no stricter, no sooner rule provisions affected, by david shanks, boeing, at regform's first...

2012 Missouri Hazardous Waste Seminar

November 13, 2012

David Shanks

Waste Identification No standardized TSD permits

for certain non-thermal treatment processes.

Material stored in surface impoundments or piles is solid waste, even if recycled.

No exemption for condenser dross residue from treatment of K061 (steel furnace dust) in metal recovery units.

No exemption for comparable fuels that meet requirements of 261.38.

Household hazardous waste becomes regulated if accepted by a TSDF.

Waste Identification Additional MO conditions

on CESQG allowance for on-site treatment.

Waste list modifications for F020, F023, and F027 waste, related to production of hexachlorophene and dioxin generation thresholds.

Lack of federal comparable fuel specifications.

Waste Generators MO-specific dioxin codes

on manifest.

Shipment-ready packaging, marking & labeling during entire storage period.

Beyond-weekly inspection: undefined “often enough..”

Detailed, prescriptive secondary containment requirements.

Waste Generators Additional safety equipment,

“such as fire blankets, gas masks, and self-contained breathing apparatus.”

One year time limit on satellite accumulation, dates required on satellite containers.

No generator use of drip pads that meet Subpart W.

Generators meet same requirements for ignitible and and reactive wastes as TSDs.

Waste Generators Manifest exception

reporting differences:

45 day deadline for generators between 100-1000 kg/mo

Detailed content and certification language.

TSD Rules Additional conditions on federal

exclusion of elementary neutralization and on-site wastewater treatment.

24 hour rule for wastes coming to a TSD, but not yet within permitted area boundary.

No reliance on federal Appendix VI county list regarding seismic risk. Missouri PE must certify ability to withstand earthquake loadings, regardless of location.

TSD Rules Detailed design criteria

for indoor storage of ignitible or reactive waste if <50 ft. from property boundary, in lieu of federal prohibition.

TSD Rules Multiple pages of MO

text with very detailed design criteria and location restrictions for surface impoundments, waste piles, and hazardous waste landfills Rather than performance

requirements of federal rule or permitting guidance.

TSD Rules Missouri-unique Railcar

management plans

time limits

restrictions on storage in railcars, etc.