CHMM Disposition of Hazardous Materials 4 — Questions and Answers
Question 1: A facility plans to thermally treat hazardous waste in a boiler to recover energy. Under what conditions is this considered legitimate recycling rather than sham recycling?
- The waste must have a heating value of at least 5,000 BTU/lb and be used as a fuel in a boiler (Correct answer)
- The waste must be listed as a fuel in 40 CFR 261
- The waste must meet RCRA ignitable characteristic only
- Any thermal treatment qualifies as energy recovery
Correct answer: The waste must have a heating value of at least 5,000 BTU/lb and be used as a fuel in a boiler
EPA's legitimacy criteria require, among other things, that hazardous waste burned for energy recovery have a meaningful heating value (≥5,000 BTU/lb) and be used as a fuel.
Question 2: Which type of hazardous waste storage unit requires secondary containment, leak detection, and a liner under 40 CFR Part 264 Subpart J?
- Waste pile
- Surface impoundment (Correct answer)
- Container storage area
- Land treatment unit
Correct answer: Surface impoundment
Surface impoundments under 40 CFR 264 Subpart K must have double liners, a leachate collection system, and groundwater monitoring.
Question 3: What is the regulatory status of hazardous waste that has been delisted by EPA?
- It remains hazardous but requires reduced monitoring
- It is no longer subject to RCRA Subtitle C regulation for the specific waste from the specific facility (Correct answer)
- It is transferred to state authority only
- It is exempt from LDRs but still regulated under TSDF standards
Correct answer: It is no longer subject to RCRA Subtitle C regulation for the specific waste from the specific facility
A delisted waste is no longer considered hazardous under RCRA for that specific waste stream from that specific facility, removing it from Subtitle C regulation.
Question 4: Under TSCA Section 6, EPA required phased elimination of polychlorinated biphenyls (PCBs). What is the general disposal standard for PCB concentrations ≥500 ppm?
- Incineration in an approved incinerator or high-efficiency boiler (Correct answer)
- Landfill disposal in a permitted chemical waste landfill
- Treatment in a wastewater treatment facility
- Export for disposal in a licensed foreign facility
Correct answer: Incineration in an approved incinerator or high-efficiency boiler
PCBs at concentrations ≥500 ppm must be incinerated in an EPA-approved incinerator or approved high-efficiency boiler under 40 CFR 761.
Question 5: A TSDF's closure plan must address all of the following EXCEPT:
- Decontamination of equipment and structures
- Disposition of all hazardous waste on-site
- Financial assurance for post-closure care
- Annual financial audits submitted to EPA (Correct answer)
Correct answer: Annual financial audits submitted to EPA
Closure plans must address waste disposition, decontamination, and financial assurance, but do not require annual financial audits to EPA during closure.
Question 6: Which RCRA concept determines whether contaminated environmental media (soil, groundwater) at a TSDF is subject to RCRA Subtitle C hazardous waste regulation?
- Derived-from rule
- Contained-in policy (Correct answer)
- Mixture rule
- Land disposal restriction variance
Correct answer: Contained-in policy
The contained-in policy states that environmental media is not itself a listed waste but is subject to RCRA if it 'contains' a listed hazardous waste.
Question 7: Under RCRA, what post-closure care period is typically required for hazardous waste landfills after final closure?
- 5 years
- 10 years
- 30 years (Correct answer)
- 100 years
Correct answer: 30 years
RCRA requires a minimum 30-year post-closure care period for hazardous waste landfills, during which groundwater monitoring, maintenance, and reporting must continue.
CHMM Disposition of Hazardous Materials 4
A facility plans to thermally treat hazardous waste in a boiler to recover energy.
Under what conditions is this considered legitimate recycling rather than sham recycling?