homework 11 - Vanessa Barela April 15, 2007 Enve 302...

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Vanessa Barela April 15, 2007 Enve 302 Homework #11 1) According to 40 CFR 300.400 a CERCLA waste can be shipped off site to a RCRA TSD facility for treatment and disposal as long as the facilities themselves are not under RD/RA and the facility is allowed to accept waste. The EPA will determine if the facility is allowed to accept the CERCLA waste. CERCLA waste cannot be shipped to a RCRA site if there s a non-receiving unit that is releasing hazardous waste is being corrected. A RCRA hazardous waste can be transferred from a CERCLA site for treatability studies and meet the requirements for an exemption under 40 CFR 261.4(e). The facility must be in compliance, and meet 40 CFR 268 subpart D standards, the treatment must also reduce mobility, toxicity, or persistence if there is no treatment standard, the storage and ultimate disposal the CERCLA waste is not treated to the pervious criteria. Violations include deviations from regulations, order provisions, or permit conditions. These provisions are in place to ensure that the CERCLA waste is at an authorized facility, it does not release more hazardous waste, there is proper detection for releases, and there will be corrective action for any future release. Additional requirements for RCRA include, following subsections of sections 3004 and 3005 of RCRA, sections of State environmental law, land disposal units at RCRA subtitle C facilities tat receive RCRA waste under CERCLA must be in compliance with RCRA section 3004(o) minimum technology requirements, exceptions may only be made if a waiver from 40 CFR 264.301 is met. Releases cannot exceed RCRA section 3004(n) if they are into the air. If there is a release from a RCRA site receiving CERCLA wastes, the CERCLA waste may be transferred to an off-site unit regulated under subtitle C of RCRA only if that unit is not releasing any hazardous waste to the water, soil, or air. CERCLA wastes may not be shipped to any unit at a RCRA subtitle C land disposal facility where a non-receiving unit is releasing any hazardous wastes into the air, water, or soil, unless the release is controlled by an enforceable agreement for corrective action under subtitle C of RCRA. A RCRA land disposal facility is defined as any RCRA facility where land disposal unit is located, regardless of if the unit is the receiving unit. CERCLA waste should not be transferred to any facility that is not a RCRA subtitle C facility. 2) The procedures relative to the Potentially Responsible Party (PRP) and the EPA from the City of Socorro can be reimbursed from the EPA if requested. Only one reimbursement request can be made, so only one organization request reimbursement on behalf of all involved. According to 40 CFR 310.14, the City of Socorro must try to recover the
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homework 11 - Vanessa Barela April 15, 2007 Enve 302...

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