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DRAFTRCRA MISCELLANEOUS TREATMENT UNITS

ENCYCLOPEDIA XTECHNICAL RESOURCE DOCUMENT

Preparedby:

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION 4

RCRA PROGRAMS BRANCH

April 2002

Draft Encyclopedia X April 2002

Executive Summary

The information in this document has been funded by the United States Environmental Protection Region 4.This guidance was developed by EPA Region 4 in cooperation with a few states as well as many EPAoffices. This guidance does not constitute rulemaking by the EPA and may not be relied on to create asubstantive or procedural right or benefit enforceable, at law or in equity, by any person. EPA may changethis document at any time without public notice. The mention of trade names or commercial products doesnot constitute endorsement or recommendation for use by EPA.

EPA would like to acknowledge the support of:

Carl Daly, EPA Region 8 John Crawford, Indiana Department of Environmental Management Mike Mikulka, EPA Region 5


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1.0 INTRODUCTION

On December 10, 1987, under 52 FR 46946, EPAissued regulations that outlined procedures forissuing permits to miscellaneous units that treat,store, or dispose of hazardous waste. Thoseregulations, which were codified at 40 CFR Part264, Subpart X, created a new category of hazard-ous waste management unit (known as the miscella-neous unit or Subpart X unit). Such units weredefined as those that do not meet any of the defini-tions in Part 264 of other types of hazardous wastemanagement units. The purpose of this document isto provide EPA and State permit writers andinspectors with guidance for reviewing permitapplications, establishing enforceable permit condi-tions for, and conducting inspections of Subpart Xunits.

The primary element of the Subpart X permittingregulations requires that the permit applicant performan environmental assessment to demonstrate that theoperation of the proposed unit will be protective ofhuman health and the environment. The assessmentmust consider the effects of the proposed unit on air,subsurface environment, and surface water and soils.The assessment must include information about thecharacteristics of the waste to be treated, the designand operating characteristics of the unit, and poten-tial receptors of releases from the unit. For manytypes of Subpart X units, particularly mechanicalunits such as shredders, crushers and filter presses,an environmental assessment may not be necessary.This is especially true in cases where the unit is fullyenclosed in a containment structure such as abuilding. The applicant must be able to justify thatan environmental assessment is unnecessary. Thisdocument identifies the minimum requirements forsuch an assessment and provides guidance forevaluating information submitted by permit appli-cants and using that information to develop permitconditions.

Although the Subpart X permitting regulations rely toa great extent on an environmental performancestandard (i.e., protection of human health and theenvironment), permit writers should attempt to


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establish permit conditions for the units that includespecific requirements governing location, design,operation, and maintenance. In general, the bestway to accomplish this is to selectively apply thedesign and operating requirements for hazardouswaste management units set forth under 40 CFRPart 264, Subparts I through O, that may apply tothe unit under application (264.601). Such anapproach will allow the permit writer to use permitconditions that have been proven effective, protec-tive of human health and the environment, and thatare less vulnerable to challenge by permit applicants.Appendix A contains a permit review checklist.Appendices B - E provide model permit languageand example permits for a variety of Subpart Xunits. Appendices F through H provides inspectionchecklists for a number of Subpart X units.

The Subpart X permitting process is unique underRCRA because the types of units being permittedmay have obtained interim status as a number ofdifferent types of units as specified in Part 265 (e.g.,units that are eligible to be permitted under SubpartX are open burning/open detonation (OB/OD) units,which would have obtained interim status as thermaltreatment units and are currently operating under therequirements of Part 265, Subpart P).

The general approach for issuing permits to ownersor operators that submit Subpart X permit applica-tions is to permit these units as conventional hazard-ous waste management units whenever possible.Although not applicable to OB/OD units, thisapproach is preferred for other types of miscella-neous units because the design and operatingstandards contained in other Subparts of Part 264are well understood by permit writers and applicantsand are less likely to be challenged by a permitapplicant than permit conditions developed specifi-cally for Subpart X units. Even in cases where apermit writer cannot permit a unit under the stan-dards applicable to one of the conventional units inPart 264, a permit writer may be able to use specificdesign and operating requirements from one or moreof these Subparts in developing permit conditions.In many cases, the approach described above will

An overview of the key definitions and termsassociated with 40 CFR Part 264, Subparts Ithrough O is provided in the Definitionsdocument.


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minimize the time and effort required to issue apermit for a prospective Subpart X unit.

1.1 Applicability

Because Subpart X is an exclusionary category, avariety of treatment and disposal units are consid-ered. Some of the types of operational units that arediscussed in this document include open burn/opendetonation (OB/OD) units, enclosed combustiondevices, carbon and catalyst regeneration units,thermal desorption units, shredders, crushers, filterpresses and geologic repositories. A number ofinnovative and emerging technologies for the treat-ment of hazardous wastes also may be consideredfor permitting under Subpart X.

1.2 Purpose of the Document

This document provides to permit writers guidancefor evaluating information submitted by permitapplicants addressing the information requirementsspecific to Subpart X units under 270.23. Thespecific information requirements for Subpart Xpermit applicants ensure that the environmentalperformance standard will be met, and includes aunit description; information about pathways ofexposure and potential receptors; and, for treatmentunits, a demonstration of the effectiveness of treat-ment. The permit writer then develops permitconditions for the general facility standards in Part264, Subparts A through H, as applicable, and thespecific standards of Subpart X.

Although the Subpart X permitting process is uniqueunder RCRA, Subpart X permit applicants mustmeet the same basic objectives as applicants forpermits for other types of units. Permit writersshould request information from applicants todemonstrate compliance with general standardsgoverning TSDFs and require a thorough risk andenvironmental assessment to demonstrate that theoperation of the unit will be protective of humanhealth and the environment. Miscellaneous units canpose unique problems in the areas of waste charac-terization, modeling and monitoring of environmentaleffects, closure, and corrective action. This docu-


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ment highlights those areas by providing informationto assist permit writers with technical and policyissues associated with those areas.

Throughout the document, the reader is informed ofa variety of other guidance and policy documents,tools and resources available to the regulatorregarding Subpart X and other related topics. Manyof the referenced documents will be directly appli-cable to the needs of the permit writer and/orinspector and should be evaluated carefully todetermine how best they can be used. The readercan be directly linked to the referenced document orwebsite by simply clicking on the blue highlightedtext. References used in preparing this guidance arefound at the end of the individual chapters.

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2.0 SUBPART X UNITS

This chapter provides basic descriptions of the moretypical units permitted as Subpart X units. Thechapter also discusses circumstances when it may beappropriate to permit proposed miscellaneous unitsas conventional hazardous waste management units.Examples of patented or trademark technologies arediscussed throughout this chapter. However, theAgency does not endorse the technology availablefrom any specific company.

2.1 Types of Thermal Units Included UnderSubpart X

2.1.1 Open Burning and Open DetonationUnits

Many waste propellants, explosives, andpyrotechnics (PEP), and munitions items are unsafeto treat by conventional methods of hazardous wastemanagement. Open burning and open detonation(OB/OD) remain the primary methods of treatmentfor these wastes. Currently, research is beingconducted to develop alternative methods oftreatment for PEP wastes. New technologies, suchas enclosed detonation chambers, are likely tobecome more widely available in the next severalyears. Some of these new technologies may qualifyfor permitting under Subpart X.

The unit descriptions provided here focus on militaryOB/OD units, because the majority of the units areoperated by the military. The design configurationsand operational standards discussed in this sectionwill, however, also be used at non-military facilities.

2.1.1.1 Open Burning: Physical and ProcessDescription

Open burning (OB) is used primarily to destroypropellants, and is generally conducted onengineered structures such as concrete pads, ormetal pans to avoid contact with the soil surface.Such structures may range in size from 3 to 5 feetwide by 5 to 20 feet long, and are 1 to 2 feet deep.OB pans should be made of a material sufficient to

View of burning pans on a secondarycontainment pad. Note that the pads do notappear to have berms around them.

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withstand the burning process, and should be ofsufficient depth and size to contain treatmentresidues. The pans may be elevated slightly abovethe ground to enhance cooling and to allowinspections for leaks. The pans should be coveredwhen they are not in use to prevent precipitationfrom entering them. Pans may be equipped withports for draining collected precipitation or cleaningsolutions. Collected precipitation should not bedischarged onto the ground unless the pan wasdecontaminated after its last use, or unless theprecipitation is sampled and analyzed anddetermined not to contain hazardous constituents. Ametal cage placed over the burn unit duringtreatment may be helpful to minimize the ejection ofresidues from the unit.

The ground beneath the trays or pans may besurrounded by berms to prevent runon and runofffrom the area; however, a well-designed andoperated burn pan may not require berms. Groundcover around and beneath the pans should beprepared for ease of recovery of ejected treatmentresidues and for prevention of fire hazards that suchresidues may pose. Maintenance of a packed soilsurface is the minimum preparation sufficient toaccomplish those goals.

To prevent propagation of an accidental detonationfrom one device to another, DoD regulations requirecontainment devices, trenches, and individual groundtreatment units be spaced at least 150 feet apart.Detailed design specifications for containmentdevices, whether trenches, pans or other types ofcontainment, should be included in the permitapplication.

Waste propellant to be treated is often contained inbags, which are placed directly into the unit. Thewaste may be primed (that is, an initiating device isplaced in the waste material) either electrically ornon-electrically with black powder squibs. Thewaste is then ignited and the established wait time isobserved. If explosives are treated, a wait time of atleast 12 hours typically is observed before siteworkers inspect the unit. A 24-hour wait timetypically is observed between OB events to allow

Closeup view of burning pans on concreteslab. Note the white covers in thebackground which can be rolled over thepans to prevent precipitation from enteringthem.

To view a video of an open burning operation,double click on the image above.

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the surface to cool. After the OB treatment,containment devices are cleaned of any residues.OB operations generally are restricted to daylighthours, and usually are not conducted duringinclement weather.

2.1.1.2 Open Detonation Unit: Physical andProcess Description

Open detonation (OD) is used primarily to treatmunition items. OD typically is conducted in pits ortrenches below ground to minimize the ejection oftreatment residue, although surface detonations areperformed under certain circumstances. Trenchesvary in size depending on the quantity of material tobe treated, and are usually 4 feet deep or greater,and can vary in size from 4 to 8 feet wide by 6 to 15feet long.

The maximum quantities to be treated are measuredby net explosive weight (NEW), which is the totalweight of explosives in the munition. The NEWdoes not include the weight of the explosive chargeused to initiate the detonation (donor charge).Military units often use Composition (C-4) (90percent RDX and 10 percent plasticizer, such aspolyisobutylene) as a donor charge for ODoperations. The quantity of donor charge used isusually equal to the NEW of the munitions to betreated.

Open detonation involves placement of wastes at thebottom of the pit, along with the donor charge. Thewaste and charge are then covered with soil to thetop of the pit. After detonation, any treatmentresidues should be removed to minimize the potentialfor releases of hazardous waste or hazardousconstituents to the environment. Surrounding soilsshould be maintained in a manner that minimizes thepotential for fire posed by dry vegetation or otherhazards.

2.1.2 Enclosed Treatment Units

In recent years, DoD has encouraged the use ofcontrolled thermal treatment units for the destructionof pyrotechnics, small arms ammunition and

View of open detonation.

Open detonation is usally conducted in anexcavated pit to minimize the ejection oftreatment residues, although surfacedetonations may be performed. Not the raincover in the background which can be rolledover the area.

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fireworks. Examples of enclosed thermal treatmentunits include the Donovan Blast Chamber, the BlastContainment Structure and the Hurd Burn Units.

2.1.2.1 Donovan Blast Chamber

The Donovan Blast Chamber is used to performcontrolled thermal treatment of PEP in a room-sizeblast chamber. The explosion chamber consists ofan elongated double-walled steel explosion chamberanchored by bolts to a reinforced concretefoundation. In the preferred design, the insidedimensions of the chamber are eight feet high, sixfeet wide and fifty feet long. The reinforcedconcrete foundation is preferably at least four feetthick. The chamber is equipped with a double-walled access door for charging batches ofexplosives and a double-walled vent door fordischarging the products of detonation. The double-walls of the chamber, access door and vent door arefilled with a granular shock-damping material such assilica sand and the floor of the chamber is coveredwith a shock-damping bed such as pea gravel.Within the chamber, plastic polymer film bagscontaining water are suspended from steel wiresover the explosive material. Detailed drawings anddesign specifications for the unit are available inUnited States Patent No. 5,613,453. Additionalinformation can also be found athttp://www.demil.net

Materials to be treated are placed in the unit throughthe access door and onto the granular bed. Thesuspended plastic bags contain an amount of waterthat approximates the weight of the explosive. Anelectrical blasting cap is attached to the igniter leadwires. The access and vent doors are interlockedwith the electrical igniter to block ignition unless bothdoors are positively shut. When the doors areopened after a detonation, a vent fan is activatedand the gaseous products of detonation are drawnthrough the vent door opening and discharged to ascrubber system or baghouse. The DonovanChamber can be utilized to safely detonate explosivecharges in a wide variety of sizes, ranging from twoto fifteen pounds NEW. A smaller transportableversion of the chamber called the T-10 can be used

To view a video of an open detonationoperation, double click on the image above.

Exterior view of the Donovan Blast Chamber.

http://www.demil.net

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to treat up to 10 pounds NEW per shot. Stacktests have been conducted at units located at theMassachusetts Military Reservation and Blue GrassArmy Depot. Performance data from these testswere outlined in Pollutant Emission Factors for aTransportable Detonation System for DestroyingUXO.

2.1.2.2 Blast Containment Structure

The Army Corps of Engineers, Engineering andSupport Center in Huntsville, Alabama hasdeveloped a blast containment structure which isdesigned to capture all significant blast pressures fora total NEW of up to six pounds of TNT. The unitis also designed to capture all fragments from casedmunitions including 57-mm and 75-mm recoillessrifle shells, 75-mm howitzer and 60-mm and 81-mmmortars. The container consists of a steel cylinder,six feet tall and three and one-half feet in diameter,with elliptical top and bottom caps. The top cap isremovable and is held in place by a hinged steel ring.The bottom cap is permanently welded to thecylinder but it features a four-inch diameter drainport for cleanout and several one-inch diameter ventholes. The entire container is mounted on a steelframed skid. The skid includes a working platform,made of fiberglass grating, and a hoist for removingthe top cap. All steel parts are cabled together in anelectrically continuous fashion and are grounded.

The container utilizes a multi-layer fragment capturesystem to capture debris. Ordnance and a boostercharge are placed in a sand-filled plastic cylinder.Just outside the sand layer, plastic bags filled withwater are used to absorb much of the heat of theexplosion and to reduce the blast pressures.Outside the sand layer is a steel cable mat shaped inthe form of the cylinder, with a top and bottom matto protect the end caps. The mat is similiar toblasting mats used at construction sites. A steelplate liner is located between the cable mat and theouter steel shell. The liner is made in easilyremovable segments. The sand and water arereplaced after each detonation. The cable mats areexpected to last for up to ten detonations beforebeing replaced. The liner plate may survive as many

Interior view of the floor of a DonovanBlast Chamber.

Schematic of Blast Containment Chamber.

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as 50 to 75 detonations before requiringreplacement. Additional information regarding thistreatment device is available at http://www.hnd.usace.army.mil/oew/tech/techindx.html

2.1.2.3 Hurd Burn Units

The unit consists of a quarter-inch thick steel,enclosed cylindrical box equipped with a hingeddoor on one end. The cylinder or barrel is mountedon a movable trailer which may be positioned on aconcrete pad when in operation. The fuel source forthe unit is a pair of propane tanks. Waste militarymunitions are placed onto screens in the barrel of theunits. The door to the unit is closed and the propanefuel source is turned on and adjusted through aregulator. The application of a flame ignites the unit.Air holes located on both sides of the unit provideoxygen for the burn. Air emissions escape throughthe vent at the top of the unit, the air holes on theside of the unit, and through cracks in the doorway.A maximum of 25 pounds NEW may be placed intoa single burn unit at any time. The maximumtreatment time is 20 minutes. Situating the unit on asteel reinforced concrete slab will provide additionalcontainment in the event of spillage of ash orkickout. However, the unit has no air pollutioncontrol features associated with it.

2.1.2.4 Confined Burn Facility

The U.S. Navy at Indian Head has designed aConfined Burn Facility (CBF) that uses a batch-feedchamber. Upon ignition of the wastes in thechamber, the hot gases that are generated arequenched with water and stored in a containmentreservoir for subsequent scrubbing and treatment ata slow continuous rate before discharge. The fiveburn chambers of the CBF are connected via ducts,equipped with scrubbing and quenching sprays, to acentral exhaust gas storage vessel. Each burnchamber can hold up to 1,200 pounds of explosivehazardous waste. All chambers are loaded at thebeginning of the shift. Each chamber is ignited oneat a time with 40 to 80 minutes between eachignition to allow processing of all gases. The designrequires no additional pre-treatment, and it can burn

View of Hurd Burn Unit. This is a moble unitwhich can be used for treating small quantitiesof PEP.

Schematic Diagram of Hurds Burn Unit.

http://www.hnd.usace.army.mil/oew/tech/techindx.htmlhttp://www.hnd.usace.army.mil/oew/tech/techindx.html

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up to 6,000 pounds of energetics per shift. Itincludes redundant burn chambers of composite wallconstruction (inner wall is ablated during massdetonation to absorb shock waves, and it minimizesdamage to the chamber should a mass detonationoccur). It uses standard exhaust gas treatmenttechnology, and it uses burn pans similar to presentOB site operations.

2.1.3 Carbon and Catalyst RegenerationUnits

Carbon and catalyst regeneration units include bothcontrolled-flame and non-flame devices. Since1991, EPA has considered the regeneration orreactivation of spent carbon from a carbonabsorption system, used in the treatment of a listedhazardous waste or used to capture emissions froma listed hazardous waste, to be thermal treatmentunder the interim status provisions of RCRA. Thecarbon, which contains absorbed organics, isclassified as a hazardous waste under the derived from rule (40 CFR 261.3 (c)(2)(i)). In thatprocess, organic contaminants are desorbed fromactivated carbon at temperatures as high as 1,800degrees () Fahrenheit (F). Carbon regenerationunits that use thermal treatment include rotary kilns,fluidized-bed regenerators, infrared furnaces ormultiple-hearth furnaces, all of which transfer heat tothe contaminated carbon. The most prevalentfurnace type is the multiple hearth furnace, followedclosely by rotary kilns. As an alternative, steam maybe used to desorb contaminants from the media indevices similar to tanks.

Catalyst regeneration processes can be similar tothose used for carbon regeneration. However, thetypes of catalyst to be regenerated, the types andconcentrations of contaminants to be desorbed, andthe conditions under which the desorption takesplace may alter the combustion chemistrysignificantly from that which is seen in carbonregeneration units.

Overview information regarding theConfined Burn Facility is available athttp://www.ih.navy.mil/environm.htm

Refer to August 8, 1991 Policy Memo andJanuary 5, 1998 Policy Memo regarding theregulatory status of Carbon RegenerationUnits.

http://www.ih.navy.mil/environm.htmhttp://www.epa.gov/rcraonline/index.htm

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Controlled-flame devices used for carbonregeneration are similar to those used for incinerationor for boilers and industrial furnaces (BIF).However, strict compliance with incinerator or BIFregulations may not be appropriate. Use of EPAsincinerator and BIF destruction and removalefficiency (DRE) standard and carbon monoxideand total hydrocarbon monitoring in the off gasesmay be appropriate for such units. Following arebrief descriptions of some of the more commontypes of regeneration units.

A rotary kiln is an inclined rotating cylinder, linedwith refractory brick and internally fired. The spentcarbon is fed at the higher end of the kiln andmoves, driven by gravity, down the length of the kilnas the kiln rotates. A heated air stream passescountercurrent with the waste, volatilizing thecontaminants in the carbon. The exiting air streamcontains desorbed contaminants and any combustionproducts that may have formed within the kiln. Therotational speed of the kiln can be varied.Peripheral speeds of 0.5 meters/minute (m/min) to 2m/min are typical.

A fluidized-bed furnace is a cylindrical vertical vesselwith an air feed at the bottom of the unit. Influidized-bed units, the granular material (the bed) isfluidized by directing air upward through the bed.Fuel is charged directly into the fluidized-bed or intothe window box beneath the bed. The temperaturein the freeboard area above the bed can be higherthan that within the bed. Because of the airflowrequired to fluidize the carbon particles, fluidized-bed furnaces have a larger exhaust volume thanother types of regeneration furnaces with the samecarbon throughput rate.

A multiple hearth furnace typically consists of arefractory-lined vertical steel shell. Inside is a seriesof flat hearths that are supported by the walls of theshell. A rotating shaft runs vertically through thecenter of the hearth. Rabble arms attached to therotating shaft move the waste across each hearth.The hearths have holes, either in the center near the

Schematic of Fluidized-bed Furnace.

Schematic of Rotary Kiln.

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shaft or near the outside edge through which thewaste drops to the hearth below. Combustion airtravels countercurrent to the waste flow.

In an infrared furnace spent carbon is transportedthrough the horizontal furnace via a metal grate. Aseries of heating elements above the metal grate areelectrically heated to incandescence. The infraredradiation heats the carbon and a draft fan is used todraw air through the furnace and remove desorbedgases as they are released from the carbon.

These types of units may use a backflush of steam todesorb contaminants. The contaminated steam thenis condensed and transferred to a decanter. In thedecanter, a concentrated organic solvent phase isseparated from the water phase. The water phasecontains measurable concentrations of organiccontaminants and must be treated as hazardouswastes.

Some carbon regeneration tanks also may meet thedefinition of wastewater treatment unit under40 CFR 260.10. Such units are used to adsorbcontaminants from wastewaters. These units areexempt from permitting standards under RCRAwhen they are used to treat wastewater fordischarge under National Pollutant DischargeElimination System (NPDES) or publicly ownedtreatment works (POTW) standards.

2.1.4 Thermal Desorption Units

As outlined in a June 12, 1998 Policy Memo, theEPA regulations do not define thermal desorber,but the term generally applies to a unit which treatswastes thermally to extract contaminants (i.e.,volatile organics) from a matrix. A thermal desorberutilizing controlled flame combustion (e.g., equippedwith a directly fired desorption chamber and/or afired afterburner to destroy organics) would meetthe regulatory definition of an incinerator.Alternatively, a thermal desorber that did not usecontrolled flame combustion (e.g., equipped with anindirectly heated desorption chamber and thedesorbed organics were not controlled/destroyedwith an afterburner) would be classified as a

Schematic of Multiple Hearth CarbonRegeneration Unit.

Schematic of Infrared furnace.

http://www.epa.gov/rcraonline/index.htm

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miscellaneous unit. Thermal desorption mayoxidize organics but in some cases merely volatilizesorganic compounds from the contaminated mediaand concentrates them in the desorber exhaust gasstream. Thermal desorption reduces the volume ofthe contaminated media, but the desorber exhaustgas stream typically still requires some form oftreatment.

A typical thermal desorption unit includes feedprocessing equipment, such as hoppers, sieves, orshredders. The feed material then is transferred intothe thermal treatment unit by such equipment asconveyor belts. The feed storage, preparation, andtransfer system may be unenclosed, posing risks ofreleases during those steps. Emission controls forthe ancillary equipment may be necessary to addresssignificant risks.

The thermal treatment unit itself may consist of arotary kiln, a fluidized-bed system, or a multiple-hearth system, as described above for regenerationunits. Typically, the waste feed travelscountercurrent to an air stream inside the desorber,where temperatures typically are between 400 and1,000F. The contaminated air stream is directedthrough air pollution control devices, such asafterburners, venturi scrubbers, electrostaticprecipitators, or baghouses, before it is released intothe atmosphere.

2.1.5 Vitrification Units

The development of vitrification technology has beenpromoted by the large volume of low-level and highlevel radioactive waste requiring treatment at U.S.Department of Energy (DOE) sites. Much of thiswaste includes RCRA hazardous constituents and isregulated as mixed waste.

There are two general categories of vitrificationprocesses: those applied to site remediation (e.g.,contaminated soils) and those applicable totreatment of waste streams from uranium/plutoniumprocessing (e.g., tank wastes). Vitrificationprocesses used in the treatment of wastes aretypically conducted as ex-situ vitrification whereas

Additional Policy Memos regarding theapplicability of the Subpart X regulationsto Thermal Desorbers were issued onJuly 30, 1997, February 23, 1994,October 29, 1993 and May 18, 1988.


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treatment of contaminated soils is generallyconducted in-situ. A description of both ex-situ andin-situ vitrification processes follows.

2.1.5.1 Ex-Situ Vitrification

The ex-situ vitrification process is a thermaltreatment process that both oxidizes and vitrifieswastes. It can treat wastes in the form of solids oras slurries. Typically waste and fuel are mixed in apre-combustor before being transferred to acombustion chamber. Oxidation will take place inthe combustion chamber. After the waste has beenoxidized the ash is transferred to a vitrificationchamber where it is mixed with glass makingingredients to create glass materials. In somesystems, wastes treated this way are reportedlycapable of passing the toxicity characteristic leachingprocedure (TCLP).

2.1.5.2 In-Situ Vitrification

In-situ vitrification earth-melting technology wasdeveloped by Battelle Memorial Institute during the1980s for DOE and is now commercially availableas Geosafe Corporations GeoMeltTM technology.In-situ vitrification treats contaminated materialswhere they presently exist. This method is preferredwhen it is necessary to avoid the risks associatedwith excavation of the waste. The vitrificationprocess can simultaneously treat wastes with highconcentrations of both organic and inorganic (e.g.,heavy metal) contaminants. Organic constituents arethermally desorbed and then destroyed by thermaldecomposition (pyrolysis) within the oxygen-depleted media being treated. Nonvolatileinorganics (metals) are typically incorporated intothe melt and the resulting vitrified product. Suchincorporation occurs within the framework of theglassy product itself, as opposed to simpleencapsulation (being surrounded) by the glass. Alarge volume reduction (25-50% for soils) occursdue to elimination of void volume and vaporizablematerials during processing. This process worksbest with treatment zones that are >10 feet inthickness.

Schematic of high level waste melter used forex-situ vitrification.

In-situ vitrification hoods.

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Off-gas hoods are used to cover an area ofcontaminated soil. The process works by meltingsoil in place using electricity applied between pairsof graphite electrodes. The process employs jouleheating and typically operates in the range of 1,600to 2,000 Celsius (C) for most earthen materials. Ahighly conductive starter path is placed between theelectrodes to allow initiation of melting. Aselectricity flows through the starter path, the pathheats up and causes the surrounding media to melt.Once the media is molten, it too becomes electricallyconductive. Continued application of electricityresults in joule heating within the molten mediabetween the electrodes. After the melt is fullyestablished, the melt zone grows steadily downwardand outward through the contaminated volume.Successful melting is contingent upon the use ofadequate electrical conductivity. Additives includinglime, soda, ash, or pre-manufactured glass frit maybe used to improve performance.

A low vacuum can be pulled on the hood inoperation to capture emissions from the melt andsend them to the off-gas treatment system, whichmay include a quencher, scrubber, demister, heater,particulate filter, blower, and optional activatedcarbon or thermal oxidation units. The entire ISVsystem can be monitored from a process controlroom.

2.1.6 Rotary Metal Parts Treatment Unit

Rotary metal parts treatment (RMPT) is used in thedecontamination of empty projectile and mortarshells. The RMPT consists of a cylindrical structurerotating at a prescribed speed inside a cylindricalfurnace. The dimensions of the RMPT are 4 feet, 8-inches inner diameter by 15 feet, 7-inches in lengthwith design conditions of 15 psig/full vacuum at1,500 F. The inside cylinder contains 15 cageswhich are evenly distributed around a 36-inchoutside diameter inner pipe, supported andstrengthened by baffles. Each cage is constructedwith three -inch diameter stainless steel rods,positioned at a 120-degree angle and parallel in theaxial direction. The size of the cages is dependanton the different munitions and mortars to be treated.

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The RMPT is heated by using external electricinduction coils and superheated steam as the carriergas.

Munitions that have been washed and drained aretransported by a conveyor system and loaded intothe cages on a unit feed basis. The furnace is heatedby induction power supplied from a radio frequencygenerator. The entire furnace wall area must beheated and maintained at a temperature of 1,250 F.The furnace shell must have a high emittance in orderto optimize performance. In addition, the shell mustalso have good chemical resistance to corrosion, inorder to resist the acid gases that are generatedduring operation. The total residence time for eachmunition ranges from 75 minutes for 105-mmprojectiles and 4.2-inch mortars to 105 minutes for155-mm projectiles. At the same time as amunition is loaded on the front end of the unit, atreated munition is discharged at the opposite end ofthe furnace. A vent gas reheater is installeddownstream of the RMPT to complete destructionof the agent. Downstream of the reheater, the ventstream is cooled and condensed in a quenchcondenser which is in contact with a recirculatedbrine stream. Noncondensable gases will be sent toa dedicated CATOX offgas treatment system.

Internal parts removed from the 105-mm, 155-mmmunitions and 4.2-inch mortars are processed in asmaller Batch Metal Parts Treatment (BMPT) unit.The internal parts consist of burster wells, burstertubes, fuzes, nose cones, lifting lugs and plugs.Similiar to the RMPT, the BMPT consists of acylindrical furnace which uses external inductioncoils as the primary heat source and superheatedsteam as the carrier. The BMPT measures 4 feet,8-inches in diameter by 11 feet in length with designconditions of 15-psig/full vacuum at 1,500 F. Theinternal parts are removed from the main bodies ofthe projectiles or mortars and collected intorectangular boxes. These boxes are placed on arolling plane and fed into the furnace on a batchbasis.

Detailed process flow diagrams and designspecifications for the RMPT, the BMPT andthe associated ancillary equipment are inprovided in following document: RotaryMetals Parts Treatment.

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2.2 Types of Mechanical Units IncludedUnder Subpart X

2.2.1 Shredder Units

Shredders typically are used to make waste moreamenable to subsequent treatment in other units,such as thermal desorbers, regeneration units, orincinerators, through reduction in size, and blending.Shredders may be regulated under Subpart X basedon the material managed. Refer to June 24, 1988Policy Memo. Drum shredders are found at anumber of facilities. If the unit is managing RCRAempty containers, then the unit is exempt fromRCRA Subtitle C regulations. (Refer to 40 CFR261.7 for the definition of RCRA empty). Severaltypes of shredders are used, the major examples ofwhich are hammer mills, shear shredders, and augershredders.

A hammer mill is a type of shredder that reduces thesize of the waste by impaction and that works bestwith friable materials. The mill can handle a widerange of solids but must be matched well with thewaste to prevent problems related to excessiveequipment wear and jamming. Stringy or stickymaterials also can jam the mechanism. Shear andauger shredders use low-speed knives or counter-rotating augers to shred solid materials, such asdrums.

A mechanical feed system, typically consisting of afeed hopper and some type of conveyance system,should be available to avoid the need for plantpersonnel to be near the opening of the hopperduring operation. To prevent flying debris and tominimize emissions, the feed system should beenclosed. The shredder also must be designed tocontain dusts and mists of toxic materials, as well as,in the case of hammer mills, particulate matterescaping the unit at high velocity. Dust and fumescan be controlled by drawing them into an airpollution control device associated with theshredder. In some cases, flame-suppression devicesmay be necessary to prevent explosion and fire inthe feed hopper and the shredder.

Schematic of HammerMill Shredder.

Schematic of Shear Shredder.

http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgihttp://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi

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2.2.2 Filter Press Units

Filter presses are used to separate solids from fluidsunder pressure. The most basic type of filter pressis the plate-and-frame press. As shown in theschematic to the right, the unit consists of alternatingsolid plates and hollow frames that are situated onparallel support bars. The filter medium is placedagainst each side of the solid plates, the surfaces ofwhich are slotted or grooved. The entire collectionof plates and frames is pressed together using ascrew or hydraulic ram assembly, which shouldachieve essentially a fluid-tight closure. The filtermedium between the plates and frames acts as agasket. This schematic also shows the flow pathwithin a plate-and-frame press. Although the figureshows filtrate exiting through a closed system, otherdesigns discharge filtrate through cocks located atthe base of each plate into open collection trays. Aclosed discharge system is essential to prevent toxicor volatile air emissions.

Filter presses often drip and leak. Emptying andcleaning of a filter press may include disassembly ofthe press and scraping of the filter cloth by hand.For such units, secondary containment (e.g., asrequired for tanks under 40 CFR 264.193) may beappropriate to minimize the potential for harm posedby releases that may occur during operation andmaintenance of the units.

2.2.3 Drum Crushers

Drum crusher units that are eligible to be permittedunder Subpart X, handle containers of hazardouswastes. Typically, a can or drum crusher handlesone container at a time. The containers lid may beremoved before it is placed in the crusher, or the lidcan be left in place if an opening, such as abunghole, is present. Some units are designed to cutoff the top of the drum to allow easier access to theinterior. After the container is conveyed into the unitand opened, the interior of the container may besprayed with an appropriate solvent to mobilizehazardous waste residues.

Schematic of Filter Press.

A Policy Memo concerning the applicabilityof Subpart X to Drum Crushers was issuedon May 21, 1991.


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Within the unit, a perforated plate is clamped on thetop of the container, and then the container is flippedover and crushed with a hydraulic ram. Thehydraulic ram may be electric or pneumaticpowered. The rinse solvent and residues are forcedout of the container and down through theperforations. The solvent and rinsate drain from thebottom of the can crusher unit into a collection tank.The crushed container, which typically isapproximately one-inch thick, is then conveyed outof the unit. The hazardous waste that drains into thecollection tank may be thick and difficult to mobilize.The collection tank may have ancillary equipment forsuch processes as agitation, grinding, or addition offluid to enhance removal of the hazardous waste.

The drum crusher unit should be enclosed, so that anitrogen or carbon dioxide blanket can be appliedduring crushing to minimize the risk of explosion.The unit also should be equipped with a flame-arrester vent that is connected to appropriateemission control equipment. Secondary containmentmay be necessary for the entire unit.

2.2.4 Drum Washer

Commercial drum washing systems are availablefrom several manufacturers. These units areregulated as Subpart X units if the units are handlingnon-RCRA empty drums. The definition of RCRA-empty container is provided in 40 CFR 261.7.Drum washers may be fully automated with severalstations to flush, rinse, purge, and siphon both polyand steel drums. In general, a drum washing systemprovides enclosed containment to capture the liquidsolvent used to clean the interior and exterior of adrum. The solvent may be applied by a high-pressure spray wand or automated rotating brushes.The cleaning solvent may be as simple as high-pressure water, although it is common to use acommercial chemical solvent. Recovered solventcarries drum bottoms and may be recycled througha closed-loop solvent recovery system associatedwith the drum washer. The drum washer may alsoinclude an exhaust fan and air pollution controlequipment (e.g., fume scrubber) to capture volatileorganics and particulates evolved during drum

Schematic of Drum Crusher.

Schematic of Drum Washer.

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cleaning. In addition to drum washers, systems arealso available to clean smaller containers such astotes and pails. Examples of drum washing units areshown in the column to the right.

2.2.5 Mercury Bulb Crushers

Fluorescent lamps are widely used in businesses, asthey provide an energy-efficient source of lighting.The commercial and industrial sectors dominateusage of fluorescent lamps, accounting for over 90percent of total usage. Fluorescent lights aredesigned so that approximately half of them willoperate after 20,000 hours of operation. Wherethese lamps are being used on a small scale, they aregenerally replaced as they burn out, one at a time.However, in large companies and industries, thismethod is not practicable, and, therefore, grouprelamping is done on a regular basis. Typically,group relamping is performed at 15,000 hours, or75 percent of the lamps rated life. This translates toreplacement every two years for continuousoperations, and every three to five years fornoncontinuous operations, which are much morecommon. Approximately 20 percent of all lampsare currently replaced annually. Group relampingoperations generate large quantities of lamps to bedisposed of at a single time.

A typical fluorescent lamp is composed of a sealedglass tube filled with argon gas at a low pressure(2.5 Torr), as well as a low partial pressure ofmercury vapor, thus the tube is a partial vacuum.The inside of the tube is coated with a powdercomposed of various phosphor compounds.Tungsten coils, coated with an electron emittingsubstance, form electrodes at either end of the tube.When a voltage is applied, electrons pass from oneelectrode to the other. These electrons pass throughthe tube, striking argon atoms, which in turn emitmore electrons. The electrons strike mercury vaporatoms and energize the mercury vapor, causing it toemit ultraviolet radiation. As this ultraviolet lightstrikes the phosphor coating on the tube, it causesthe phosphor to fluoresce, thereby producing visiblelight. The most commonly used fluorescent lamp isthe 40-watt, 4-foot long tube, although smaller,

View of interior Drum Washer.

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larger and differently shaped lamps are also used.The amount of mercury in fluorescent lamps variesconsiderably with manufacturer, and typically rangesfrom 27 to 41 mg of mercury per lamp. Manyfluorescent, high-pressure sodium, mercury vaporand metal halide lamps exhibit the toxicitycharacteristic for mercury. In addition, some high-density discharge (HID) and incandescent lampsmay contain lead solder at levels which exceed thetoxicity characteristic regulatory level for lead.Fluorescent light fixtures may also contain hazardousconstituents in their ballasts (i.e., polychlorinatedbiphenyls (PCBs) and diethylhexyl phthalate(DEPH)).

Historically, spent hazardous waste lamps wereplaced in landfills. On July 6, 1999 EPA addedspent hazardous waste lamps to the list of federaluniversal wastes (64 FR 36466) in order toencourage recycling of these wastes. The UniversalWaste Rule is codified in 40 CFR 273. TheUniversal Waste Rule for spent lamps becameeffective at the federal level on January 6, 2000.However, the rule is not effective in states that areauthorized for the base RCRA program until thestate chooses to adopt it. Some states may chooseto not adopt the universal waste regulations butrather to regulate units which treat hazardous wastelamps under a Subpart X permit.

The simplest of crushers is essentially a single unit,with a crusher mounted on top of a barrel, usually a55-gallon drum. This system is used in manyindustrial facilities to crush their fluorescent lamps asa means to reduce the solid waste volume beforedisposing the material in a landfill. In this version,light lamps are hand-fed to a feeder chute of variablelength and diameter. This chute is not necessarilylonger than the lamps being fed into it. The lampspass to the crushing unit, typically consisting ofmotor-driven blades, which implode and crush thelamps. From here, the crushed powder drops intothe barrel below the crusher. There are no airpollution controls on the device. The crushed lampsare collected in drums until they are full, and then thefull drums are transported to one of several facilities.The crushed material may then be separated into

View of a barrel-mounted crusher utilizing anegative air exhaust system.

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=1999_register&docid=99-16930-filed

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glass, metal, and powder components. Typically,the untreated powder is then deposited in a landfill.This is currently the most common method ofdisposing these lamps. Alternatively, the barrelsmay be transported to a mercury recovery facility,which will separate the mercury-containing phosphorpowder from the crushed glass and aluminumendcaps, and recycle all the materials.

A more sophisticated version of this barrel-mountedcrusher utilizes a negative air exhaust system to drawthe crushed debris and prevent it from reemergingthrough the feeder tube. The drawn air is thenpassed through a High Efficiency Particulate Air(HEPA) filter to remove particulate matter from theexhausted airflow. The crushed material is thendisposed in one of the manners discussed above.

Another model design consists of a hand fedapparatus with two feeder chutes. One chute is 5feet long, to accommodate 4 foot lamps, and theother tube is 9 feet, in order to accommodate 6 to 8foot lamps. Each chute is placed at an angle, andhas a 9-inch by 12 inch opening, which canaccommodate several lamps at a time. The lampsare delivered down this angled tube onto a motordriven blade made of heavy gauge hardened steelrotating at 2700 rotations per minute. The rotatingblades implode and crush the lamps as they arrive.The crushing unit has an operating capacity of 62.5lamps per minute. A vacuum system collects airfrom beneath the crusher, preventing mercury-ladenair from exiting through the feed tube. Materialcollected in the vacuum system first passes through acyclone separator. This removes glass particles,which drop into the drum. Air from the cycloneseparator contains phosphor powder and somemercury vapor. After passing through the cyclone,the air is pulled through to a baghouse, where fabricfilters trap particulate matter in the air stream. Every45 seconds, these fabric filters are cleaned with areverse pulse of air. The air leaving the baghouse istypically composed only of air and mercury vapor.This air and mercury vapor mixture continuesthrough several more particulate matter and HEPAfilters, to ensure that all particulates have been

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removed. From here, the exhaust is delivered totwo 250-pound activated carbon beds, which trapthe mercury vapor.

The entire process is vacuum-sealed and monitoredcontinuously for leaks and to ensure that air in thecontainment area is in compliance with OSHAregulations. Effectively, the only time where levels ofmercury in the workplace may approach the OSHAlimit of 0.05 mg/m3, is when lamps have beendropped and broken.

A third design is a completely enclosed system thatfeeds fluorescent lamps in one end to a crusher,passes the exhaust through an extensive filteringsystem, and delivers the powder to a thermalreduction unit (TRU), which recovers the mercuryfrom the phosphor powder. Thus, this systemcarries out the entire mercury recycling process,from the crushing of fluorescent light lamps to theretorting and reclamation of mercury from phosphorpowder.

Lamps are hand-fed into feeder tubes of differentlengths, depending upon the size of the lamps beingprocessed. The lamps are fed to the crusher, whichimplodes and crushes the lamps into small fragments.The operating capacity of the unit is 60 lampscrushed per minute. As with the second design, theentire process is conducted under negative airflow.The crushed debris is exhausted first to a cyclone,where the larger particles, such as crushed glass andaluminum endcaps, are separated out. At this point,much of the phosphor powder drops out into acyclone hopper. From this collection hopper, thephosphor powder, containing mercury, is transferredto the TRU via an enclosed auger conveyer. Afterthe cyclone, the airflow proceeds to a baghouse,where fabric filters continue to remove particulatematter from the airstream. The fabric filters arecleaned with a reverse pulse mechanism, and thepowder that drops out here is also routed to thecyclone hopper. The air stream leaving thebaghouse proceeds to a HEPA filter, and then to apotassium iodide-impregnated carbon filter. Thisremoves the mercury vapor, by precipitating it in theform of mercuric iodide.

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2.3 Other Types of Units Included UnderSubpart X

2.3.1 Underground Mines, Caves, andGeologic Repositories

Placement of hazardous waste in subterraneanfeatures, such as mines, caves, and salt domes, isregulated under 40 CFR Part 264 Subpart X andconstitutes land disposal. Hazardous waste placedin these units must be treated before disposal, incompliance with treatment standards promulgatedunder the land disposal restrictions (LDR), 40 CFR268, unless the owner or operator demonstratesthat there will be no migration of hazardousconstituents from the unit, in accordance with 40CFR 268.6.

The design considerations for these units are similarto those for landfills. Because of the depth ofgeologic repositories, it may be extremely difficult toimplement groundwater monitoring. The stability ofthe underground formation also is an importantconsideration.

At cave and mining sites, infiltration of water shouldbe evaluated carefully. The presence of caves ingeologic formations indicates the presence of waterwithin the formation at some time. The permitapplicant must demonstrate that ground water is notexpected to discharge into the unit for at least thetime period of operation of the unit. Thatrequirement can be met by demonstrating that thereare no nearby aquifers above the level of the unit, orthat aquitards exist above the repository level.Should the applicant be unable to demonstrate thatcondition, some form of infiltration control must beprovided (a requirement similar in concept to that forleachate control for landfills).

2.3.2 Biological and Chemical TreatmentUnits

A permit writer may receive a permit application fora biological or chemical treatment unit that theapplicant is attempting to permit under Subpart X.Many of these types of units may be more

Schematic of geologic repository at YuccaMountain.

1. Canisters of waste, sealed in special casks,are shipped to the site by truck.

2. Shipping casks are removed, and the innertube with the waste is placed inmultilayered storage container.

3. An automated system sends storagecontainers underground to the tunnels.

4. Containers are stored along the tunnels, ontheir side.

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appropriately permitted under either the tank or landtreatment unit regulations, or should incorporatesuch standards as part of the Subpart X permit.

2.4 References

Additional information regarding these unitsdescribed above can be found in the followingdocuments:

EPA. 1992. Alternative Control Document.Carbon Reactivation Processes. EPA 453/R-92-019. December.

U.S. Patent Office. 1997. Patent No. 5613,453.Donovan Chamber.

EPA. 1994. Evaluation of Mercury Emissionsfrom Fluorescent Lamp Crushing. EPA 453/R-94-018. U.S. EPA Control Technology Center.February.


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3.0 SUBPART X REQUIREMENTS

This section discusses the general requirements forSubpart X units under 40 CFR Part 264. In addi-tion, a discussion regarding other requirementswhich may be applicable to Subpart X units isprovided.

3.1 Requirements Under 40 CFR Part 264

Subpart X does not specify minimum technologyrequirements or monitoring requirements for miscel-laneous units. Subpart X specifies an environmentalperformance standard that must be met throughconformance with appropriate design, operating,and monitoring requirements. The performance-based standard addresses the prevention of releasesthat exceed the environmental performance standardto (a) groundwater and the subsurface environment;(b) surface soil, surface water, or wetlands; and (c)air. The applicant must demonstrate that the envi-ronmental performance standards will be met duringand after the active life of the unit by meeting infor-mation requirements specified in 40 CFR 270.23.

Subpart X requires that an environmental assess-ment and risk assessment be performed to meet theinformation requirements outlined above. For eachassessment, different levels may be needed, depend-ing on the findings of the initial or screening assess-ments. If the findings indicate little or no negativeenvironmental effect or likelihood of release, thepermit applicant may submit the initial findings in anattempt to satisfy the information requirements.

However, for many types of Subpart X units,particularly mechanical units such as shredders,crushers and filter presses, an environmental assess-ment may not be necessary. This is especially true incases where the unit is fully enclosed in a contain-ment structure such as a building. The applicantmust be able to justify that an environmental assess-ment is unnecessary. To do this, the applicant mustprovide all design and operating information neces-sary to support their claim that an environmentalassessment is not required. The permit writer mustbe able to assess whether adequate safeguards are

Additional information regarding the Subpart Xregulations and determining whether or not theyapply is outlined in the Subpart X Overview andBig Issues presentations from the February 2002EPA Region 4 RCRA Miscellaneous UnitsPermitting and Compliance Training.


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engineered into the system. Additionally, the permitwriter may specify design and operating conditionsconsidered appropriate for the technology and site,to ensure that the unit will not impact any environ-mental media.

3.2 Other RequirementsAppropriate for Subpart X Units

3.2.1 Subpart I - Containers

Subpart I addresses the use and management ofcontainers, and portable devices in which material isstored, transported, treated, disposed of, or other-wise handled. Portable, fabricated devices used forOB operations or operations at shredders orcrushers may be similar to containers. Therefore,certain requirements of subpart I may be applicableto these devices. The necessity for secondarycontainment (40 CFR 264.175(c)) also should beevaluated, especially if the wastes treated in the unitcontain liquids.

3.2.2 Subpart J - Tanks

Subpart J establishes requirements for tank systems.Certain types of miscellaneous units may resembletanks, such as certain OB units or units performingphysical handling operations such as drum shreddersor crushers.

Tank-like devices designed for OB operations mayrequire lining with refractory materials to insulate themetal walls of the tank from the extreme heat thatmay be generated during operation of the unit. Theaboveground portions of the units should be in-spected daily. If a tank-like unit is closed withwastes in place, the post-closure care must beperformed as for a landfill (40 CFR 264.197).Assessment of the integrity of a unit that resembles atank (40 CFR 264.191) can be addressed ad-equately by conducting inspections on a regularschedule (either daily, weekly, or monthly dependingon the frequency of use).


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3.2.3 Subpart K - Surface Impoundments

Subpart K establishes requirements for surfaceimpoundments. Ponds used for underwater detona-tion may resemble surface impoundments. How-ever, such ponds would not be designed in preciselythe same manner as surface impoundments becausethey will be subject to extreme stresses resultingfrom repeated detonation of explosives. Thoseactivities would destroy synthetic (or other types of)liners and leachate collection systems that usually areinstalled immediately beneath a surface impound-ment. However, the necessity for monitoring of theground water beneath the unit should be evaluated.The surface impoundment should be inspectedweekly for evidence of any sudden drops in the levelof the impoundments contents and signs of deterio-ration in dikes or other containment devices (40CFR 264.226(b)). The surface impoundmentshould be designed, constructed, and monitored, insuch a way as to prevent overtopping and to preventfailure of any dikes (40 CFR 264.221(g) and (h)).

3.2.4 Subpart L - Waste Piles

Subpart L establishes requirements for waste piles.OB/OD units may resemble waste piles, especially ifresidual waste is left to accumulate on the groundsurface or during temporary storage of the wastebefore it is treated by OB/OD. Standards for wastepiles that may be applicable to the circumstances atan OB/OD unit described above include require-ments for installing leachate collection systems andliners. The leachate collection and removal systemmust be chemically resistant to the waste managed inthe pile and the leachate expected to be generated(40 CFR 264.251(a)(2)(i)(A)). The liner must beconstructed of materials that have appropriatechemical properties and sufficient strength andthickness to prevent failure due to pressure gradi-ents, physical contact with the waste, climaticconditions, and the stresses of installation and dailyoperation (40 CFR 264.251(a)(l)(i)). Clay linersshould be considered in particular for OB units thatdo not have containment devices; synthetic linersmay not withstand the extreme temperatures gener-ated in the OB unit. Further, detonation activities


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conducted in OD units will destroy any kind ofsynthetic liner conventionally installed beneath theunit. Therefore, synthetic liners are not generallyrecommended for OD units.

Other requirements for waste piles that may beapplicable and appropriate for OB/OD units includerequirements for controlling run-on and run-off, andconducting ground-water monitoring if the environ-mental assessment indicates that there is potential forcontamination of the ground water. The run-oncontrol system should be capable of preventing flowonto the active portion of the waste pile during peakdischarge from a 25-year storm (40 CFR264.251(g)). The runoff management systemshould be capable of collecting and controlling thewater volume resulting from a 24-hour, 25-yearstorm (40 CFR 264.251(h)). The pile should bemanaged to control any particulate matter subject towind dispersal (40 CFR 264.251(j)). The wastepile should be inspected weekly and after storms(40 CFR 264.254(b)).

3.2.5 Subpart N - Landfills

Subpart N establishes requirements for landfills. Insome cases, miscellaneous units may be closed aslandfills if clean closure is not feasible. This is oftenthe case for historical OB/OD units. Therefore,closure standards and requirements for post-closurecare that are applicable to landfills may also beapplicable to Subpart X units. Upon closure, thelandfill must be covered with a final cover and mustmeet other monitoring requirements (40 CFR264.310). Ignitable wastes must be disposed ofsuch that they are protected from causes of ignition(40 CFR 264.312)

3.2.6 Subpart O - Incinerators

Subpart O establishes requirements for incinerators.Use of the Subpart O requirements may be appro-priate for some thermal treatment units includingcarbon regeneration units and thermal desorbers.These requirements include waste analysis require-ments (40 CFR 264.341), the potential need for atrial burn (40 CFR 264.340(d)), acceptable


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operating limits for each type of waste feed (40CFR 264.345(b)), control of fugitive emissions (40CFR 264.345(d)), and monitoring and inspectionrequirements (40 CFR 264.347). A permit writermay require a trial burn for such thermal treatmentunits if the permit applicant cannot convincinglydemonstrate in the risk assessment a lack of envi-ronmental effects.

3.2.7 RCRA Organic Air Emission Standards

3.2.7.1 Subpart AA - Process Vents

Subpart AA applies to process vents that may beassociated with units that manage hazardous wastehaving concentrations of organic constituents of atleast 10 parts per million by weight (ppmw). Appli-cants for Subpart X permits for carbon regenerationunits and thermal desorption units must comply withthe requirements of Subpart AA if the units are fittedwith process vents like those described in SubpartAA. According to 40 CFR 264.1032, the owneror operator of a facility that has process ventsassociated with air or steam stripping operations thatmanage hazardous wastes having concentrations oforganics of at least 10 ppmw must either (1) reducetotal organic emissions from all affected processvents at the facility to a level below 1.4 kg/hr or (2)reduce, by use of a control device, total organicemissions from all affected process vents at thefacility by 95 percent by weight. If the owner oroperator installs a closed-vent system and controldevice to comply with provisions of 40 CFR264.1032(a), the device must meet the require-ments governing closed-vent systems and controldevices specified in 40 CFR 264.1033.

One of the issues that has arisen in recent years isthe issue of whether groundwater treatment units aresubject to the RCRA organic air emission standards.Many believe that air strippers fall under the waste-water treatment unit exemption outlined in 40 CFR264.1(g)(6). The June 21, 1990 preamble to theRCRA Subpart AA & BB Rule does make refer-ence to wastewater treatment tanks as defined under40 CFR 260.10 being excluded from applicability


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to these two Subparts. But, this is not the casewhen remediating groundwater in air strippingoperations. 40 CFR 260.10 defines wastewatertreatment units as receiving or treating an influentwastewater that is classified as hazardous waste asdefined in 40 CFR 261.3. However, 40 CFR261.3 does not address environmental media suchas groundwater. Environmental media are not solidwastes. The Agencys position is that mixtures ofenvironmental media and listed hazardous wastesmust be managed as if they were hazardous wastes,an interpretation other words referred to as thecontained-in policy and upheld in Federal court(ref. Chemical Waste Management Inc. v. U.S.EPA, 869 F.2d 1526; D.C. Cir. 1989). In sum-mary, groundwater is not a hazardous waste anddoes not meet the criteria of 40 CFR 261.3. Thus,an air stripper treating groundwater contaminatedwith volatile organic compounds does not meet thedefinition of a wastewater treatment unit as men-tioned in the 1990 preamble to the Subpart AA &BB Rule and is not excluded from applicability to theRCRA Organic Air Emission Standards. In accor-dance with the Contained-in Policy, a correctiveaction unit treating groundwater contaminated with alisted hazardous waste should be addressed as ahazardous waste management unit - not as a waste-water treatment unit.

By statute, air emissions (as well as other environ-mental media releases) from units managing hazard-ous wastes with interim status, are subject to correc-tive action under 3008(h) authority. The statuterequires environmental media contamination resultingfrom waste management be addressed to protecthuman health and the environment. Subpart AA &BB were promulgated under HSWA authoritymandated by Section 3004(n) of the Solid WasteDisposal Act (refer to the June 21, 1990 FR 25456,Section III, C. Air Standards Under RCRA Section3004(n)). Section 3004(n) requires the monitoringand control of air emissions at units treating, storingor disposing of hazardous wastes as necessary toprotect human health and the environment.


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3.2.7.2 Subpart BB - Equipment

Subpart BB applies to equipment, such as pumps,valves, compressors, pressure relief devices, sam-pling connection systems, open-ended lines andvalves, closed-vent systems, control devices, flangesand other connectors that contain or come intocontact with hazardous wastes with concentrationsof organics of at least 10 percent by weight that aremanaged in (1) units subject to the permittingrequirements of Part 270 or (2) hazardous wasterecycling units that are located at hazardous wastemanagement facilities subject to permitting require-ments under Part 270. Depending on the type ofequipment and the associated service (i.e., gas, light-liquid or heavy liquid service), the owner or operatormust either (1) periodically test the equipment usingan organic vapor analyzer and repair any leaksdetected within a prescribed time period or (2)follow certain prescribed equipment standards.Organic vapors vented to a control device must bereduced by 95% or meet the 20-ppmv total organicoutlet concentration limit for a combustion device.Where applicable, permit applicants must submitinformation that demonstrates compliance with allrequirements of Subparts AA and BB.

3.2.7.3 Subpart CC - Containers, Tanks andSurface Impoundments

Subpart CC applies to interim status and permittedTSD facilities that manage hazardous waste incontainers, tank systems, surface impoundments ormiscellaneous units and large quantity generators(LGQs) that accumulate hazardous waste in tanksand containers. Waste management units thatcontain hazardous waste with an average organiccompound concentration of 500 parts per million byweight (ppmw) or greater are subject to the SubpartCC requirements. Type-specific equipment designand operating practices apply to each regulatedwaste management unit. In addition, any controldevice handling emissions from such units must meetthe 95% minimum control or 20-ppmv total organicoutlet concentration limit for a combustion device.Applicants must submit information that demon-strates compliance with those requirements if the

Additional information regarding theapplicability of the RCRA Organic AirEmission Standards to Subpart X units isoutlined in the Case Study on Subpart Xpresentation from the March 2002 EPARegion 4 RCRA Organic Air EmissionStandards Permit and Compliance Trainingand in the Subpart CC Fact Sheet.


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units resemble the types of units regulated underSubpart CC, as described above.

3.2.8 Subpart EE -Miliary Munitions Rule

Section 107 of the Federal Facility Compliance Actof 1992 added a new subsection 3004(y) to RCRA,requiring EPA to issue regulations that identify whenconventional and chemical military munitions becomehazardous wastes subject to RCRA Subtitle C, andthat provide for the safe storage and transportationof such waste. EPA published the final MilitaryMunitions Rule on February 12, 1997 (62 FederalRegister 6622-6657). This rule directly affectsSubpart X OB/OD operations in three situations: (1)use of a product for its intended use, including theOD of bombs hitting the ground, the OD of explo-sives for mining or road clearing, and the training ofmilitary personnel in the OB/OD of military muni-tions, (2) the on-range OB/OD destruction ofunexploded ordnance (UXO) during range clear-ance activities at active or inactive ranges, and (3)the OB/OD destruction of all munitions and explo-sives during an emergency response. In the first twosituations the final rule specifies that these materialsare not solid waste, and therefore the RCRApermitting standards do not apply. In the third case,regardless of whether the material is a solid waste,the final rule exempts the emergency OB/ODoperations from RCRA permitting requirements.Except for the training of military personnel in theOB/OD destruction described in situation one, thesesituations apply to non-military munitions andexplosives. For all other non-use OB/OD destruc-tion of munitions or explosives, RCRA permitting orinterim status is generally required. These situationsare discussed in greater detail below.

3.2.8.1 Training in Use of a Product

The final Military Munitions Rule, in 40 CFR266.202 (a)(1)(i), states that a military munition isnot a solid waste when it is used for its intendedpurpose, including use in training military personnelin the proper and safe OB/OD destruction of unusedpropellant or other military munitions as may be

The Military Munitions Rule Fact Sheetprovides an overview of this regulation.

http://www.epa.gov/epaoswer/hazwaste/military/muns_fs.txt


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required on the battlefield, and the training of militaryexplosives and munitions emergency responsespecialists (i.e., explosive ordnance disposal (EOD)or technical escort unit (TEU) personnel) in theproper and safe OB/OD destruction of munitionsand explosives. Such destruction training is not aRCRA-regulated activity because the material is aproduct and not a solid waste. That is, theproduct is being used to train personnel in theproper and safe use of the product, as contrasted todestruction of an excess or waste product in theabsence of training, which is a RCRA-regulatedactivity.

Military is defined in the final rule to include theDepartment of Defense (DOD), the Armed Ser-vices, Coast Guard, National Guard, Department ofEnergy (DOE), or other parties under contract oracting as an agent for the foregoing, who handlemilitary munitions. Military munitions is defined inthe final rule to include all ammunition products andcomponents made or used for national defense andsecurity, including confined gaseous, liquid, and solidpropellants, explosives, pyrotechnics, chemicalwarfare and riot control agents, smokes and incendi-aries, chemical munitions, rockets, guided andballistic missiles, bombs, warheads, mortar rounds,artillery ammunition, small arms ammunition, gre-nades, mines, torpedoes, depth charges, clustermunitions and dispensers, demolition charges, anddevices and components thereof. Military muni-tions do not include wholly inert items, improvisedexplosive devices, and nuclear weapons, nucleardevices, and nuclear components thereof. The termdoes include non-nuclear components of nucleardevices, managed under DOEs nuclear weaponsprogram after all required sanitization operationsunder the Atomic Energy Act of 1954, as amended,have been completed.

Training (as distinguished from waste disposal) maybe evidenced by the existence and use of detailedprotocols or training manuals for training militarypersonnel in the handling and burning of unusedpropellant, the presence of military trainees, anddocumentation of the training activities (e.g., numberof personnel trained, date and time of training,

OB/OD destruction of excess propellants orother munitions and explosives in theabsence of training is not a use for itsintended purpose, but rather, is treatmentof a solid waste requiring a RCRA permitunder Part 264, Subpart X, or interimstatus under Part 265, Subpart P.

The preamble to the Military Munitions Ruleprovides information on documentation U.S.EPA prefers to see to justify training events.


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military personnel attendance lists, and the amount ofpropellant used in training).

3.2.8.2 Range Clearance

The final Military Munitions Rule, in 40 CFR266.202 (a)(1)(iii), states that the recovery,collection, and on-range destruction of unexplodedordnance and munitions fragments during rangeclearance activities at active or inactive ranges isincluded within the use of a product for its intendedpurpose and therefore is not a solid waste. Sincethe material is not a solid waste, a RCRA permit isnot required for its on-range destruction by OB/OD.

The final rule defines active range as a militaryrange that is currently in service and is being regu-larly used for range activities. Inactive range isdefined as a military range that is not currently beingused, but that is still under military control andconsidered by the military to be a potential rangearea, and that has not been put to a new use that isincompatible with range activities. Military rangeis defined to include firing lines and positions,maneuver areas, firing lanes, test pads, detonationpads, impact areas, and buffer zones with restrictedaccess and exclusionary areas.

The final rule clarifies, in 40 CFR 266.202(c)(1),that a used or fired military munition is a solid waste,and therefore subject to the RCRA permittingrequirements, when transported off range or from asite of use, where the site of use is not a range, forthe purposes of reclamation, treatment, disposal,treatment prior to disposal, or storage prior toreclamation, treatment, or disposal.

In the training and range clearance situations, apermitted RCRA OB/OD unit may still be used solong as the permit conditions are met.

3.2.8.3 Emergency Responses

The final Military Munitions Rule, in 40CFR262.10(i), 264.1(g)(8), 265.1(c)(11), and270.1(c)(3), states that immediate responses toactual or potential threats involving explosives and


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munitions are exempt from RCRA generator andpermitting requirements. Transportation during anemergency response to a safer location, such as anopen space or EOD range for treatment or othermeans of rendering safe, is exempted, in 40 CFR263.10(e), from RCRA transporter/manifestingrequirements.

The final Military Munitions Rule includes three keydefinitions pertinent to explosives and munitionsemergency responses that help clarify the scope ofthis exemption. Explosives or munitions emer-gency is defined as a situation involving the sus-pected or detected presence of unexploded ord-nance (UXO), damaged or deteriorated explosivesor munitions, an improvised explosive device (IED),other potentially explosive material or device, orother potentially harmful military chemical munitionsor device, that creates an actual or potential immi-nent threat to human health, including safety, or theenvironment, including property, as determined byan explosives or munitions emergency responsespecialist. Such situations may require immediateand expeditious action by an explosives or munitionsemergency response specialist to control, mitigate,or eliminate the threat.

Explosives or munitions emergency response isdefined as all immediate response activities by anexplosives or munitions emergency response spe-cialist to control, mitigate, or eliminate the actual orpotential threat encountered during an explosives ormunitions emergency. An explosives or munitionsemergency response may include in-place render-safe procedures, treatment or destruction of theexplosives or munitions and/or transporting thoseitems to another location to be rendered safe,treated, or destroyed. Any reasonable delay in thecompletion of an explosives or munitions emergencyresponse caused by a necessary, unforeseen, oruncontrollable circumstance will not terminate theexplosives or munitions emergency. Explosives andmunitions emergency responses can occur on eitherpublic or private lands and are not limited to re-sponses at RCRA facilities.


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Explosives or munitions emergency responsespecialist is defined as an individual trained inchemical or conventional munitions or explosiveshandling, transportation, render-safe procedures, ordestruction techniques. Explosives or munitionsemergency response specialists include DODemergency EOD, TEU, and DOD-certified civilianor contractor personnel; and other Federal, State, orlocal government, or civilian personnel similarlytrained in explosives or munitions emergency re-sponses.

When a munition lands off-range, it must bepromptly rendered safe and/or retrieved, or ifremediation is infeasible, a record of the event mustbe maintained as long as any threat remains. RCRAcorrective action or Section 7003 imminent andsubstantial endangerment authorities, or CERCLAauthorities, may be used to address the problem,including use of in-place OB/OD.

As stated earlier, an explosive or other munitionposing or potentially posing an imminent and sub-stantial endangerment threat are exempt from RCRApermitting under 40 CFR 264.1(g)(8) and270.1(c)(3). Non-time-critical emergency re-sponses, however, are subject to the emergencypermit requirements of 40 CFR 270.61. Emer-gency permits may be oral or written. If oral, it mustbe followed in five days by a written emergencypermit. Emergency permits must be accompaniedby a public notice per 40 CFR 270.61. Somestates require notification prior to and/or after theemergency permit action is completed. Conditionsin the permit should describe the type of communi-cation necessary. The following is a listing ofconditions that may be included in an emergencypermits.

Temporary EPA ID Number Verification of a threat to human health or the

environment Type of waste(s) and amount Method of treatment Location and restrictions, isolation distances Time Limit: up to 90 days Notification of initiation and completion


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General permit conditions applicable to anypermit

Special conditions related to the permittedactivity- Compliance with DOT- Rate of treatment- Treatment unit design- Discharges or emission compliance with

other laws (CWA, CAA)- Preparedness and prevention- Inspection and disposal of treatment

residues Corrective action provisions can also be applied

as a standard condition.

Some states require sampling in emergency permits.Data quality objectives (DQOs) need to beconsidered in requiring sampling. EPA guidance onthis topic is available in a document titled FieldSampling and Selecting On-site Analytical Methodsfor Explosives in Soils (EPA/540-R-97/501),November 1996.

Conditions requiring removal and management of allvisibly affected soil and any popout, may besufficient in some emergency permits. This provisionwould reduce risk from materials left on-site, whichis common in emergency situations. Removal wouldalso reduce future land use risk at the location oftreatment. For thermal treatment of metal bearingwastes, air sampling may be required if pollutioncontrols are not installed on the unit. An example ofan emergency permit is provided from the State ofNebraska.

Emergency permits issued to the same facility or thesame owner/operator on a routine basis may show aneed for an operating permit. Routine is not defined,but over 3-5 times a year may show repetition.Agencies need to consider administrativeprocessing, permitting fees, etc. in determining howmany emergency permits should be issued to thesame owner/operator. Emergency permits aremeant for threats. If threats are becoming a problemit may be necessary for the State and other RCRAauthorities to assess the facility and operations.

Additional information regarding emergencypermits is outlined in the Emergency Permitsand RCRA Emergency Exemptionpresentations from the February 2002 EPARegion 4 RCRA Miscellaneous UnitsPermitting and Compliance Training.

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3.2.8.4 Other Changes Impacting OB/ODUnits

40 CFR 266.203 (a)(1) provides a conditionalexemption from the RCRA manifest requirementsfor the transportation of conventional munitions fromone military installation to an OB/OD facility atanother military installation, but not to a commercialOB/OD facility.

3.3 Subpart EEE - NESHAPS: FinalStandards for Hazardous Waste AirPollutants for Hazardous WasteCombustors

Section 264.601 was recently modified (refer to 64FR 52993, September 30, 1999) to include areference to the new 40 CFR Part 63 Subpart EEEstandards (NESHAPS: Final Standards forHazardous Waste Air Pollutants for HazardousWaste Combustors; Final Rule (HWC MACTRule)). 40 CFR 264.601 now states that permitterms and provisions must include thoserequirements of subparts I through O and subpartsAA through CC of this part, part 270, part 63subpart EEE, and part 146 of this chapter that areappropriate for the miscellaneous unit beingpermitted. Refer also to the March 10, 2000Policy Memo for additional clarification regardingSubpart EEE.

3.4 Endangered Species Act

The Federal Endangered Species act and similarState legislation require the determination that nothreatened or endangered species will be affectedadversely by proposed activities. The permitapplicant must certify, either through a biologicalassessment or through a literature review, that nosuch species are present in the area of the unit. Ifsuch species are present, a plan must be developedto minimize any effects on those organisms.

In the case of a unit to be located along a migratorypathway of some animal, similar options areavailable. If, for example, a unit were to be locatedalong a migration pathway used by elk, the permit

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application should include a discussion of additionalphysical barriers that would exclude elk from thearea and perhaps, a discussion of schedulemodifications of the operating schedule of the unit toaccount for their migratory habits.

Dealing with an environmental impact statement(EIS) is far more complicated than handling any ofthe circumstances described earlier. If, based on theEIS, an applicant has not been able to obtain afinding of no significant impact (FONSI) or acategorical exclusion for the operation, the terms ofthe EIS are likely to add a new level of complexityto the application. The findings of any required EIS,and the mitigation and monitoring plans included in it,should be included with the permit application as anappendix. The permit applicant should discussexplicitly how the mitigation and monitoring planswill be implemented and how implementation willaffect overall operations. Once again, the permitwriter must evaluate the information against themitigation and monitoring plans and determinewhether it meets those requirements and whether therequirements cause unintended problems in theoperation of the unit.

Refer to the Specific Technical Issuespresentation (slides 65-68) from the February2002 EPA Region 4 RCRA MiscellaneousUnits Permitting and Compliance Training foradditional information on Endangered Speciesissues.

http://www.eqp.gov/rcraonline/index.htm

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4.0 INFORMATION REQUIREMENTS

A Subpart X permit applicant must provide bothgeneral and specific information about the miscella-neous units described in the permit application.General information requirements for all RCRApermit applications, including those for miscellaneousunits, are specified in 40 CFR 270.14. Thespecific information requirements for Subpart Xunits, set forth in 40 CFR 270.23, include adetailed description of the unit, environmentalsettings, pathways of exposure and receptors, anddemonstration of effectiveness of treatment.

The following subsections provide guidance forevaluating information submitted by permit appli-cants in response to the specific, and some of thegeneral information requirements. Appendix A ofthis document contains a check list that summarizesthe information requirements that must be addressedin a Subpart X permit application. Permit writersalso should refer to the RCRA MiscellaneousTreatment Units Permitting and Compliance Training- Available Information and Tools, General Techni-cal Issues and Specific Technical Issues presenta-tions for assistance in reviewing Subpart X permitapplications. In addition, a number of states havealso developed Subpart X guidance. In addition, anumber of states have also developed guidance onreviewing permit applications for Subpart X units.

4.1 Physical and Chemical Characteristicsof Waste and Residues

The permit application for a miscellaneous unit, mustinclude waste characterization data that are sufficientto assure that the wastes managed by the facility canbe (1) adequately and safely stored at the facilityand (2) effectively treated in the miscellaneous unit.For each hazardous waste and hazardous debristreated, stored, or disposed of at the facility, thepermit application must include a description of thewaste and its EPA or state hazardous waste code,its hazard characteristics, the basis for its designationas hazardous, and the results of chemical andphysical analyses of representative samples of thewaste. However, certain types of wastes, such as

Draft Encyclopedia April 2002

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