Management facilities, hazardous wastes, RCRA

The Resource Conservation and Recovery Act (RCRA) identifies both compounds for groundwater monitoring at hazardous waste management facilities (EPA 1987a). RCRA also designates 1,3,5-TNB as a hazardous waste when it occurs as a discarded commercial product, off-spec species, container residue, or spill residue (EPA 1980a). 

The U.S. Environmental Protection Agency (EPA) authorizes states to regulate hazardous wastes within their borders under RCRA using provisions that are no less stringent than the requirements adopted by the EPA (40 CFR 271). Kentucky and Colorado, as well as all of the states with currently operating chemical agent disposal facilities, have obtained EPA authorization to implement and enforce state requirements for the management of hazardous waste. 

The technical differences between site problems at RCRA facilities and CERCLA sites sometimes may be difficult to distinguish, owing to similarities in present or past uses of the site, in hydrogeologic setting, and/or in the types of substances disposed, spilled, or otherwise managed at the site. Consequently, many technical aspects of the study and remediation of releases of hazardous wastes and constituents from RCRA facilities often will closely parallel those at Superfund sites, and cleanups under both statutes must achieve similar goals for protection of public health and the environment. Additionally, activities which would be termed removal actions or expedited response actions under CERCLA may be undertaken by owners and operators under RCRA. In the RCRA context, such actions are termed interim measures, as will be discussed in subsequent chapters. 

Hazardous waste generators To ensure proper and safe waste management, the RCRA regulations provide management standards for those facilities that produce hazardous waste and provide reduced regulations for facilities that produce less waste. 

Hazardous waste transporters To govern the transport of hazardous waste between management facilities, RCRA regulates hazardous waste transporters. 

The RCRA statute additionally grants U.S. EPA broad enforcement authority to require all hazardous waste management facilities to comply with the regulations. The program also contains provisions that allow U.S. EPA to authorize state governments to implement and enforce... 

For off-site land disposal of wastes resulting from a CERCLA activity, the program contains two additional requirements. First, the unit in which the wastes are to be disposed must not be releasing hazardous wastes or constituents into groundwater, surface water, or soil. Second, any releases from other units of the facility must be under an approved RCRA corrective action program. This policy assures that wastes shipped off-site from CERCLA sites are sent to environmentally sound waste management facilities. 

Under the RCRA, the hazardous waste management program is based on a cradle-to-grave concept, so that all hazardous wastes can be traced and accounted for fully. Section 3010(a) of the act requires all generators and transporters of hazardous wastes as well as owners and operators of all TSD facilities to file a notification with the ERA within 90 days after the promulgation of the regulations. The notification should state the location of the facility and include a general... 

The section of the RCRA of most concern to the chemical industry is Subtitle C, the hazardous waste management regulations. The purpose of this section is to regulate hazardous wastes from their generation to their disposal. Facilities that generate, treat, store, or dispose of hazardous wastes are covered by these regulations. 

Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)/RCRA regulations in effect at the end of 1986 bromine is regulated as a hazardous waste or material. Therefore, it must be disposed of in an approved hazardous waste facility in compliance with EPA and/or other applicable local, state, and federal regulations and should be handled in a manner acceptable to good waste management practice. The... 

Management and disposal of hazardous chemical waste under RCRA is based on detailed and prescriptive technical requirements that apply to any facility for waste treatment, storage, or disposal, whereas management and disposal of low-level radioactive waste is more flexible because AEA allows consideration of waste- and site-specific factors. As a consequence, acceptable approaches to management and disposal of mixed low-level waste probably will be determined primarily by RCRA requirements, unless exempt levels of hazardous chemicals are established that render the waste nonhazardous under RCRA. 

There are some differences in the specific waste disposal management schemes at the five sites that were reviewed. Most of the differences between the five chemical destruction facilities are due to the different implementation strategies in place in the five different states, particularly permit parameters and requirements. Each state has a program for granting permits for the construction and operation of TSDFs. Permits implement the general RCRA requirements in the design, construction, and operation of a TSDF. They also establish appropriate site-specific conditions for almost every aspect of the hazardous waste management and destruction processes used. 

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