Hazardous waste exceptions

When directing U.S. EPA to establish the LDR program, Congress called for regulations that specified concentrations of hazardous constituents or methods of treatment that would substantially decrease the toxicity of hazardous waste or decrease the likelihood that contaminants in such wastes would leach. U.S. EPA responded to these requirements by establishing waste-specific treatment standards that dictate to what extent waste must be treated. All hazardous wastes, except under certain circumstances, must meet a specific treatment standard before they can be disposed of. 

If the neutralent is a RCRA characteristic hazardous waste, it must be treated in accordance with LDRs before being disposed of in a hazardous waste landfill. Thus, constituent levels must be reduced from those shown in Table C-1 to the treatment technology-based limits before disposal in a landfill. Again, nonstockpile agent is not a listed hazardous waste (except for phosgene), and neither ERA nor the states have specified a treatment technology or treatment limits for the disposal of stockpile or nonstockpile agents. 

CFR 261.33, listed hazardous waste - EPA RCRA Hazardous Waste Number. All the solvents that are on the RCRA list are listed because of Section 3001 of RCRA (part fm identification and hsting of hazardous waste) except hexane which is on because of CAA Section 112 (HAP). 

From Title III Lists of Lists, U.S. EPA, EPA 740-R-95-001 (April 1995) 40 CFR 52-99 (59 FR 4478 January 31, 1994) hexane added to TRI list (60 FR 31633 June 16,1995) acetone removed from TRl list Mo CFR 261.33, listed hazardous waste - EPA RCRA Hazardous Waste Number. All the solvents that are on the RCRA list are listed because of Section 3001 of RCRA (part for identification and listing of hazardous waste) except hexane which is on because of CAA Seetion 112 (HAP). 

The design of this fish study centered on sample collection, preservation, preparation, analysis, and QA/QC. There was no discussion of the effect of compositing on the sample population. No description was given of statistical techniques to be applied to the data for reporting results and for comparison with action levels and future data. Unfortunately, the omission of a statistical framework during planning of the field study is the rule rather than the exception in hazardous waste investigations. 

This series of prohibitions restricts how wastes subject to LDR requirements are handled. The most visible aspect of the LDR program is the disposal prohibition, which includes treatment standards, variances, alternative treatment standards (ATSs), and notification requirements. Land disposal means placement in or on the land, except in a corrective action unit, and includes, but is not limited to, placement in a landfill, surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, underground mine or cave, or placement in a concrete vault, or bunker intended for disposal purposes. The other two components work in tandem with the disposal prohibition to guide the regulated community in proper hazardous waste management. The dilution prohibition ensures that wastes are properly treated, and the storage prohibition ensures that waste will not be stored indefinitely to avoid treatment. 

Emissions from hazardous waste combustors are regulated under two statutory authorities RCRA and the CAA. The MACT standards set emission limitations for dioxins, furans, metals, particulate matter, total chlorine, hydrocarbons/carbon monoxide, and destruction and removal efficiency (DRE) for organics. Once a facility has demonstrated compliance with the MACT standards by conducting its comprehensive performance test (CPT) and submitting its notification of compliance (NOC), it is no longer subject to the RCRA emission requirements with a few exceptions. RCRA-permitted facilities, however, must continue to comply with their permitted emissions requirements until they obtain modifications to remove any duplicative emissions conditions from their RCRA... 

There are two major areas of overlap between MPRSA and RCRA. MPRSA prevents waste from an RCRA generator or TSDF from being deposited into the ocean, except in accordance with a separate MPRSA permit. In addition, dredged materials subject to the requirement of an MPRSA permit are not considered as hazardous wastes under RCRA.2... 

Table 20.5 lists the partition and transformation processes applicable in the deep-well environment and indicates whether they significantly affect the toxicity or mobility of hazardous wastes. None of the partition processes results in detoxification (decomposition to harmless inorganic constituents), but all affect mobility in some way. All transformation processes except complexation can result in detoxification however, because transformation processes can create new toxic substances, the mobility of the waste can be critical in all processes except neutralization. 

With few, if any, exceptions, deep-well injection zones will be sedimentary rock, and the reactions that take place when hazardous wastes are injected are determined largely by the physical and... 

A major difference between organic and inorganic hazardous wastes is that, with the exception of cyanide, inorganics cannot be destroyed by being broken down into nonhazardous component parts, because at least one element in the compound is toxic. Inorganic hazardous wastes containing toxic elements can be transformed from a more to a less toxic form, but can never be transformed to a nontoxic form. 

All devices classified as incinerators that burn hazardous waste must follow the Subpart O standards, with the following exception. The Regional Administrator must exempt an owner/operator applying for a permit from all of the incinerator standards in Subpart O, except waste analysis and closure, if the hazardous waste fed into an incinerator is considered as low-risk waste. The criteria for defining a waste as low risk are as follows4 ... 

Interim status furnaces are required to comply with all of the performance standards with the exception of the DRE. In addition, U.S. EPA established special interim status requirements for industrial furnaces to ensure adequate combustion of hazardous waste until more stringent, permitted conditions could be established through completion of the facility s trial bum. These conditions include minimum temperatures, assurance of adequate oxygen, and continuous hydrocarbon monitoring. 

Municipal waste (MW) Always relevant except intermediates only use in processing aids Articles waste for recycling (RW -solid) Relevant if substance is induded in aifides of glass, paper, plastics, rubber, metal, construction material or in specific articles (cars. EEE etc ) Hazardous waste (HW) Substances as such or in chemical products, liquid wastes for recycling... 

Detections of endrin in groundwater are also rare except from wells near hazardous waste sites. The EPA Pesticides in Groundwater Data Base (EPA 1989) contains groundwater data collected with good quality assurance/quality control (QA/QC) provisions from areas with significant agricultural land uses as well as... 

Bioavailability from Environmental Media. Absorption of endrin following inhalation has been shown to occur in laboratory animals (Treon et al. 1955) and endrin can also be absorbed by humans following inhalation of contaminated air (Hoogendam et al. 1965). Since endrin has a low volatility, inhalation is probably not a major concern except for potential inhalation of contaminated dust at hazardous waste sites. 

Exposure Levels in Humans. Metabolism of endrin in humans is relatively rapid compared with other organochlorine pesticides. Thus, levels in human blood and tissue may not be reliable estimates of exposure except after very high occupational exposures or acute poisonings (Runhaar et al. 1985). Endrin was not found in adipose tissue samples of the general U.S. population (Stanley 1986), or in adipose breast tissue from breast cancer patients in the United States (Djordjevic et al. 1994). Endrin has been detected in the milk of lactating women (Alawi et al. 1992 Bordet et al. 1993 Dewailly et al. 1993), but no data from the United States could be located. Data on the concentrations of endrin in breast milk from U.S. women would be useful. No information was found on levels of endrin, endrin aldehyde, or endrin ketone in blood and other tissues of people near hazardous waste sites. This information is necessary for assessing the need to conduct health studies on these populations. 

Except for the GB and HD test campaigns, for which the data were incomplete, the stack offgas did meet hazardous waste combustion and thermal treatment regulations and requirements criteria for waste streams. 

Hydrotreating also produces some residuals in the form of spent catalyst fines, usually consisting of aluminum silicate and some metals (e.g., cobalt, molybdenum, nickel, tungsten). Spent hydrotreating catalyst is now listed as a hazardous waste (K171) (except for most support material). Hazardous constituents of this waste include benzene and arsenia (arsenic oxide, AS2O3). The support material for these catalysts is usually an inert ceramic (e.g., alumina, AI2O3). 

Humans are susceptible to the acute toxic effects of 1,2-dibromoethane from various routes of exposure. Except for adverse reproductive effects in men after occupational exposure, chronic effects of 1,2-dibromoethane exposure have not been documented in humans. Based on data derived from animal studies, mechanisms of action of 1,2-dibromoethane at a cellular level, toxicokinetics, and genotoxicity tests, there is a potential for certain adverse health effects in humans exposed chronically to low environmental levels of 1,2-dibromoethane that could exist near hazardous waste sites or areas of former agricultural use. 

The animal studies for oral exposure to heptachlor and heptachlor epoxide are almost all limited to some extent by the number of doses used, the lack of appropriate statistics, or the small number or lack of controls. No information was located regarding the health effects of inhalation or dermal exposure, with the exception of a dermal LDso in rats. Exposure of the general population via the inhalation and dermal routes may result from contaminated soil or vapors from treated houses. Some exposures from contaminated soil or water may occur in populations located near hazardous waste sites in which these chemicals have been stored or from food grown in contaminated soil. 

If the industrial plant s manager or consulting engineer does not receive a copy of the manifest from the receiving facility (i.e., the disposal facility and/or the recychng facihty) within 35 days of the date when the plant s waste was shipped, the transporter or the operator of the facility must be contacted to determine the stams of the waste. If the plant has still not received the manifest within 45 days, an Exception Report, explaining the efforts the plant has taken, must be filed with the State s Division of Hazardous Waste and with the State where the designated facility is located. 

Each container holding hazardous wastes must be tightly closed throughout the period of accumulation, except when the waste is being added or removed ... 

Figure 10 Refinery schematic diagram indicating representative sources of solid waste in wastewater treatment system. All wastes except waste activated sludge are classified as hazardous wastes because of their oil contents. (From Ref. 18.)...

Hexachlorobutadiene did not adversely affect reproduction in animals except at high doses (150 mg/kg/day for 10 weeks). Although there was some evidence of fetotoxicity in animals after inhalation (10 ppm) or oral (15 mg/kg/day) exposure, embryolethality and teratogenicity were not detected. Oral studies in animals indicate that hexachlorobutadiene may increase the risk of renal cancer at dose levels of 20 mg/kg/day. The effects of hexachlorobutadiene are most pronounced after repeated chronic exposure to low doses, suggesting that effects are cumulative. For this reason, there is greater concern for populations living near hazardous waste sites, where exposure to low levels may occur for long periods of time, than for acute exposure scenarios. 

Waste streams from sites of HDI or HDI polymer production may release HDI or HDI prepolymers to water. No information is available in the TRI database on the release of HDI to water from facilities that produee or proeess HDI because this eompound is not included imder SARA, Title III, and therefore, is not among the ehemieals that facilities are required to report (EPA 1995). HDI and HDI prepolymers may also be released to water at hazardous waste sites however, no information was foimd on detections of HDI in water at any NPL or other Superfund hazardous waste sites (HazDat 1996). Because of its reactivity with water to form amine or polyurea derivatives (Chadwick and Cleveland 1981 Hulse 1984 Kennedy and Brown 1992), monomeric HDI is not likely to be foimd in waste water streams or in other aquatic environments except near sources of release. Small amounts of HDI that have become encapsulated in water-insoluble polyurea agglomerates may persist in water (see Section 5.3.2.2). 

Except for occupational settings, no information was formd in the available literature on eoncentrations of HDl or HDl prepolymers in air. Because of the relatively short atmospheric half-life (approximately 2 days) from reaction with hydroxyl radicals (see Section 5.3.2.1), significant atmospheric concentrations of HDl would be expected to be found only near sources of this substance (e.g., waste streams from manufacturing or processing facilities, hazardous waste sites, occupational settings). Atmospherie eoneentrations of HDl and HDI-BT found in occupational settings are siunmarized in Section 5.5. 

No information was found in the available literature on concentrations of HDl or HDl prepolymers in water. Because of the expected rapid hydrolysis of HDl, significant concentrations may not be found in water, except near sources of this substance (e.g., industrial waste streams, hazardous waste sites). Small amoimts of unreacted HDl may persist in water if eneapsulated in water-insoluble polyurea erusts formed during hydrolysis (Gilbert 1988). 

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