Hazardous waste regulated units

Thermal treatment is used to destroy, break down, or aid in the desorption of contaminants in gases, vapors, Hquids, sludges, and soHds. There are a variety of thermal processes that destroy contaminants, most of which are classified as incineration. Incineration HteraHy means to become ash (from Medieval Latin, incinerare in or into ashes). With respect to the incineration of hazardous wastes regulated in the United States, however, there is a strict legal definition of what constitutes an incinerator. The Resource Conservation and Recovery Act (RCRA) definition of incinerator at 40 CFR 260.10 is... 

Figure 23.1 provides a compilation of information on reported emergency incidents at hazardous waste combustion facilities and other TSDFs regulated under the RCRA. It covers emergency incidents such as fires, explosions, hazardous waste spills, or unauthorized releases of hazardous waste. The reported incidents at 24 hazardous waste combustion units and 26 other TSDFs... 

In addition to these exemptions, there are three types of units that are conditionally exempt from the regulations. These are metal recovery furnaces, precious metal recovery units, and certain other special industrial units. In order to claim these exemptions, owners/operators must provide a onetime written notice claiming the exemption, conduct sampling, and analysis, and maintain records to demonstrate compliance with all applicable requirements. Any waste management prior to burning in this type of unit, and any resulting residues, are subject to applicable hazardous waste regulation. 

This wastewater is often cleaned further by other treatment systems (filters, impoundments, etc.). The solids separating in these systems continue to be API separator sludge, a listed hazardous waste. Therefore, all downstream wastewater treatment systems are receiving and treating a hazardous waste and are considered hazardous waste mauagement units subject to regulation. 

New Hazardous Waste Regulations were introduced in July 2005 and under these regulations lamps and tubes are classified as hazardous. While each lamp contains only a small amount of mercury, vast numbers of lamps and tubes are disposed of in the United Kingdom every year, resulting in a significant environmental threat. 

California and Minnesota have placed restrictions on the disposal of fluorescent light tubes, which contain from 40—50 mg of mercury per tube, depending on size. After batteries, fluorescent lamps are the second largest contributor of mercury in soHd waste streams in the United States (3,14). A California law classifies the disposal of 25 or more fluorescent lamp tubes as hazardous waste. In Minnesota, all waste lamps generated from commercial sources are considered hazardous waste. Private homes are, however, exempt from the law (14). Other states have proposed similar regulations. Several companies have developed technologies for recovering mercury from spent lamps (14). 

Aeration basins can be constmcted as concrete or steel tanks or earthen impoundments, although tanks are more common in the United States now because of ground water problems with leakage from impoundments and stringent regulation of impoundments for the treatment of hazardous waste. 

In the United States, the Resource Conservation and Recovery Act of 1976 (RCRA) is the major legislation covering the disposal of solid and hazardous wastes (2). This act provides a multifaceted approach to solving the problems associated with the generation of approximately 5 billion metric tons of solid waste each year in the United States. It places particular emphasis on the regulation of hazardous wastes. This law established the Office of Solid Waste within the Environmental Protection Agency and directed the agency to publish hazardous waste characteristics and criteria. 

Congress, in an attempt to promote mineral development in the United States, has exempted most hazardous wastes produced at the wellsite under the Resource Conservation and Recovery Act (RCRA) Subtitle C regulations. Hazardous wastes are listed due to inherent characteristics of ... 

Universal waste destination facilities are facilities that treat, dispose of, or recycle a particular category of universal waste. These facilities are subject to the same requirements as fully regulated hazardous waste TSDFs. Full regulation includes permit requirements, general facility standards, and unit-specific standards. The universal waste program includes only two additional specific universal waste requirements for destination facilities. These requirements are procedures for rejecting shipments of universal waste and the documentation of the receipt of universal waste. 

The RCRA regulations broadly define the term generator to include any person, by site, who first creates or produces a hazardous waste (e.g., from an industrial process) or first brings a hazardous waste into the RCRA system (e.g., imports a hazardous waste into the United States). 

A hazardous waste transporter is any person engaged in the off-site transportation of hazardous waste within the United States, if such transportation requires a manifest. Off-site transportation of hazardous waste includes shipments from a hazardous waste generator s facility property to another facility for treatment, storage, or disposal. Regulated off-site transportation includes shipments of hazardous waste by air, rail, highway, or water. 

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. 

Surface impoundment treatment exemptions Surface impoundment treatment exemptions allow the regulated community to petition U.S. EPA for permission to treat hazardous waste in surface impoundments. Under normal circumstances, owners and operators cannot place untreated hazardous waste on the land, even if it is in a land-based unit for treatment. Since many facilities use surface impoundments as a means of treating waste, the surface impoundment treatment exemption allows owners and operators to conduct such treatment under certain conditions. Surface impoundments treating waste under this exemption must comply with double liner and minimum technical requirements, and provisions for the removal of sludges and treatment residues. 

The management or disposal of metals and ash, other by-products of the combustion process, also causes concern. Ash is an inert solid material composed primarily of carbon, salts, and metals. During combustion, most ash collects at the bottom of the combustion chamber (bottom ash). When this ash is removed from the combustion chamber, it may be considered hazardous waste via the derived-from rule or because it exhibits a characteristic. Small particles of ash (particulate matter that may also have metals attached), however, may be carried up the stack with the gases (fly ash). These particles and associated metals are also regulated by the combustion regulations, as they may carry hazardous constituents out of the unit and into the atmosphere. Since combustion will not destroy inorganic compounds present in hazardous waste, such as metals, it is possible that such... 

Units burning hazardous wastes that are exempt from RCRA regulation, such as household hazardous wastes. 

Hazardous waste burning incinerators, cement kilns, and LWAKs do not follow a tiered approach to regulate the release of toxic metals into the atmosphere. The MACT rule finalized numerical emission standards for three categories of metals mercury, low-volatile metals (arsenic, beryllium, and chromium), and semivolatile metals (lead and cadmium). Units must meet emission standards for the amount of metals emitted. For example, a new cement kiln must meet an emission limit of 120pg/m3 of mercury, 54pg/m3 of low-volatile metals, and 180 pg/m3 of semivolatile metals. 

Residues from the combustion of hazardous waste are also potentially subject to RCRA regulation. If a combustion unit bums a listed hazardous waste, the ash could also be considered a listed waste via the derived-from rule. The owner and operator must also determine whether this ash exhibits any hazardous waste characteristics. The same is true if a unit bums waste that only exhibits a characteristic. Ash that exhibits a characteristic must be managed as a hazardous waste. 

Once hazardous wastes are transported from a CERCLA site, they are subject to full RCRA regulation. Therefore, all transportation and TSD requirements under RCRA must be followed. This means that off-site shipments must be accompanied by a manifest. In particular, the off-site disposal of hazardous wastes can occur only at an RCRA facility in a unit in full compliance with the requirements. U.S. EPA policy requires that the disposal facility be inspected six months prior to receiving the waste. 

The hazardous waste listings, the hazardous waste characteristics, and the mixture and derived-from rules are all essential parts of the definition of hazardous waste, but these key elements are all described in different sections of the RCRA regulations. Only one regulatory section unites all four elements to establish the formal definition of hazardous waste. This section is entitled Definition of Hazardous Waste, which states that all solid wastes exhibiting one of the four hazardous characteristics are hazardous wastes. This section also states that all solid wastes listed on one of the four hazardous waste lists are hazardous wastes. Finally, this section explains in detail the mixture and derived-from rules and the regulatory exemptions from these rules. Thus, although the section is entitled Definition of Hazardous Waste, it serves primarily as a guide to the mixture and derived-from rules. 

TSDFs). U.S. EPA promulgated both general facility standards that apply to all TSDFs and requirements for specific types of units (e.g., incinerators, landfills, and surface impoundments) in 40 CFR Parts 264 and 265. The regulations under Parts 264 and 265, Subpart O, apply to owners and operators of facilities that incinerate hazardous waste.4... 

Combustion is a technology employed to burn hazardous waste for energy or materials recovery. This occurs in a group of units collectively known as BIFs. The following sections will provide an overview of the regulation of these units, found in 40 CFR Part 266, Subpart H.5 21... 

Units burning hazardous wastes exempt from regulation under Section 261. 

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