Treatment and Disposal Methods and Processes OBJECTIVES At the completion of this chapter, the student should: • Have overview knowledge of historical and traditional methods of treat- ment and disposal of hazardous wastes, and the environmental impacts of each. • Have knowledge of past and present practices of land treatment and disposal, the environmental impacts thereof, and the RCRA land disposal restrictions. • Have overview knowledge of nonpoint-source water quality impacts of hazardous waste treatment and disposal operations. • Understand the air quality implications, residue management, and waste destruction capabilities of burning vs. incineration and the RCRA approach to each. • Understand some of the classic reuse and recycling processes as a basic management approach and as an introduction to Chapter 8. • Understand the basic differences between treatment, immobilization, and destruction and the processes associated with each category. • Be familiar with history and practice of ocean dumping and underground injection and with concerns regarding potential environmental impacts of each. INTRODUCTION In the two previous chapters, we overviewed first the generation and then the transportation of hazardous wastes. We now take up the technologies, practice, and regulatory requirements associated with the ultimate disposition of hazardous wastes. Where appropriate, we will follow the pattern of previous chapters by beginning a topic with a discussion of “generic” practice or technology and follow with the regulatory requirements of the Resource Conservation and Recovery Act (RCRA). As before, the format for a generic discussion of treatment and disposal is shaped by the RCRA format that groups treatment, storage, and disposal functions together 7 L1533_frame_C07 Page 127 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC as the “final link in the cradle-to-grave hazardous waste management system.” The rationale for grouping treatment and disposal together is fairly clear. Some recollection of the early practices and “horror stories” of Chapter 1 should serve to refresh our understanding of the abuses that were associated with accumu- lation of hazardous wastes. It is clear throughout the Subtitle C regulations that Congress intended that accumulation of hazardous wastes be controlled very rigor- ously. Thus, the grouping of treatment, storage , and disposal facilities (TSD facilities or TSDFs) as the final link, and as the entities requiring operating permits, became a regulatory format. For instructional purposes, it has become an entire way of thinking about the final disposition of hazardous waste. The original RCRA legislation establishes two categories of TSD facilities based upon permit status. Section 3005(a) of the Act specifies that TSD facilities must obtain a permit to operate. In recognition of the fact that several years would be required for the EPA to issue permits to all operating facilities, Congress included § 3005(e), which established “ interim status .” TSD facilities that were in existence on November 19, 1980, and met certain conditions, were allowed to continue oper- ating until their permit was issued or denied. Such facilities are said to have interim status and are regulated by 40 CFR 265. The second category consists of those facilities having permits . Permitted facilities are regulated by 40 CFR 264. Both interim status and permit standards consist of two types of requirements: • Administrative and nontechnical requirements which are nearly identical for interim status and permitted facilities • Technical and unit-specific requirements which embody significant dif- ferences for interim status and permitted facilities Large numbers of interim status facilities continue to operate legally without fully approved permits , and it is expected that this situation will prevail for several more years. The 40 CFR 264 “finally permitted” standards, which will eventually apply to all TSD facilities, are more stringent than the Part 265 “interim status” standards. However, they are only a blueprint for the permit writer who must develop “best engineering judgment” standards for the specific facility. In the following paragraphs, we will overview both the interim status and permitted facility standards pertaining to administrative and nontechnical requirements. We will point out various differences that exist between the two sets of requirements. Treatment, storage, and disposal practice involves a large variety of units and technologies. Thus, the TSD regulations are far more extensive than for generators and transporters. We will attempt to overview only the most important generic topics and salient features of the regulations. The student or reader is encouraged to (and the practitioner must) explore the technical literature and the RCRA Subtitle C regulations for details. A DMINISTRATIVE AND N ONTECHNICAL R EQUIREMENTS The administrative and nontechnical requirements are intended to ensure that owners and operators establish the necessary procedures and plans to operate the TSD facility L1533_frame_C07 Page 128 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC according to established practice and to handle any emergencies or accidents. The administrative and nontechnical requirements for interim status and permitted TSDFs are very similar. These requirements are found in Subparts A through E of 40 CFR Parts 264 and 265. Subpart A — Facilities That Are Subject to the Regulations In general, all owners or operators of facilities engaged in the treatment, storage, or disposal of hazardous wastes must comply with the 40 CFR 264/265 regulations unless they are specifically excluded. Exceptions include • A farmer who disposes of waste pesticides from his own operations • Facilities that qualify for a “permit-by-rule” 1 • The owner or operator of a totally enclosed treatment facility • The owner or operator of an elementary neutralization unit • The owner or operator of a wastewater treatment unit that is subject to Clean Water Act pretreatment standards or a National Pollutant Discharge Elimination System (NPDES) permit • A person who responds to or cleans up a hazardous waste spill or release • Facilities that legitimately reuse, recycle, or reclaim hazardous waste • Generators, including small quantity generators (SQGs), that accumulate wastes within the time periods specified in 40 CFR 262 • Facilities that treat, recycle, store, or dispose of wastes generated by conditionally exempt small quantity generators (CESQGs) 2 • A transporter that stores manifested shipments for less than 10 days (40 CFR 265.1) Interim status TSDFs may manage dioxin-containing wastes (F020-F023, F026, and F027) only if the requirements of 40 CFR 265.1(d) pertaining to an immediate threat to human health, public safety, property, or the environment from the known or suspected presence of military munitions, other explosive material, or devices are met. Subpart B — General Facility Standards As was covered in the previous chapters, all facilities handling hazardous wastes must obtain an EPA identification number. 3 Owners and operators of TSDFs must ensure that the wastes being handled are correctly identified and managed according to the regulations. They must ensure that facilities are secure and are operating properly. Personnel working in the facilities must be trained to perform their duties 1 Facilities that have a permit issued under other environmental laws, i.e., ocean disposal, underground injection, publicly owned treatment works, that meet the requirements of 40 CFR 270. 2 See: 40 CFR 261.5. 3 It may be conceptually useful to understand that anyone can apply for, and obtain, an EPA ID number. Issuance of the ID by the EPA does not amount to a permit or certification. It is a means of identification that the holder will be called upon to provide should he/she ultimately engage in hazardous waste management activity. L1533_frame_C07 Page 129 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC correctly, safely, and in compliance with all applicable laws, regulations, and codes. In order to satisfy these requirements, owners and operators must: • Conduct waste analyses prior to initiating treatment, storage, or disposal in accord with a written waste analysis plan (WAP), which must be kept on site. The WAP must specify tests and test frequencies that will provide the owner or operator with sufficient information on the properties of the waste to enable management of the waste in accord with the applicable laws, regulations, and codes ( see: 40 CFR 264, 265.12). • Install security measures to prevent accidental or unauthorized entry of people or animals onto the active portions of the TSDF (Figure 7.1). The facility must be surrounded by a barrier (i.e., a fence) with controlled entry systems or 24-hr surveillance. Signs carrying the warning “Danger — Unauthorized Personnel Keep Out” must be posted at all entrances (Figure 7.2). Signs must be printed in English and also in other languages predominant in the area surrounding the facility. Precautions must be taken to avoid fires, explosions, generation of toxic gases, and any other events that would threaten human health, safety, and the environment. • Conduct inspections according to a written inspection plan and schedule to assess the compliance status of the facility and to detect potential problems such as malfunction, deterioration, operator error, and leaks or discharges. Observations made during the course of the inspections must be recorded in the facility’s operating log and kept on file for 3 years. All problems noted must be remedied. • Conduct training to reduce the potential for mistakes that might threaten human health and the environment. The regulations specify that the employee “… must successfully complete classroom instruction or on- the-job training that teaches them to perform their duties in a way that FIGURE 7.1 Site security requirement for RCRA sites. L1533_frame_C07 Page 130 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC ensures the facility’s compliance with the regulations.” In addition, the Occupational Safety and Health Administration (OSHA) requires TSD facilities to implement a hazard communication plan, medical surveillance program, and a health and safety plan. 4 Decontamination procedures (Chapter 15) must be in place and employees must receive a minimum of 24 hr of safety training. The training must be completed within 6 months from the date the facility becomes subject to the TSDF standards or 6 months from the date the employee begins work at the facility. New employees must work under supervision until the training is completed, and the training must be reviewed annually. • Properly manage ignitable, reactive, or incompatible wastes. Ignitable or reactive wastes must be protected from sources of ignition or reaction or be treated to eliminate the possibility. Owners or operators must ensure that treatment, storage, or disposal of ignitable, reactive, or incompatible waste does not result in damage to the containment structure, and/or threaten human health or the environment. Separation of incompatible wastes must be maintained. Part 264, Appendix V, provides a list of some common potentially incompatible wastes. It may be necessary to test the wastes to determine compatibility. • Comply with location standards to avoid siting a new facility (subject to Part 264) in a location where flood or seismic events could affect a waste FIGURE 7.2 Sign requirement for RCRA sites. 4 The required OSHA training is detailed in Chapter 15. L1533_frame_C07 Page 131 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC management unit. Existing facilities, subject to Part 265, are not required to meet this standard. Interim status and permitted TSDFs are prohibited from placement of noncontainerized or bulk liquid hazardous wastes in salt domes, salt beds, or underground mines or caves. The Department of Energy Waste Isolation Pilot Project ( see: Chapter 13) has been granted exclusion from this prohibition by Congress. • Prepare and comply with the construction quality assurance (CQA) pro- gram requirements that are applicable to foundations, dikes, soil liners, geomembranes, leachate detection, collection, and removal systems, and final cover systems at permitted and interim status facilities. The CQA program ensures that all design criteria are met during the construction of a unit. A written CQA plan is required. The CQA officer (a registered professional engineer) must certify that the unit meets all design criteria and permit specifications before waste can be received by the unit. These construction standards are extensive and will be covered in detail in the permitting process (40 CFR 264, 265 Subpart B). Subpart C — Preparedness and Prevention Facilities must be designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents which could threaten human health or the environment. 5 Facilities must be equipped with: • An internal communications or alarm system that can provide immediate emergency instructions to facility personnel • A telephone or two-way radio capable of summoning emergency assis- tance from local police, fire, and emergency response units • Portable fire extinguishers , fire, spill control, and decontamination equipment • Water at adequate volume and pressure to supply water hoses, foam- producing equipment, automatic sprinklers, or water spray systems All communications and emergency equipment must be tested as necessary to ensure proper operation in time of emergency. All personnel must have immediate access to the internal alarm or emergency communication system. 6 Aisle space (Figure 7.3) must be maintained to allow unobstructed movement of personnel and equipment during an emergency. Owners or operators of TSDFs must attempt to make arrangements to: 5 See: 40 CFR 264, 265.32 for exceptions to these rules where the nature of the hazard(s) cause the rule to be unnecessary. 6 If there is ever only one employee on the premises while the facility is operating, the employee must have access to a telephone or hand-held two-way radio, capable of summoning external emergency assistance [40 CFR 264, 265.34(b)]. L1533_frame_C07 Page 132 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC • Familiarize police, fire, and emergency response teams with the facility, wastes handled and their properties, work stations, and access and evac- uation routes. • Designate primary and alternate emergency response teams where more than one jurisdiction might respond. • Familiarize local hospitals with the properties of the hazardous wastes handled at the facility, and the types of injuries or illnesses which could result from events at the facility. Subpart D — Contingency Plan and Emergency Procedures A contingency plan must be in effect at each TSD facility and by reference [§ 262.34(a)(4)] at each generator facility. The plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any release of hazardous waste constituents. The plan must be implemented immediately when- ever there is a fire, explosion, or release which could threaten human health or the environment. The contingency plan must: • Describe the actions which personnel must take to implement the plan. • Describe arrangements concluded with local police, fire, and hospital authorities, contractors and emergency response teams to coordinate emer- gency services. • List names, addresses, and the telephone numbers of all persons qualified to act as emergency coordinator for the facility. • List emergency equipment, communication and alarm systems, and the location of each item. • Include an evacuation plan for facility personnel. FIGURE 7.3 Aisle space, drum stacking limitation. L1533_frame_C07 Page 133 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC The contingency plan must be maintained at the facility and at all emergency response facilities that might be called upon to provide emergency services. It must be reviewed and updated whenever any item affecting the plan is changed. A key requirement is the designation of an emergency coordinator who is responsible for directing response measures and reducing the adverse impacts of hazardous waste releases. There must be at least one employee present on the premises or on call at all times to fill this role. The emergency coordinator must have the authority to commit the resources needed to implement the emergency/contingency plan. Other regulatory programs related to hazardous waste management, releases of hazardous materials to the environment, or exposures of humans to toxic materials also require emergency response planning, and/or preparation of contingency plans. These planning requirements are becoming more numerous, and the specifications are becoming more complex and sophisticated. Risk assessment and risk manage- ment measures are being required in a wide range of situations. Owners or operators of TSD facilities and their emergency coordinators will increasingly find it necessary to devote time and resources to the contingency planning effort. Among the different regulatory programs, some planning requirements are similar, duplicative, overlap- ping, or redundant. Time and resource commitments, training, drills, and coordina- tion requirements can be economized by combining the required plans in one document. In an effort to assist preparers of these multiple planning requirements, five agencies 7 have collaborated in preparing the “‘Four’ Agency Integrated Contin- gency Plan.” The National Response Team (NRT), chaired by the U.S. EPA, has issued “The National Response Team’s Integrated Contingency Plan Guidance.” The guidance is intended to provide a mechanism for consolidating the multiple plans, that would otherwise be required, into one functional emergency response plan or integrated contingency plan (ICP). A copy of the guidance can be obtained by calling the EPCRA/RCRA/Superfund Hotline at 800-424-9346 or electronically at the home page of EPA’s Chemical Emergency Preparedness and Prevention Office (http://www.epa.gov/swercepp/). The ICP guidance document provides a suggested structure for the facility’s ICP and a detailed cross-reference matrix of ICP elements on the vertical axis and the regulatory Chapters and Parts on the horizontal headings. Table 7.1 lists the com- ponents and regulatory references upon which the ICP is based. The suggested structure is organized into three main sections: an introductory section, a core plan, and a series of supporting annexes. The structure of the core plan and annexes in the ICP guidance is based on the structure of the National Interagency Incident Management System (NIIMS) Incident Command System (ICS). NIIMS ICS is a nationally recognized system that has been used by federal, state, and local response organizations in a variety of emergency situations. The planner should find this guidance document to be helpful in developing a facility-specific ICP, which will dovetail with established response management practices, thereby facilitating its usefulness during an emergency. 7 Environmental Protection Agency; Department of Transportation, Coast Guard (USCG), and Research and Special Programs Administration (RSPA); Department of the Interior, Minerals Management Service (MMS); Department of Labor, Occupational Safety and Health Administration (OSHA). L1533_frame_C07 Page 134 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC Subpart E — Manifest System, Record Keeping, and Reporting The operation of the manifest system has been previously described. The TSDF owner or operator receiving the waste is responsible for ensuring that the waste described on the manifest is the same as the waste on the truck. The intent is to ensure that there are no significant discrepancies in the amount (e.g., an extra drum) or type of waste (e.g., acid waste instead of paint sludge) that was shipped by the generator. If a significant discrepancy is discovered, the TSDF must reconcile the difference with the generator or transporter. If the difference cannot be cleared up, the EPA must be notified within 15 days of the incident. The owner or operator or his agent must sign and date all copies of the manifest to verify that the waste has reached the designated facility. The copy of the signed manifest must be placed in the TSDF files, and a copy must be sent to the generator within 30 days. If it is necessary to send the waste to another facility, the owner/oper- ator/agent must initiate a new manifest. Subpart E includes extensive record keeping and reporting requirements (EPA 1998, Section III). G ENERAL T ECHNICAL S TANDARDS FOR I NTERIM S TATUS AND P ERMITTED F ACILITIES The 40 CFR 265, Subpart F, groundwater monitoring standards for interim status TSDFs were designed to minimize the potential for environmental and public health TABLE 7.1 Integrated Contingency Planning Components Agency Statute Plan Requirement Reference EPA RCRA Contingency Plan 40 CFR 262.34, 264 and 265, Subparts C and D, and 279.52 EPA CWA Spill Prevention Control, a Countermeasure Plan 40 CFR 112 EPA CAAA Risk Management Program for Chemical Accidental Release Prevention 40 CFR 68 DOI/MMS CWA/OPA a Facility Response Plan 30 CFR 254 DOT/USCG NNWA b Facility Response Plan 33 CFR 154, Subpart F DOT/RSPA HMTA Pipeline Response Plan 49 CFR 194 DOL/OSHA SARA c HazWOper Emergency Plan 29 CFR 1910.120 DOL/OSHA CAA Chemical Process Safety Standard 29 CFR 1910.119 DOL/OSHA OSHA Emergency Action Plans 29 CFR 1910.38 a Oil Pollution Act. b Navigation and Navigable Waters Act. c Superfund Amendments and Reauthorization Act (SARA) Title III includes emergency planning by State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs). RCRA facilities may be required or may wish to coordinate their contingency plans with those of the SERC or LEPC or both. L1533_frame_C07 Page 135 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC threats resulting from hazardous waste treatment, storage, and disposal at existing facilities that are awaiting permitted status. Over time, and because of the extended periods during which some facilities have operated under interim status, these stan- dards have taken on greater importance than was originally intended and are indeed minimally adequate to serve their intended purpose. In contrast, the Part 264 stan- dards entitled “Releases from Solid Waste Management Units” are detailed and comprehensive. Moreover, permit writers have wide latitude for imposing monitoring requirements that can reasonably be expected to detect releases from land-based units and/or provide the data needed for remediation. Nevertheless, there are com- mon technical and environmental performance elements of the interim status and permitted facility standards. Both sets of standards are designed to protect the uppermost aquifer, which is the water-bearing geologic formation nearest the ground surface. Any and all deeper aquifers that are hydraulically connected to the upper- most aquifer are considered to be part of that aquifer. Part 265, Subpart F — Groundwater Monitoring Owners and operators of surface impoundments, landfills, and land treatment facil- ities used to manage hazardous waste must meet minimum groundwater monitoring requirements. The interim status facility requirements in 40 CFR 265.91 call for a monitoring system consisting of at least one well upgradient from the facility and three downgradient wells. The upgradient well(s) must provide data on groundwater that is not influenced by leakage from the waste management unit. The downgra- dient wells must be placed to intercept any waste migrating from the unit should a release occur. Figure 7.4 illustrates a “one-up-and-three-down” layout of monitoring wells for a land-disposal facility — the upper left well being the upgradient or background data well and the others being the downgradient wells. Figure 7.5 illustrates an important problem, i.e., the nearby stream at low stage may draw the contaminant FIGURE 7.4 Groundwater monitoring well layout for a landfill disposal facility. (Adapted from Glenn R. Smart and David K. Cook, RCRA and CERCLA Groundwater Well Locations and Sampling Requirements, Hazardous Materials Control, 1(3), May/June 1988.) L1533_frame_C07 Page 136 Monday, May 7, 2001 11:29 AM © 2001 by CRC Press LLC [...]... 17 Pertaining to approximately 1% of the annual hazardous waste generation in the U.S., by the pre-19 97 RCRA definition of hazardous waste; ” or about 10% of the hazardous waste generated, based on the 19 97 RCRA definition which excluded wastewaters (see: Chapter 2) A large portion of the hazardous waste subject to the 1999 MACT combustion rule is “wastewater.” Thus, the total annual generation of hazardous. .. FIGURE 7. 7 Treatment and disposal alternatives for industrial wastes (Adapted from Hazardous Waste Management, © 1989, McGraw-Hill, New York With permission from Charles A Wentz.) © 2001 by CRC Press LLC L1533_frame_C 07 Page 145 Tuesday, May 1, 2001 12:33 PM FIGURE 7. 8 Centrifuge Component of a hazardous waste solidification system FIGURE 7. 9 Gravity separation cones (From ROMIC Chemical Corporation,... preclude future releases of hazardous wastes, waste constituents, or decomposition products of hazardous wastes All equipment, structures, and soil must be removed, disposed of, or decontaminated The closure and post-closure standards consist of two parts: (1) the general standards in 40 CFR Parts 264 and 265, Subpart G and (2) technical standards for specific types of hazardous waste management units as detailed... EPA publishes “guidance” documents dealing with a wide range of hazardous waste management topics, including treatment Several of them are referenced throughout this chapter Destruction of Hazardous Wastes by Thermal Processes Organic compounds can be destroyed by well-designed and properly operated hightemperature processes Hazardous waste incinerators (adding an oxidizing agent to the process) can... closure and post-closure funds (see also: U.S EPA 1998, Chapter 5) HAZARDOUS WASTE TREATMENT Hazardous waste treatment is a rapidly developing industry full of experimentation and innovation This innovation is being driven by the need for effective and economical processes for reclaiming, treating, or destroying wastes rather than landfilling them without treatment A hierarchy of general waste management. .. L1533_frame_C 07 Page 141 Tuesday, May 1, 2001 12:33 PM authority and to the EPA or the state agency The plat preserves a record of the exact location and dimensions of the hazardous waste activity for future reference A notation must also be made on the deed to the property, notifying potential purchasers that the site was engaged in hazardous waste activity Following the closure, a 30-year post-closure... common method of hazardous waste management, and the practice can be a potential threat to human health and the environment Burners mix hazardous wastes with fuel oil or other fuel mixtures and burn the mix in low temperature/low pressure boilers or other combustion units Some flammable wastes continue to be burned in disregard of federal, state, and local regulations and ordinances Such low-temperature... L1533_frame_C 07 Page 149 Tuesday, May 1, 2001 12:33 PM FIGURE 7. 10 Carbon adsorption pressurized contactor • Mixing acidic waste with lime or dolomite lime slurries • Mixing the acidic waste with a compatible alkaline waste1 3 Methods of neutralizing alkaline wastes include • • • • Adding appropriate amounts of strong or weak acid to the waste Adding compressed carbon dioxide gas to the waste Blowing... Blowing flue gas through the waste Mixing the alkaline waste with a compatible acidic waste1 3 (Hass and Vamos 1995, Chapter 5) 13 Great care must be taken in determining compatibility of wastes to be mixed For an exhaustive treatment of the neutralization processes, see Hass and Vamos 1995, Chapter 5 © 2001 by CRC Press LLC L1533_frame_C 07 Page 150 Tuesday, May 1, 2001 12:33 PM FIGURE 7. 11 Carbon regeneration... state agency may establish additional clean-closure requirements on a case-by-case basis (Figure 11.18 illustrates the extent of removal that may be necessary to “clean close” a former hazardous waste impoundment.) A successful demonstration of clean closure eliminates the requirement for post-closure care of the site (see also: U.S EPA 1997b; U.S EPA 1998, Chapter 5) Subpart H — Financial Requirements . from the waste management unit. The downgra- dient wells must be placed to intercept any waste migrating from the unit should a release occur. Figure 7. 4 illustrates a “one-up-and-three-down” layout. disposal functions together 7 L1533_frame_C 07 Page 1 27 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC as the “final link in the cradle-to-grave hazardous waste management system.” The rationale. coagulants. L1533_frame_C 07 Page 143 Tuesday, May 1, 2001 12:33 PM © 2001 by CRC Press LLC FIGURE 7. 7 Treatment and disposal alternatives for industrial wastes. (Adapted from Hazardous Waste Management, ©