| Abstract: | Delisting (up-front or not) of hazardous waste streams (with or without stabilization or any other form of treatment) can be an effective approach for reducing high sludge disposal costs because a nonhazardous classification of the waste will alleviate the financial burden associated with the disposal costs. Facilities may petition EPA to remove individual waste streams from regulation as listed hazardous wastes under the Resource Conservation and Recovery Act (RCRA). EPA encourages the use of up-front delisting petitions because they have the advantage of allowing the applicant to know what treatment levels for constituents should be sufficient to render specific wastes nonhazardous before investing in new or modified waste treatment systems. Thus, up-front delisting allows new facilities to receive exclusions prior to generating wastes that, without upfront exclusions, would unnecessarily have been considered hazardous. On July 18, 1991, EPA proposed to use the EPA Composite Model for Landfills (EPACML) when considering delisting petitions and evaluating the impact of the petitioned waste on human health and the environment. The use of the EPACML provides consistency in delisting decisions. Further, this new model allows a two-to-three-times higher dilution than the previously used Vertical and Horizontal Spread (VHS) model. This article presents case studies from several industry sectors where stabilization and delisting were used to manage wastes in a reliable, cost-effective, and environmentally sound manner. |
