-FFFFF)
Dear Mr. Kampfhenkel:
We have reviewed the information Koch Refining Company
(Koch) submitted on February 1, 1991 regarding the no-migration
petition for the Corpus Christi Refinery land treatment unit
(LTU), and found the additional information on unsaturated zone
and ground-water monitoring useful in answering some of the
earlier questions we had about the petition. However, the
information from Koch did not resolve some of the critical
deficiencies noted in the original petition submission. These
include the presence of hazardous constituents in soil-pore
liquids, below the treatment zone, and in the ground water.
PRESENCE 07 HAZARDOUS CONSTITUENTS IN TEE SOXL-PORE LIQUIDS
Your letter suggests that the detection of benzene in soil-
pore liquids was most likely caused by using a pump contaminated
' with oil and grease. However, after our review of the type of
lysimeter used by Koch, we do not consider this explanation to be
convincing. Specifically, our examination of the mechanics of
the pressure-vacuum type lysimeter indicates that the pressure-
vacuum pump and the connecting tube do not come in contact with
the liquid sample. Therefore, any contamination occurring from
the pump would be limited to the air pumped into the lysimeter
during the evacuation phase.
During the September 1988 sampling event, 2-butanone and
ethyl benzene were detected at higher levels than was benzene.
Since benzene is a relatively volatile constituent, and is
expected to degrade at a faster rate than 2-butanone or ethyl
benzene, the absence of these more persistent constituents during
fnheorpiawt	wrtf cnpp^^t- pump Inhrifiinl-c «
iaha mure a mf the lygj-mat-g zfaSIEBiaiafcuaB	. Tf fhp hpn7pnw ,
*e*sc*ed aur.iijg #n£, wyjemifer monitoring event-w#~

-------
-2-
residual contamination from the September 1988 sampling event, 2-
butanone and ethyl benzene also should have continued to be
present. Your letter also fails to provide any alternative
source or explanation for the detection of 1,2-dichloroethane,
toluene, and styrene in the soil-pore liquids at concentrations
exceeding the health based levels.
In regard to the inorganic constituents, your letter
concludes that "because there are no data available from LY-1
since September 1988, it cannot be determined whether the
concentrations of heavy metals from the LTU soil-pore liquid
samples are the result of a release from the LTU or due to other
factors (e.g., varying background conditions, laboratory
inaccuracies) . ** Koch's inability to collect background
monitoring data after September 1988 is unfortunate for the
showing you are attempting to make. However, for the purposes of
EPA's data evaluation, a sample was successfully collected from
the background lysimeter (LY-1) during the September 1988
monitoring event when the bulk of the data showing migration also
were collected. Those data show that beryllium, chromium, lead,
and nickel were detected in the active area lysimeters, at
concentrations exceeding the HBLs, but not in the background
sample. The lack of background data from other monitoring events
does not affect the validity of the data obtained from the
September 1988 sample. Without supportive comparative background
data, we are obliged to discount other factors for the
contamination. We, therefore, continue to conclude from Koch's
petition data that hazardous constituents have already migrated
beyond the unit boundary.
PRESENCE OF HAZARDOUS CONSTITUENTS BELOW TIE TREATMENT ZONE
Your letter claims that because background soil-core data
have not been collected, EPA cannot assume that data showing
. "antimony and beryllium below the treatment zone indicate
migration. While it is unclear why Koch did not collect
background soil cores fi.e., the permit stipulates that Koch must
collect background soil-core samples within 30 days of permit
issuance - August 31, 1988), in their absence it is impossible to
make a conclusive showing that migration has not occurred. We
also consider the detection of beryllium in soil-pore liquids in
the active area lysimeters to strengthen our conclusion that
beryllium detected in the soil-core sample is from the LTU.
In addition, Koch claims that the detection of organics and
oil and grease below the treatment zone was caused by waste
migrating from Carson's Pit and not the LTU. Koch supports their
claim by stating that concentrations of the organic constituents
increased with depth below the lower treatment zone, and organic
constituents were not detected in any of the soil-core samples
1^0 A
-------
collected from the three sampling intervals ranging from 1.5 to
5.5 feet.
Although it may be possible for organic constituents and oil
and grease to have originated from Carson's Pit, due to either
mounding or as a direct result of a portion of Carson's Pit
extending beneath the LTU, we do not believe that Koch has
clearly demonstrated thati Carson's Pit accounts for the observed
contamination levels and patterns. Your suggestion of Carson's
Pit as the contamination source provides no explanation of the
various data in the petition showing detection of the following
constituents in the 1.5 to 3.25 foot interval in one or more
locations and/or occasions:
benzene, ethyl benzene, xylenes, 1-methylnaphthalene,
3-methylphenol, 7,12-diaethylbenz(a)anthracene, chrysene,
methyl chrysene, naphthalene, phenanthrene, benzo(a)pyrene,
2,4-dinitrophenol, fluoranthene, pyrene, and toluene.
Your claim that organic constituents were not detected in any of
the soil-core samples collected from the three sampling intervals
ranging from 1.5 to 5.5 feet is at odds with these petition data.
We, therefore, continue to believe that wastes are moving through
the unit, and that Koch has failed to demonstrate to a reasonable
degree of certainty that there will be no-migration of hazardous
constituents from the disposal unit.
PRESENCE OF HAZABDOOS CONSTITUENTS IN THE GROTOD WATER
Finally, the presence of vanadium above its health based
level in the ground water, as detected in August 1988, remains a
primary concern. Koch claims that the August 1988 monitoring
data may be unreliable and nonrepresentative of the ground water
because inorganic constituents were found in all of the
"monitoring wells, but were not found during subsequent events.
Koch's conclusion that the August 1988 monitoring data may
be invalid is not supported by the fact that low levels of other
inorganic constituents (beryllium, cadmium, nickel, arsenic, and
mercury) were only found during the August event. Rather, the
presence of the inorganic constituents could indicate that
contamination plumes occur sporadically. He note that vanadium
was detected in two of the four downgradient monitoring wells,
but not in the upgradient monitoring wells during the August 1988
sampling event.
Furthermore, based on the petition, we disagree with Koch's
assertion that inorganic constituents were not detected during
subsequent monitoring events. Although not found above its
health-based level, vanadium was detected during the March 1989
monitoring event at concentrations ranging from 0.018 mg/1 to
L i o
-------
-4-
0.057 mg/1. In addition, nickel was detected during September
1988, January 1989, and December 1989 sampling events at
concentrations ranging from 0.055 mg/1 to 0.15 mg/1.
In order to help support a claim regarding unreliable
ground-water data, analytical data fe.er.. QC data) indicating
field or laboratory contamination would be necessary. We,
therefore, continue to believe that the petition data show that
vanadium has already migrated beyond the unit boundary.
As a result of our review of your supplementary information,
we have concluded that the technical basis still exists for
proposing to deny your petition. After making our recommendation
to EPA's Assistant Administrator for Solid Waste and Emergency
Response, we will proceed to publish a proposed denial in the
Federal Register. If you wish to avoid a negative publication,
you may send a letter withdrawing your petition and acknowledging
that Koch Refining Company considers the petitioned wastes to be
restricted wastes subject to the Third Third Land Disposal
prohibitions. You should forward this letter to:
James Michael, Acting Chief
Assistance Branch (OS-343)
Office of Solid Waste
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Any questions regarding our findings may be submitted in
writing to Mr. Chris Rhyne of my staff.
Sincerely,
Jeffery D. Denit, Deputy Director
Office of Solid Waste
cc: James Michael, PSPD, OSW
Chris Rhyne, PSPD, OSW
Bill Honker, Region VI
David Neleigh, Region VI
Minor Hibbs, Texas Water Commission

-------
Summary of Soil-Core Monitoring Data for Oil and Grease (mg/kg)
Soil- Core
#
0' -
1.5'
1.5' "
3.25'
3.25'
-5.0*
5.0' -
5.5'
5.5' -
6.5*
6.5 1 -
7.5*
06/29/89
1
75,000
160
58
51
<10
<10
2
29,000
256
74
<10
18
<10
3
120,000
340
1,000
34
26
<10
4
190,000
46,000
100
50
<10
<10
5
42,000
34
<10
<10
<10
<10
6
110,000
520
18
<10
<10
<10
12/19/89
1
11,000
290
92
1,900
7,000
4,600
2
110,00
290
<10
<10
<10
<10
3
<10
<10
<10
<10
<10
<10
4
110,000
50,000
31,000
170
160
250
5
69,000
92
94
50
<10
<10
6
940
<10
<10
<10
<10
<10

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9551.1991(13)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
r;~f z Q -	oesiCEOf
SOliD WAST£ AND SMS«G6NCv BESPQf
Mr. Douglas MacMillan, Director
Hazardous Waste Policy
National Solid Wastes Management Association
Suite 1000
1730 Rhode Island Ave., N.W.
Washington, DC 20036
Dear Mr. MacMillan:
This letter responds to your inquiry dated October 11, 1990
about several aspects of the Third Third land disposal
restrictions final rule. Your letter includes questions about
the following topics; lab packs, inorganic solid debris,
certification/notification requirements, and the disposal of D001
ignitable wastes. Responses to the specific questions about each
of these topics are presented below.
!• Lab Packs
Your question concerns the language in 40 CFR 264.316(f) and
40 CFR 265.316(f). You refer specifically to perceived
contradictions between the first and second sentences of these
paragraphs; however, it is assumed that you are actually
concerned with the language of the second and third sentences
which specifies that "[pjersons who incinerate lab packs
according to the requirements in 40 CFR 268.42(c)(1) may use
fiber drums in place of metal outer containers. Such fiber drums
must meet the DOT specifications in 49 CFR 173.12 and be
overpacked according to the requirements in paragraph (b) of this
section." In particular, you request clarification of whether
this language requires fiber drums to be overpacked in metal
drums. It is assumed that your confusion stems either from the
DOT specifications in 45 CFR 173.12, or the overpacking
requirements in 40 CFR 264.316(b) and 40 CFR 265.316(b). The
language of the DOT specifications and the §S 264.316(b) and
265.316(b) overpacking requirements will be examined below.
The language specifying that fiber drums must meet the DOT
specifications in 49 CFR 173.12 does not require fiber drums to
be overpacked in metal drums. In fact, paragraph (b) of 49 CFR
173.12 states: "The outside packaging must be a DOT
specification metal $£ fiber drum" [emphasis added].
Moreover, the language specifying that fiber drums must be
overpacked according to the requirements in Si 264.316(b) and

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265.316(b) does not require overpacking of fiber drums in metal
drums. The first sentence of Si 264.316(b) and 265.316(b)
("[t]he inside containers must be overpacked in an open head DOT-
specification metal shipping container") does not apply because
IS 264.316(f) and 265.316.(f) clearly state that "[p]ersons who
incinerate lab packs according to the requirements in 40 CFR
268.42(c)(1) may use fiber drums in place of metal outer
containers." The Si 264.316(b) and 255.316(b) language that does
aPPly# however, is the requirement to pack a sufficient quantity
of absorbent material around the inner containers to completely
absorb all of the liquid contents of the inside containers,
making the outer container full after packing.
As you mention in your letter, the preamble language on page
22631 of the Third Third final rule explains the Agency's
decision to allow fiber drums to be used as outer containers for
lab packs being incinerated according to the requirements in
40 CFR 268.42(C)(1). The language of Si 264.316(f) and 265.316(f)
does not eliminate this decision by otherwise requiring the fiber
drums to be overpacked in metal drums.
2. Containers
You request clarification of why containers are included in
the "inorganic solid debris" definition. You also ask when an
empty container would be judged to carry a characteristic of
hazardous waste.
By way of background, inorganic solid debris is defined in
40 CFR 268.2(g) as nonfriable inorganic solids contaminated vith
D004 - D011 hazardous wastes that are incapable of passing
through a 9.5 mm standard sieve; and that require cutting, or
crushing and grinding in mechanical sizing equipment prior to
stabilization? and, are limited to certain types of debris
specified in subsequent paragraphs. Paragraph (g) (6) of
„•§ 268.2 includes metal cans, containers, drums, or tanks in the
' definition of inorganic solid debris.
As a further point of background, the answers to your
questions are impacted by whether the container being discussed
is empty as defined at 40 CFR 261.7(b). Under the S 261.7(b)
provisions, a container that has held hazardous waste (other than
a compressed gas or an acute hazardous waste) is "empty" if it
meets certain criteria. All wastes must have been removed that
can be removed using the practices commonly employed to remove
materials from that type of container. To assure that all waste
has been removed, there may be no more than 2.5 centimeters (one
inch) of residue remaining on the bottom of the container or
inner liner; or no more than 3 percent by weight of the total
capacity of the container remaining in the container or inner
' liner if the container is less than or equal to 110 gallons in
size, or no more than 0.3 percent by weight of the total capacity

-------
of the container remaining in the container or inner liner if the
container is greater than 110 gallons in size.
In response to your first question, containers are included
in the definition of inorganic solid debris to cover the possible
scenario of a container that has been discarded by means of land
disposal (as defined in $ 268.2), that does not meet the
i 261.7(b) definition of empty, and that is contaminated with a
characteristic metal waste. This scenario could occur, for
instance, during an excavation at a corrective action site. A
container might be uncovered that is damaged (e.g., crushed) so
that the hazardous waste within it cannot be removed sufficiently
to meet the S 261.7(b) definition of empty. Such a container
(i.e., including its contents) is a hazardous waste subject to
the land disposal restrictions if it is subsequently land
disposed. Furthermore, it is likely that the disposed container
would be considered contaminated debris (such a determination may
depend upon site-specific conditions best made by an authorized
State or SPA Regional representative). If the waste
contaminating this disposed container is a characteristic metal
waste (D004 - D011), the container would likely meet the
$ 268.2(g)(6) criteria of inorganic solid debris, and would thus \
be subject to a national capacity variance until May 8, 1992 (see
i 268.35(b)).
In response to your second question, a container meeting the
S 261.7(b) definition of empty may be judged to be a
characteristic metal waste under two scenarios. In the first
scenario, a container that has never held any hazardous waste may
be a characteristic waste if: (1) it is being discarded; and, (2)
if the container is in itself a characteristic waste.
In the second scenario, an empty container (as defined in
S 261.7(b)) may be a characteristic waste if: (1) it is being
discarded; and, (2) if the container is in itself a
characteristic waste. It should be noted, however, that any
residue remaining in the container is exempt from regulation
under the provisions of $ 261.7(a) that states that N[a]ny
hazardous waste remaining in either (i) an empty container or
(ii) an inner liner removed from an empty container, as defined
in paragraph (b) of this section, is not subject to regulation
under Parts 261 through 265, and Parts 268..."
3. certiflcaUgng
You request clarification of the record keeping requirements
for a particular scenario: A waste that the generator determines
(based on process knowledge) does not meet the treatment standard
is sent to a treatment facility. The treatment facility
determines the waste does meet the treatment standard. You did
not suggest how such a determination was made. Your question is,
how would the record keeping requirements be affected?
/
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In this particular scenario, the treatment facility should
analyze the waste in order to determine that the waste seets the
treatment standard according to the provisions of their waste
analysis plan. It should be noted, however, that there is no
requirement that treatment facilities analyze each shipment of
waste received, except as specified in their waste analysis plan
(see § 268.7(b). In this particular scenario, however, the
generator has made the determination that the waste must be
treated based on his knowledge of the waste. The treatment
facility is countering the generator's determination with a
determination that the waste meets the treatment standard as
generated; therefore, the Agency believes that it is appropriate
to ask the treatment facility to support their determination with
analytical data. The treatment facility also must complete a
certification that the waste met applicable treatment standards
as generated (see § 268.7(a)(2)(ii), supported by the general
principle expressed in § 268.7(b)(6) requiring treatment
facilities to comply with notice and certification requirements
applicable to generators).
The treatment facility must send the waste analysis data
(see $ 268.7(b)(4)(iv)), the certification, and a notification ;
(either the generator's notification may be sent, or the facility
may create a new notification) to the disposal facility. Copies
of the waste analysis data, the generator's notification (as well
as the treatment facility's notification if a new notification
was created), and the certification must be kept as records in
the treatment facility's files.
«~ notification/Certification
A scenario was presented of a TSO company that has a sister
company on adjacent property that recycles "side-stream" and
"off-spec" chemicals and other wastes containing recoverable
amounts of organics by means of a custom distillation process.
This process generates still bottoms and wash waters that are
subject to the land disposal restrictions. These restricted
wastes are piped directly back to tanks at the TSD facility,
sometimes on an intermittent basis, sometimes continuously. The
question is asked: How must these piped transfers of hazardous
wastes from the recycler to the TSD be handled from the
perspective of notification/certification compliance?
Even though the recycling facility and the TSD facility are
sister companies on adjacent property, they would have been
assigned different EPA identification numbers and are thus,
considered separate facilities. Therefore, the waste that is
piped to the TSD facility (regardless of whether it is on a
continuous or an intermittent basis) is subject to the record
keeping requirements of i 268.7.
The recycling facility would be subject to the generator
requirements of § 268.7(a), which specify that a notification
must be sent with each shipment of waste (in this case, from the
O •
-------
recycling facility to-the TSD facility). The TSD facility must
comply with the requirements of § 268.7(b). Questions on hov
frequently the required paperwork should be sent from the
recycling facility to the TSD (i.e., what constitutes a
"shipment") should be directed to the EPA Regional land disposal
restrictions contact.
The question is whether 40 CFR 264.312 allows for the land
disposal of a D001 waste. Until promulgation of the Third Third
final rule on Hay 8, 1S90, 40 CFR 264.312 (and § 265.312) set out
special management requirements for ignitable or reactive wastes
that were disposed in a surface impoundment, waste pile, land
treatment unit, or landfill. On page 22553 of the final rule,
however, the Agency explained that these management requirements
are superseded by the treatment standards promulgated in the
Third Third final rule. This means that "[facilities handling
ignitable and reactive wastes will have to comply with the
promulgated treatment standards for these wastes in order to land
dispose them." The Agency made changes to the regulatory
language of §s 264.312 and 265.312 in the Third Third final rule ;
to incorporate the requirement that the treatment standards for
ignitable and reactive wastes must be set prior to land disposal.
Furthermore, the Agency*s intent is clearly expressed in the
preamble (55 FR 22553).
Therefore, land disposal is allowed only for those 0001
wastes that meet the treatment standard. (The treatment standard
for 0001 wastes containing less than 10% total organic carbon
(TOC): deactivation? for 0001 containing greater than 10* TOC:
incineration or fuel substitution; see 40 CFR 268.42, Table 2.)
1 hope you find these answers to be helpful. If you have
any further questions, please feel free to contact
Matthew A. Straus at (703) 308-8414.
5. D001
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste
(
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9551.1991(14)
MAY i 1991
Mr. David R. Saad
Environmental Coordinator
Illinois Refining Division
Marathon Petroleum Company
Robinson, XL 62454
Re: No Migration Petition for the Robinson, Illinois Land
Treatment Facility and Storage Surface Impoundments
(F-91-NMPP-FFFFF)
Dear Mr. Saad:
I understand from Jim Michael and Dave Eberly that the EPA -
Marathon meeting on April 30 vas very productive, your interest
in discussing the proposed response to the Notice of Deficiency
for Robinson's No-Migration petition vas velcomed by us. One
procedural question hanging over from that meeting concerns the
best approach for revising Marathon's petition to cover only the
East land treatment unit.
In our judgment, the most efficient approach would be for
you to withdraw your petition for the three surface impoundments
and the two land treatment units and to submit a new petition
limited to the East land treatment unit. That approach would
, -simplify four related tasks for Marathon and EPA. First, it
would close out the administrative record on your current
petition. Our recommendation for denial is still on the record,
and your withdrawal would eliminate any need to publish a
decision or to maintain a docket. Second, Marathon would not
have to respond to our Notice of Deficiency, but could instead
use it as a guide in preparing a new petition for the East unit.
Third, a new petition would be easier to prepare than a revision
to the existing petition which would involve excising or editing
discussion of all areas except as they pertain to the East unit.
Finally, a new petition for the East unit would, we believe, be
consistent with any required permit modifications.

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We, therefore, recommend a letter of withdrawal for the
existing petition in response to our letter of November 6, 1990
and submission of a new petition for the East unit as soon as
possible. As we stated at our meeting on April 30, we will focus
our review of the new petition on those technical concerns in the
November 6 letter related to the East unit.
Please be assured that Marathon's withdrawal of its original
petition and subsequent submission of the new petition would not
affect Marathon's position in the queue for review and decision-
making by EPA.
If you have amy questions on implementing this approach,
please call Dave Eberly on 202-382-4691.
Sincerely,
Elizabeth Cotsworth, Chief
Assistance Branch (OS-343)
cc: Ronald Andes, Marathon
Jim Michael, AB, PSPD, OSW
Dave Eberly, AB, PSPD, OSW
Gail Hrusfca, EPA Region V
David Deisher, IEPA
U5!
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UNITED aTATES ENVIRONMENTAL PROTECTIO., aGENCY 9554.1990(13)
.iGV 2 0 199G
Mr. William J. Ziegler
Vice President of Health,
Safety and Environmental Affairs
ThermalXEM, Inc.
454 S. Anderson Rd.
BTC 532
Rock Hill, SC 29730
Dear Mr. Ziegler:
I an writing in response to your letter, dated October 19,
1990, requesting clarification of the wording in the Third Third
final rule regarding the alternative treatment standards for lab
packs. The point requiring clarification is found at 40 CFR
264.316(f) and 40 CFR 265.316(f) which specifies that "persons
who incinerate lab packs according to the requirements in 40 CFR
268.42(c)(1) may use fiber drums in place of metal outer
containers. Such fiber drums must meet the DOT [Department of
Transportation] specifications in 49 CFR 173.12..." You
requested clarification of whether the word "drum" precludes the
use of other acceptable DOT container types, such as fiber and
wooden boxes.
The Agency added this provision allowing use of fiber
(rather them metal) drums for overpacking lab packs based on
several comments received on the Agency's proposed approach (see,
for instance, comment number LD12-00110 from ThermalKEM/CyanoKEM,
comment number LD12-00124 from Rollins Environmental Services,
and comment number LD12-00172 from the Hazardous Waste Treatment
Council). Commenters stated that lab packs destined for
incineration are usually packaged in fiber packs that are DOT
approved under 49 CFR 173.12. These fiber packs are utilized
since th* container can be incinerated without opening or
emptyiner the container. Commenters urged EPA to accept this DOT
allowance for fiber packages for lab packs, and to reference the
citation to 49 CFR 173.12 instead of, or in addition to, the 40
CFR 264.316 and 265.316 citations which refer to requirements for
lab packs overpacked in metal drums that were primarily designed
for landfilling untreated wastes.
-------
The DOT requirements at 49 CFR 173.12 presents criteria to
be used in selecting a proper outside package. Paragraph (b) of
49 CFR 173.12 states:
The outside packaging must be a DOT specification
metal or fiber drum. It may also be a
polyethylene drum capable of withstanding:
1.	The vibration and compression tests specified
in 178.19-7(c)(1) and (2), and
2.	A four foot drop test as specified in
178.224-2(b).
The Agency found the commenters• argument about the danger
posed by opening metal drums and emptying inner containers prior
to incineration persuasive. The Agency agreed that if fiber
drums were used, the entire lab pack unit could be incinerated.
Furthermore, the Agency agreed that the DOT requirements for the
structural integrity of fiber drums would assure that lab packs
were transported in a safe container to incinerators. Therefore,
the provision was made in 40 CFR 264.316(f) and 265.316(f) that
fiber drums were acceptable, and the reference to 49 CFR 173.12
was incorporated into these sections.
As to a clarification of 49 CFR 173.12, it is the Agency's
understanding that when DOT regulations specify drums, that is
indeed what is meant. Thus, fiber or wooden boxes or other
containers not meeting the DOT specifications in 49 CFR Parts 178
— 199 for fiber drums may not be used as outer containers for
lab packs. The DOT specifications, however, include several
types of fiber drums, and any of these would be acceptable as
outer containers for lab packs.
Additionally, you request clarification of the effect the
performance packaging specifications proposed in HM181 will have
, - on lab packs when they are implemented in December of 1990.
Based on the Agency's understanding of the proposed
specifications, they should have very little impact on the lab
pack requirements. The performance-oriented packaging provisions
will specify criteria for fiber drums (as well as other DOT outer
containers) based on the DOT hazard classification of the
materials being transported (e.g., flammable liquids). The DOT
expects that such criteria will add flexibility to the
requirements for outer containers inasmuch as they may be built
in any design, or of various materials, so long as they meet the
criteria for that particular hazard classification. As to the
expected effect the performance-oriented packaging provisions
will have on lab packs, the Agency foresees that the generator
may be required to give additional attention to packing only
wastes that fit within one DOT hazard classification in the lab
pack; however, given that all the wastes included in the
Appendices to 40 CFR 268 are capable of being incinerated, the
(/£'
-------
Agency expects that most of these wastes will fall within one or
two of the DOT hazardous classifications (i.e., flammable
liquids, flammable solids).
I hope this letter clarifies the meaning of "fiber drum" as
it pertains to lab packs regulated under the land disposal
restrictions. If additional information is needed about current
DOT specifications for fiber drums, the DOT hazard
classifications, or proposed HM181, please contact DOT directly.
If additional information is needed about the alternative
treatment standards for lab packs, please call Rhonda Craig of
EPA's Waste Treatment Branch at (703) 308-8434.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste


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i £S '*
*&>
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9554.1990(14)
WASHINGTON, D.C. 20460
Of PICE Of
SOUIO WASTE AND EMEBCENCV HES'C
yffi 2 7 I3:-C
Mr. Kevin S. Dunn
Project Manager
Environmental Policy Center
Lav Companies Environmental Group
1828 L Street, N.W., Suite 711
Washington, D.C. 20036
Dear Mr. Dunn:
This letter is in response to your letter dated
November 16, 1990 requesting clarification on certain issues
regarding treatment standards for certain mixed radioactive
wastes.
With regards to Question l (as referred to in your letter),
"placement in a heavy stainless steel box and velding the box
closed" vould not be considered to comply with the standard
identified as "MACRO" in 268.42 Table 1 (55 IE 22693 (June 1,
1990). This standard is quite clearly described in regulatory
language in Table 1 as "Macroencapsulation with surface coating
materials such as polymeric organics (e.g., resins and plastics)
or with a jacket of inert inorganic materials to substantially
reduce surface exposure to potential leaching media. Macro-
encapsulation specifically does not include any material that
would be classified as a tank or container according to 40 CFR
260.10" (emphasis added). Paraphrasing the regulatory language,
compliance with the macroencapsulation standard explicitly
prohibits containerization of wastes or materials in a tank or
container meeting the regulatory criteria under the 40 CFR
260.10.
Thi* is not the same situation as where the U.S. Naval
Nuclear Propulsion Program wanted to. land dispose defueled
submarine reactor compartments. The information provided by the
Navy indicated that the "jacket of inert inorganic materials"
(i.e., the steel surrounding the lead) could "substantially
reduce surface exposure to potential leaching media" and that
due to their size and structure these compartments would na& be
classified as a tank or container according to the definitions
in 40 CFR 260.10. EPA purposely modified the proposed standai.*d
for DO08 radioactive lead solids to include "jackets of inor-
ganic materials" in order to specifically account for these
submarine reactor compartments. EPA felt that it was necessary
-------
- 2 -
to add the language to the definition of macroencapsulation to
prevent the "jacket of inorganic material" from being
interpreted as including materials that are merely containers or
drums.
With regards to the plastic coated, lead lined gloves in
Question 2 of your letter, they would be considered to comply
with the standard identified as "MACRO" provided that none of
the lead is exposed (i.e., the entire surface of the lead is
coated) and provided that the coating provides a substantial
reduction in surface exposure to potential leaching media (i.e.,
the gloves should not be expected to be exposed to physical,
chemical, or thermal conditions where the integrity of the
surface coating could likely be breached). With regards to the
lead weights in Question 2. the wastes may be considered to meet
the specified method of "MACRO", as generated, provided the
stainless steel surrounding the lead weights does not meet the
definition of a tank or container and provided a substantial
reduction in surface exposure to potential leaching media can be
determined.
The standard identified as "MACRO" currently applies only
to D008 wastes fitting the description of "Radioactive Lead
Solids'* as defined in Table 3 of 268.42 (55 Q 22700, (June 1,
1990)) (e.g., those wastes containing elemental lead forms of
lead or that act specifically as radioactive shielding). This
standard is currently not applicable to the D006 wastes referred
to in Question 3. These D0Q6 wastes would have to comply with
the concentration-based standard for D006 which is based on a
TCLP analysis. Verification of compliance with this standard
would require crushing or grinding of the material and
compliance cannot be achieved by dilution. Thus, macroencapsu-
lation processes would not comply with existing BOAT standards
for metals.
Other than a treatability variance your D006 waste may be
macroencapsulated if a no-migration petition is granted. As of
today, EPA had only granted a two-year capacity variance for
mixed wastes from the statutory deadline prohibiting the
disposal of mixed wastes scheduled in the First, Second, and
Third Third wastes. Previous capacity variances issued for
mixed wastes scheduled in the Solvent and Dioxin Rule and the
California List Wastes Rule had expired and thus, these mixed
wastes are banned from land disposal units unless they meet the
promulgated treatment standards.
-------
I trust this letter addresses all your concerns and
clarifies any outstanding issues you may have had on the
applicability of the treatment standard identified as "MACRO".
If you need further clarification, please contact Richard Kinch,
Chief of the Waste Treatment Branch, at (703) 308-8434.
Sincerely,
Sylvia K. Lowrance
Director
Office of Solid Waste

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UNIT*--. STATES ENVIRONMENTAL PROTECT.-.* AGENCY
9554.1991(01)
JAN 8 1991
Richard J. Pastor
Director, Government Relations
Envirosafe Mgt. Services, Inc.
P.O. Box 833
Valley Forge, Pennsylvania 19482-0833
Dear Mr. Pastor:
This letter is in response to your letter dated October 25,
1990, concerning a possible inconsistency in the Agency*s policy
on the regulation of cyanides under the Land Disposal Restrictions
Program of RCRA. In particular, you indicated specific instances
where you believe the Agency has been inconsistent in its position
on the use of stabilization for wastes containing cyanides. I
hope that this letter will help to clarify this matter. In that
vein, I would like to review the points you raised in some detail,
and to provide an explanation of our views, particularly as to the
full meaning of preamble language in the Land Disposal Restriction
rules.
First, you referred to the promulgation of the First Third
Land Disposal Restrictions (53 ££ 31152) for F006 wastes, where
the Agency stated that the treatment standards for F006 were based
on stabilization using cement kiln dust and that the use of other
agents in the stabilization process is not precluded. Then you
noted the statement that EPA does not consider stabilization an
appropriate BDAT for cyanides. While you did not discuss these
references any further, you seemed to imply that when compared to
each oth«ur, an inconsistent policy on cyanides could be seen.
However, a closer examination of the First Third Land
Disposal Restrictions shows that the Agency did establish
treatment standards based on stabilization, but only for the
metals contained in FQ06. (Note: The First Third LDR rule

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2
promulgated treatment standards for cyanides in F006 wastes as
"reserved"). The preamble for F006 wastes (53 FR 31152, column
3) specifies the Agency's position on stabilization of cyanides
in F006 wastes versus stabilization of metals by stating,* "EPA
does not consider stabilization—BDAT for the metals in this
waste—to be a demonstrated technology for the treatment of
cyanide." This statement is, to my reading, an accurate
reflection of EPA's current position.
Your letter also emphasized some of the Agency's language in
the Second Third LDR rule (54 £E 26609) as follows: "The Agency
does not agree with commenters that stabilization is an applicable
technology for the treatment of the majority of cyanide wastes.
While some data may indicate that stabilization processes appear
to reduce the leachability of some forms of cyanides, the Agency
contends that destruction of cyanide is clearly a preferred
treatment method." Your added emphasis appears to imply that the
Agency was trying to indicate a degree of uncertainty about its
position. Your letter then quotes a later section of the preamble
as follows: "... based ori the review of the available treatment
data, the Agency believes that the conventional cyanide treatment
technologies provide substantial treatment of both the amenable
and total cyanide concentrations as measured bv the cyanide
amenable to chlorination test in method 9010 fSPA Publication SW-
846."
Emphasis of these passages appears to give the impression
that the Agency was stressing the use of the test method to meet
the numerical treatment standard as being more important than
destroying the cyanide. However, the language that directly
precedes the emphasized phrase sheds light on how to read the
quoted passage, i.e., that the Agency believes that conventional
cyanide treatment technologies provide the necessary treatment to
achieve these standards. This is in agreement with the
legislative history (cited in our preamble and your letter) that
"destruction of total cyanides would be required as a precondition
to land disposal."
Certainly, the Agency is on record as saying that "other
technologies that can achieve these concentration based standards
are not precluded from use." However, this statement cannot be
taken alone, and all other applicable regulatory language must be
considered. In particular, section 268.3(a) states that "... no
generator, transporter, handler, or owner or operator of a
treatment, storage, or disposal facility shall dilute a restricted
waste as a substitute for adequate treatment to achieve compliance

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3
with subpart: D of this part, ...	Given the Agency's firm
position that cyanides must be destroyed and that stabilization,
as cyanide treatment, is considered impermissible dilution based
on the current lack of substantive evidence of cyanide destruction
in the stabilization process, use of general statements to
contradict specific determinations on BDAT standards is not the
appropriate reading of our intentions.
Your letter also refers to a letter dated June 13, 1990, from
Douglas Mac Millan of NSWMA to Richard Kinoh of EPA. The example
referred to in your letter as question number 15 is really NSWMA's
question number 17, a hypothetical situation for stabilization of
cyanides not supported by any submitted data. Our July 31, 1990,
response was that "destruction of cyanides is a precondition for
land disposal" and that the situation presented in question number
17 nis not permissible because stabilization is not an applicable
technology for the treatment of cyanide wastes." I have enclosed
a copy of EPA's response.
The Agency has established a treatment standard for the
majority of cyanide wastes at 590 mg/kg total cyanides based on
data from well-designed, well-operated cyanide destruction tech-
nologies. (Lower standards have been established for a few
cyanide wastes.) As noted in the administrative record for the
Second Third LDR Rule, data from certain land disposal facilities
indicate that the majority (85%) of F006 wastes were below the
original proposed treatment standard of 110 mg/kg total cyanides.
In fact very few wastes that were treated for cyanides indicated
total cyanides of 5,900 mg/kg (as in question 17) or as much as
1% (as in your intended waste acceptance policy). Perhaps these
cyanide wastes that you were considering for stabilization did not
receive efficient cyanide treatment in the first place.
Your reference to the non-goingw stabilization of F001, F002,
F003, F004, and F005 solvents does not really bear upon the
, Agency's position on cyanides. Given what we consider to be a
clear indication of our position on the stabilization of cyanides
in regulatory discussions, the determinations of BDAT for these
solvents should not raise any indirect ambiquities on our separate
decisions for cyanide.
I trust that the fuller explanations above will assist you
in working with the treatment standards for cyanides as a pre-
cursor to land disposal. I encourage you to continue to discuss
this matter more fully with members of my staff if any questions
; ¦*>-
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4
still remain. In that event, I suggest that you contact Richard
Kinch, Acting Chief of the Waste Treatment Branch (703-308-8434).
I am certain that Envirosafe shares our concern about the safe and
effective treatment and disposal of cyanides. We look forward to
continued mutual efforts in this regard.
Sincerely,
Sylvxa K. Lowrance
Director
Office of Solid Waste
Enclosure

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9554.1991(02)
rcra/superfund hotline monthly summary
JANUARY 1991
Classification of Leachate Contaminated Ground Wat^
Farardous waste miration from 211 active Subtitle C fonHfiii ii»e resulted in local
ground water contamination. As part of a corrective action at the fadlity, 400-
gallona-of contaminated ground water are withdrawn from the uppermost aquifer
and will bt sent off-site for underground injection. During the course of the clean-
up, thetfacility determined that a leachate resulting from the disposal of a variety of
listed hazardous wastes is responsible for the contamination. In accordance with the
EPA "contained-in" policy, the ground water must be managed as a hazardous
waste, namely the leachate from the landfill. For the purposes of rampKanra with
tile Land Disposal Restrictions m 40 CFR Part 268, what hazardous waste
classification and treatment standard would apply to the ground water?
The leachate meets the definition of a multi-source leachate that is derived from
the treatment, storage or disposal of more than one listed waste, excluding F020-
F023 and F026-F028. In the Third Third Land Disposal Restrictions rule
promulgated on June 1,1990 (55 FR 22520), EPA announced its decision to
eliminate the practice of classifying multi-source leachate according to the
various listed wastes from which it was derived In this rule, the Agency
established a separate treatability group for multi-source leachate, classified by
a angle waste axle, F039. (55 FR 22619) The effective date for this new
designation was August 8,1990, at which time die landfill fadlity was required
to classify its ground water, or more precisely, the multi-source leachate
contained in the ground water, as F039. (55 £& 22650)
Although the F039 waste classification became effective August 8,1990, EPA
granted a two-year national capacity variance until May 8,1992, for F039
wastewaters that are destined for underground injection (40 CFRPart 148.16).
The extension of the effective date was based upon EPA's assessment that
current treatment capacity for underground injected FQ39 wastewaters was
insufficient to require an immediate LDR prohibition effective date. (55 FR ;
22646) During the period in which the variance is in effect, the F039 ground
water mixture, if disposed in a landfill or surface impoundment, must be
managed in a unit that satisfies the minimum technological standards in RCRA
Section 3004(o)a)(A) fsee 40 CFR 2683(h)(2)}. After May 8,1992, the F039
ground water must meet the F039 treatment standards for all applicable
constituents as desaibed in 40 CFR Part 268.43, Table CCW, prior to
underground injection. (55 fit 22623-22626)
Source: Rhonda Craig, OSW	* (703)308-6462
Research: Karen Alex

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9554.1991(03)
RCRA/SUPERFUND HOTLINE MONTHLY SUMMARY
APRIL 1991
1« Treatment of Reiniprtgrf
Corrective Artinn
that * withdraw from an underlying drinldng wa«TniZSZmLToBolt
standards established m the land disposal restrictions (40 CFR Part 268) prior to
remjection of the water into the same aquifer?	«*•«»> prior to
No. There are two provisions which potentially restrict or prohibit injection of
contaminated groundwater the Land Disposal RestrictjonsODRs) under
"-^action, mu,t aU contaminated groundwater
Groundwater which is not contaminated with "hazardous waste" is not
subject to either LDRs or Section 3020. Groundwater which contains
Se5on3CKJWaSte'	^ * *0 LDRStandards'13 object only to
RCRA Section 3020(a), prohibits the injection of a hazardous waste by
underground injection into or above an aquifer formation which contains an
underground source of diinking water. Section 3020(b) specifies that such
prohibition does not apply to contaminated groundwater which is reinjected
into the aquifer from which it was withdrawn if three criteria are met Ditis
part of corrective action required under RCRA or CEECLA intended to clean-
up such contamination; 2) the contaminated groundwater is treated to
substantially reduce hazardous constituents prior to reinjection; and 3) the
proposed corrective action will be sufficient to protect human health and the
environment upon completion.
Groundwater which is contaminated by a hazardous waste for which there
are promulgated LDRs are also sub ject to the prohibition in Section 3020(a).
Moreover, EPA has interpreted the waiver provision under Section 3020(b) to-
also be available for these wastes. See OSWER Directive #9234.1-06. Under
this interpretation, the Section 3004 LDRs otherwise applicable to disposal of
contaminated groundwater have been superceded, where the waste is
disposed by underground injection, by the restrictions on such disposal
under Section 3020. Thus, if the implementing agency at a particular site
finds that the treatment of groundwater as part of the response action has
'substantially reduced" the hazardous consituents and the response action is
"sufficient to protect human health and the environment," then the
groundwater may be reinjected even if it does not meet otherwise applicable
BDAT requirements.	„
Source: Dave Fagan, OSW
Research: Karen R Alex

(202) 382-4497
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9554.1991(04)
RCRA/SOPERFDHD HOTLIHE MONTHLY SUMMARY
DECEMBER 1991
2- SW-846 Test Methods
Are the test methods published in 'Test Methods
for Evaluating Solid Waste. PhysicallChemicai
Methods," known as &V-846. required to show
compliance with 40 CFR Part 268 land disposal
restrictions (LDE) in situations where the treaanent
standard is expressed as a concentration? Are SW-
846 methods required to show compliance with Part
261, Subpart C hazardous waste characteristics?
Generally, the test methods found in SW-846 are
not required but are intended to serve as guidance.
EPA recommends these methods for evaluating
solid waste and the Agency will use the
recommended methods in enforcement situations.
There are a handful of exceptions to this rule where
pecific test methods are required.
Compliance with LDR for wastes that have a
treatment standard expressed as constituent
concentrations in wastes (CCW, §268.43) can be
shown using any appropriate method. This section
does not specifically require the use of
SW-846 methods. If the waste treatment standard is
expressed as constituent concentrations in waste
extracts (CCWE. §268.41), then the Toxicity
Characteristic Leaching Procedure (TCLP), which is
specifically referenced in §268.41(a), must be
performed. Following that, however, any
appropriate method may be used to determine
concentrations of hazardous constituents in the
extract and to show compliance with LDR.
Similarly, in identifying Pan 261, Subpart C
characteristics. §262.11 provides that a generator
has the option of applying knowledge of the
hazardous characteristics of the waste in light of the
nateriais or the processes used, or testing the
material to determine whether or not it is a
hazardous waste. If the generator chooses to test, he
must use the method prescribed in Subpart C of 40
CFR Pan 261. The toxicity characteristic, for
must be used to obtain an extract of the waste.
Following that, as with LDR, any appropriate
method may be used to analyze the extract for
hazardous constituents. In determining the
characteristic of ignitability, the regulations
reference two specific test methods, the Pensky-
Martens i method 1010) and the Setaflash
(method 1020), either of which must be
employed when testing. The characteristic of
corrosivity also references a specific test
method. If the generator chooses to test the pH
of a given waste stream, method 9040 must be
used.
Several other regulatory secnons also require
the use of SW-846 test methods. For example,
in completing a petition to delist a waste from a
specific facility, SW-846 methods must be used
in accordance with §260.22.
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9573.1991(01)
RCRA/SUPERFOND HOTLIHE MONTHLY SUMMARY
MAY 1991
2- Regulation of Municipal Waste Combustion (MWC? Ash
Two cities hive recently constructed combustion facilities to manage municipal solid
waste. The first city has an energy recovery plant, while the second has a non-
energy recovery incinerator. Both units generate a'fly and bottom ash. Would these
types of ash be subjectRCRA hazardous waste regulation if the ash exhibited a
toxicity characteristic?
No. The ash would not be subject to the 40 CFR 261.24 toxicity characteristic
(TC) regulation. The Clean Air Act Amendments of 1990 were enacted on
November 15,1990; Section 306, entitled "Ash Management and Disposal,"
established that for a period of two years after the date of enactment, MWC
ash from "solid waste incineration units" would not be regulated as a RCRA
Subtitle C waste should it exhibit a hazardous waste characteristic of
ignitability, corrosivity, reactivity, or toxicity in 40 CFR Part 261, Subpart C.
(Note: MWC ash would not be regulated as a hazardous waste in 40 CFR
Part 261, Subpart D since it is not a listed source.) The term "ash from solid
waste incineration units burning municipal waste" includes fly and/or
bottom ash from both energy recovery and incineration facilities managing
municipal waste. During the two year moratorium, however, MWC ash
would be subject to: 1) current federal regulations in 40 CFR Part 257
governing the disposal of solid waste, 2) state regulations governing solid
waste disposal; and 3) state regulations governing municipal waste
combustion ash disposal or utilization/reuse, where they exist See also
Environmental Defense Fund. Inc. v. Wheelabrator Technologies, Inc.. Docket
No. 90-7437 (2d Cir. April 24,1991).
Source: Andrew Tepliteky, OSW	(202) 382-4536
Research: Cynthia Hess	~ -m-.

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UHi.tiD STATES ENVIRONMENTAL PROTECTION AGENCY
NOV 28 1990
Marilynne Wilson, FN
Quality Assurance Coordinator
Family Home Care
P.O. Box 2145
Spokane, Washington 99210-2145
Dear Ms. Wilson:
Thank you for your letter dated October 12, 1990 regarding the
proper disposal of old medications.
Expired medications from households may fall into the category
of household hazardous waste. Household hazardous waste (HHW) is
appropriately identified by applying two criteria. First, the
waste must be generated by individuals on the premises of a
temporary or permanent residence for individuals. Second, the
waste stream must be composed primarily of materials found in the
waste generated by consumers in their homes. Other items that may
fall into this category may include excess household cleaners, lawn
and garden products, and paint thinners, among others, when
intended for disposal. Based on the information in your letter,
it is not clear whether the medication you manage qualifies as HHW.
However, you should be able to determine the regulatory status of
the material based on the aforementioned criteria. At the Federal
regulatory level, HHW is excluded from hazardous waste regulations
under Subtitle C of the Resource Conservation and Recovery Act
(RCRA). Please note that state or local regulations may be more
stringent than Federal regulations.
Although household hazardous waste is excluded from
' Subtitle C regulations, the Environmental Protection Agency (EPA)
shares concerns such as yours regarding household hazardous waste.
In fact, EPA attempts to address some of these concerns in the
enclosed publication entitled A Survey of Household Hazardous
Wastes and Related Collection Programs. This report contains the
results of a comprehensive nationwide survey of HHW. In this
publication the Agency identifies: existing information on the
types and quantities of HHW; the impacts of HHW on homeowners,
solid waste collection and disposal personnel, and the environment;
and existing collection programs at the state and local levels.
You may also be interested in the enclosed publication Household
Hazardous Waste: Bibliography of Useful References and List of
state Experts which lists resources and contacts for HHW programs.
&
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With regard to disposal of old medications, rinsing the
bottles and flushing this type of waste down a toilet may be the
most appropriate method of disposal. Additionally, most
pharmacists recommend flushing expired tablets and capsules down
the toilet. By disposing of these normally minute quantities of
household waste in this fashion, the possibility of exposing
children that might be attracted to the potentially harmful
materials while in the trash is removed. Federally, any mixture
of domestic sewage and other wastes that pass through a sewer
system to a publicly owned treatment works (POTW) for treatment is
not regulated under Subtitle C.
I suggest you consult your local publicly owned treatment
works (POTW) to determine if local limits or general/specific
prohibitions are applicable when disposing of expired medications
in this manner. I also suggest you contact your state solid waste
program office to determine if they can provide additional HHW
disposal guidance. The address in Washington is:
Solid And Hazardous Waste Management Division
Department of Ecology
Mail Stop FV-11
Olympia, Washington 98504
(206) 459-6316
Thank you for your interest in proper waste management. I
hope this information is useful when determining the appropriate
disposal options for expired medications.
Sincerely,
Mike Petruska, Chief
Waste Characterization Branch
Enclosures

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\	i iwrrpn ctstcc muiDrtti«r..-r.,	• 9574.1991(01)
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2
snail quantity generator regulations of 40 CFR 261.5, or the
generator regulations of 40 CFR Part 262. Also, individual
states may have more stringent or additional regulations
governing the management of these wastes.
Although others nay have a different interpretation of the
legislative history of the household vaste exclusion, the
Agency • s interpretation of the legislative history and of the
scope of the exclusion have been consistent since promulgation of
the exclusion in 1980. Note that the Hay 19, 1980 Federal
Register (45 JEE 33099) states that EPA interpreted Congressional
intent "... to exclude vaste streams generated by consumers at
the household level" (i.e., by homeowners at home).
Additionally, a November 13, 1984 Federal Register notice (49 £&
44978) which amended the household waste exclusion also included
a discussion of the scope of the exclusion in the preamble. The
1984 notice explained that based on legislative history, it is
appropriate to apply two criteria to define the scope of the
exclusion. First, the waste must be generated by individuals on
the premises of a temporary or permanent residence for
individuals (i.e., a household) and second, the waste stream must
be composed primarily of materials found in the wastes generated
by consumers in their homes. If a waste satisfies both criteria,
it is considered a household waste. Thus, spent NiCd batteries
generated by homeowners would fall under the household waste
exclusion, while those generated by service centers and other
businesses would not.
We recognize that the Nicd battery situation (i.e., many
states considering take-back programs and many products
manufactured such that spent batteries must be removed by service
centers) may present some unique opportunities for safe and
effective recycling. We are also aware of your concerns about
implementation of recycling programs in states considering
legislation designed to increase the rate of NiCd recycling. We
are therefore currently examining the available options to
determine how to facilitate such programs. We expect it will
' "take us several more weeks to assess options and reach a
tentative decision on how to best address your concerns. At that
time, we will notify you of the results of our analysis and of
our plans to implement the decision.
To ensure that you are fully informed about our current
thinking on an approach to this issue, there are several options
that we are exploring. First, we are investigating what could be
accomplished in the short term to alleviate the problems you have
identified. One possibility is to extend the current regulations
governing lead-acid battery reclamation to spent NiCd battery
reclamation. As part of this effort, we must evaluate issues
such ns the size of the problem, hazards posed by waste disposal
and recycling, and the feasibility of possible solutions. Any
information that you could provide concerning the following items
^ i
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3
would be extremely helpful: 1) the types and quantities of
cadmium and nickel used in batteries in the United States, 2)
current management practices for spent NiCds, 3) collection and
storage systems currently in place and planned, 4) recycling
processes currently in use and planned, and 5) quantities of
batteries reclaimed within the U.S. and overseas.
Second, as you are aware, we are currently conducting a
comprehensive analysis of the RCRA regulations to determine how
they could best be modified to encourage environmentally sound
recycling of hazardous wastes. In particular, one of the issues
being studied is how to address reverse distribution systems that
involve the return of hazardous wastes to product manufacturers.
Thank you for your continued interest in increasing the
environmentally sound recycling of NiCd batteries and how RCRA
regulations impact such efforts. Should you have any further
questions regarding the household waste exclusion, please contact
Mike Petruska at (202) 475-8551.
Sincerely
David 3ussard
Director
Characterization and Assessment
Division

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