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Five Things to Remember About Haz Waste Surface Impoundments
The Environmental Protection Agency (EPA) allows land placement of hazardous waste in nine different types of land disposal units (LDUs), but has promulgated unit-specific standards for only four, two of which are surface impoundments and waste piles. These standards are covered in 40 CFR 264/265 Subpart K and Subpart L, respectively, and include design and operations, inspection and response actions, closure, special requirements for certain wastes and, for surface impoundments, retrofitting.
Here are five things to take away from the unit-specific standards for hazardous waste surface impoundments in Subpart K:
1) Don’t confuse a surface impoundment with a tank. According to the EPA, although the definitions seem similar, the defining difference is what provides structure to the unit. In the case of surface impoundments, the structure is provided by earthen materials, while tanks are supported by other non-earthen materials such as wood, concrete, plastic, or steel. The agency recommends evaluating the unit as if it were free-standing and filled to its design capacity. If it can maintain its structural integrity, it is a tank, but if it cannot, it is a surface impoundment.
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2) RCRA mandates minimum technical requirements (MTRs) for regulated surface impoundments (all new units, lateral expansions, and replacement units for which construction or reuse began after July 29, 1992). They include:
- A double liner,
- A leachate collection and removal system, and
- A leak detection system.
In addition, these systems all require a construction quality assurance (CQA) program to ensure technical integrity. The CQA program requires a CQA plan that must identify how construction materials and installation will be monitored and tested, as well as how the results will be documented. CQA program development and implementation requires a professional engineer (PE) who will also be required to certify that the CQA plan was successfully implemented and that the LDU meets all required specifications before any waste is accepted at the site.
3) RCRA requires several types of inspections for hazardous waste surface impoundments:
- General inspection requirements under 40 CFR 264/265.15,
- Design and structural integrity inspections by the owner/operator initially after construction/installation and weekly thereafter, as well as after storms, with specifics defined in 40 CFR 264/265.226, and
- Leak detection sump inspections at least weekly to ensure liner integrity and leachate pump efficiency as well as monitoring the action leakage rate (ALR) as established in 40 CFR 264/265.223.
4) Emergency repair provisions must be undertaken for unit design failures at permitted facilities when systems or monitoring indicate a failure of the containment system. In such an event, that surface impoundment must be removed from service and the owner/operator must follow the facility’s contingency plan, including any repairs that are necessary, in accordance with 40 CFR 264.227.
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5) There are two closure options for surface impoundments with hazardous waste:
- Clean closure, which means the owner/operator is required to remove or decontaminate all wastes and unit components at closure as defined in 40 CFR 264/265.228(a)(1), or
- Waste-in-place closure, which requires that any wastes left at the unit be stabilized, free liquids removed, and a cap or cover installed. This option also has post-closure requirements as defined in 40 CFR 264/265.228(a)(2) and (b).
These are just some of the major requirements and each has specific actions and activities associated with it to ensure hazardous waste surface impoundments are safe and well managed. Tomorrow, we will look at similar requirements for hazardous waste piles.