A successful petition to delist a hazardous waste
Conference
·
OSTI ID:353672
- O`Brien and Gere Engineers, Inc., Novi, MI (United States)
The prospect of a favorable ruling in an effort to have a hazardous waste delisted is remote, and few have been granted. This paper recounts the successful procedure used to have materials from a hazardous waste site delisted. Other property owners with sites affected with hazardous wastes will find the methodology discussed here instructive if they are contemplating a delisting petition. The regulatory agency with jurisdiction was the Michigan Department of Environmental Quality through its Waste Management Division (MDEQ WMD). The state has accepted authority for this function from the USEPA. The materials from discontinued electroplating operations were considered hazardous based on their contact with a listed F006 waste sludge generated from the electroplating operations. The sludge had been stored in surface impoundments. To initiate the delisting procedure, the requirements of a USEPA document were followed: Petition to Delist Hazardous Wastes, a Guidance Manual. The MDEQ WMD sanctioned the use of this guidance. This document is issued by the Office of Solid Waste. In observing the guidance, the following actions were taken: (1) Collection of soil samples from the area proposed for delisting; (2) Evaluation of data and the feasibility of preparing a delisting petition; (3) Development of the petition. In developing the details of the petition, the data from the site were scrutinized. Analytical results of metals in the soil samples were compared with pre-established maximum allowable concentrations that had been calculated in a closure plan. These values were also compared with delisting levels calculated by USEPA`s Composite Model for Landfills (EPACML). The data indicated that the levels of chemical constituents were below the appropriate regulatory criteria. Therefore, the petition was launched. This paper discusses their effective procedure and contents of each section of the delisting petition.
- OSTI ID:
- 353672
- Report Number(s):
- CONF-970677--
- Country of Publication:
- United States
- Language:
- English
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