PB2000-104 957
October 2000
3. LDR Treatment Options for Spent Incinerator Refractory Brick
In order to properly clean and decontaminate a RCRA permitted hazardous waste incinerator
at closure, a facility must dismantle the incinerator's inner liner, which is typically composed of
refractory brick. Refractory brick that has come into contact with listed hazardous waste during
the incinerator's lifetime carries a hazardous waste listing via the contained-in policy. A facility
would like to dispose of listed hazardous refractory brick in a landfill. How should the facility
comply with the land disposal restrictions (LDR) in Part 268for the spent refractory brick?
The facility may employ one of four options in handling the refractory brick in order
to comply with Part 268. First, the facility can treat the brick to the numerical treatment
levels in Section 268.40 for the listed waste contaminating the brick. The facility can,
instead, treat the brick as hazardous debris (if the brick meets the definition of debris in
Section 268.2(g)), and employ the alternative LDR debris standards in Section 268.45.
Another option is for the owner or operator to ask EPA or the approved state agency to
issue a determination that the brick no longer contains a listed hazardous waste and is
thus exempt from all Subtitle C requirements (Section 261.3(f)(2)). Under this option,
the debris need not meet an LDR treatment standard before land disposal (Section
268.45(a)). Finally, the facility can obtain either an equivalent treatment method
variance according to Section 268.42(b), or a variance from the available treatment
standards according to Section 268.44 for the brick. In general, the facility closure plan
will detail closure requirements for the incinerator and may specify one of the four
treatment options described above for the refractory brick (Section 264.112(b)(4)).
RO 14515