Surface impoundments

Report the total of all releases to the air that are not released through stacks, vents, ducts, pipes, or any other confined air stream. You must include (1) fugitive equipment leaks from valves, pump seals, flanges, compressors, sampling connections, open-ended lines, etc. (2) evaporative losses from surface impoundments and spills (3) releases from building ventilation systems and (4) any other fugitive or non-point air emissions. 

Quantities of the chemical released to surface impoundments that are used merely as part of a wastewater treatment process generally must cal be reported in this section. However, if the impoundment accumulates sludges containing the chemical, you must include an estimate in this section unless the sludges are removed and otherwise disposed of (in which case they should be reported underthe appropriate section of the form). For the purposes of this reporting, storage tanks are not considered to be a type of disposal and are not to be reported in this section of the form. 

Releases fo Land. Wastewater from the grid paste mixing scrubber is discharged to a surface impoundment and evaporated. Aithough your facility historically has removed lead sludge Irom the surface Impoundment each year, this has not been done for the past two years, as process changes have caused the sludge to accumulate more slowly than In previous years. Therefore, the impoundment must be considered an on-site land disposal unit, and releases to the impoundment must be reported in Part III, Section 5.5.1, of the form, and not in Part III, Section 5.3. 

The facility wastewater monitoring program does not determine the concentration of lead and lead compounds in the scrubber discharge water, and releases to the surface impoundment (releases to land) must be calculated using mate-riai balance information. These releases to land are determined from the amount of lead removed by the scrubber (using the efficiency data provided by the scrubber manufacturer). The volume of the scrubber blowdown Is found to be 1,500 pounds per year. Enter the estimate of the amount of lead and lead compounds released to surface Impoundments in the space provided in Part III, Section 5.5.3 of the form. Because releases of lead to the surface Impoundment are greater than 999 pounds per year, you must enter the actual calculated amount in column A.2 of Section 5.5.1. The basis for the estimate of releases to the surface impoundment, entered in column B of Section 5, is mass balance calculations (code C). 

Sample and Analyze to Document the Conbentration of Constituents Left in Place When a Surface Impoundment Handling Characteristic Wastes is Clean Closed... 

Methods to Control Releases from Surface Impoundments... 

An enclosure is usually an air-supported structure which permits the collection and treatment of gaseous wastes produced by surface impoundments. Enclosures are susceptible to wind damage and can be harmed by the wastes they cover. Subject to these limitations, control effectiveness approaches 100 percent (University of Arkansas and Louisiana State University, 1985). 

A variety of containment strategies employ floating solid objects to control the rate of gaseous emissions from surface impoundments. These include synthetic membrane covers, rafts, and hollow plastic spheres. Synthetic membrane covers are feasible where the out-gassing of volatiles due to biological activity is not expected. Selection of the liner material must be... 

University of Arkansas and Louisiana State University. In-Situ Methods for the Control of Emissions from Surface Impoundments and Landfills. Draft Final Report. Prepared for U.S. Environmental Protection Agency. Contract No. CR810856. June 1985. pp. 95. 

The processes used in the primary production of lead produce several wastestreams of concern under different regulatory scenarios. The listed RCRA hazardous wastes include smelting plant wastes that are sent to surface impoundments to settle. The impoundments are used to collect solids from miscellaneous slurries, such as acid plant blowdown, slag granulation water, and plant... 

Store used oil in tanks and containers. Storage of used oil in lagoons, pits, or surface impoundments is prohibited, unless these units are subject to hazardous waste TSDF standards. 

The TSDF standards also establish requirements to ensure that hazardous waste management units are closed in a manner that protects human health and the environment. The closure provisions require the facility to stop accepting waste remove all waste from management units and decontaminate all soils, structures, and equipment. Some units (i.e., land treatment units, landfills, and surface impoundments) serve as places for the final disposal of hazardous waste. These land disposal units must comply with additional postclosure requirements to ensure proper long-term unit maintenance. 

RCRA s TSDF standards also include provisions to protect groundwater and air resources from hazardous waste contamination. RCRA requires owners and operators of land-based units (i.e., land treatment units, landfills, surface impoundments, and waste piles) to monitor the groundwater below their TSDF for possible contamination, and clean up any discovered contamination. 

In order to protect air resources, TSDFs are required to install unit controls to prevent organic emissions from escaping into the air. The air emission controls apply to process vents, equipment leaks, containers, surface impoundments, and tanks. 

FIGURE 12.5 Cross section of a surface impoundment. (Adapted from U.S. EPA, RCRA Orientation Man ual, www.epa.gov/waste/inforesources/pubs/orientat/roml.pdf.)... 

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. 

National capacity variance When developing a treatment standard, U.S. EPA examines the available treatment capacity to determine whether it is sufficient to handle current and future waste management needs. If U.S. EPA determines that nationally there is not enough capacity to treat a waste, it can automatically extend the effective date of the waste s treatment standard. Such an extension to the effective date is intended to give the waste treatment industry more time to develop the capacity to handle the waste. Wastes under a national capacity variance can be disposed of, without meeting the treatment standards, in landfills and surface impoundments that meet minimum technical requirements (e.g., liners, leachate collection and removal systems, and leak detection systems). 

Case-by-case extensions A facility may petition U.S. EPA for a case-by-case extension to delay the effective date of a waste s treatment standard upon showing that capacity does not exist for that particular waste. Similar to national capacity variances, wastes granted case-by-case extensions can be disposed of without meeting the treatment standards in landfills and surface impoundments that meet minimum technical requirements. 

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. 

It is handled in a manner inconsistent with its use as a raw material or commercial product substitute (e.g., storing materials in a leaking surface impoundment as compared to a tank in good condition that is intended for storing raw materials). 

The sources of contamination are usually those hazardous materials that are contained in drums, tanks, surface impoundments, waste piles, and landfills, as well as heavily contaminated media (such as soil) affected by the original leaking or spilling source. The purpose of defining sources of contamination is to help to identify the source location, potential releases, and engineering characteristics that are important in the evaluation of remedial actions, as well as waste characteristics, such as the type and quantity of contaminants that may be contained in or released to the environment, and the physical or chemical characteristics of the hazardous wastes present in the source. 

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