At a power plant, the regeneration wastes from water treatment systems and
the metal cleaning wastes can sometimes meet the corrosiveness test with a pH below 2.
188.8.131.52 Totally Enclosed Facilities. A Hazardous Waste Management Facility (HWMF)
permit is not required for any "totally enclosed" facilities used to treat hazardous
wastes. A facility is considered "totally enclosed" if the facility is constructed and
operated in a manner which prevents the release of any hazardous waste constituent into
the environment. A covered neutralization tank is an example of a totally enclosed
To qualify for the exception, the neutralization tank must meet the
a) The neutralization tank must be in a secure area. A fence with
controlled access around the entire generating facility would suffice.
b) The neutralization tank must be inspected for equipment malfunctions or
deterioration, operator errors, and discharges of the waste. A written inspection plan
and log must be kept.
c) The treatment process must not generate extreme heat or pressure,
produce uncontrolled toxic vapors, or pose a risk of fire or explosion. The process
must be conducted so as not to damage the structural integrity of the tank.
d) The tank must be constructed of sturdy, leakproof material and must be
designed, constructed, and operated so as to prevent hazardous wastes from being spilled
e) Any significant spills or leaks of hazardous waste must be reported to
the EPA Regional Administrator.
184.108.40.206 Nonhazardous Waste. RCRA classifies all nonhazardous waste disposal
facilities as either sanitary landfills or open dumps. Open dumps are facilities that
do not provide adequate protection for health and the environment. They are
unacceptable under RCRA and they were all to be up graded to a sanitary landfill or
phased out within 5 years. Sanitary landfills are disposal facilities that do provide
adequate safeguards for health and the environment. All nonhazardous waste disposal
facilities, then, must either meet the requirements of a sanitary landfill or must have
been closed. EPA has promulgated regulations that define more specifically the
difference between sanitary land fills and open dumps. The portions of these
regulations that would be applicable to fly ash, bottom ash, or scrubber sludge disposal
are as follows.
a) Facilities or disposal practices in a flood plain cannot restrict the
flow of a 100-year flood, reduce the temporary water storage capacity of the flood
plain, or result in washout of solid waste.