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U
S
A
EPA
Regulatory Bulletin |
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1) Hazardous wastes containing free liquids cannot be placed in
landfills. The EPA ruled that the Paint Filter Tests(PFT) will be
used to determine if a material contains free liquids and must pass
the PFT when properly wrung out or centrifuged.
2) Biodegradable sorbents are forbidden in hazardous waste landfills. 3) Non biodegrable sorbents must be used in lab packs going to landfills. |
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The following is a summary further explaining these new requirements.
FREE LIQUIDS PROHIBITION The resource Conservation and Recovery Act(RCRA) as amended by the Hazardous and Solid Waste Amendments(HSWA) of 1984 specifically requires the EPA to issue rules that "minimize" the presence of free liquids in containerized hazardous waste to be disposed of in landfills. Free liquids are felt to contribute to landfill liquid leachate that must be collected and removed. Free liquid determination can be made through the user of EPA's Paint Filter Test(PFT). This is a very simple test to run. Waste is placed in a specific paint filter and if one drop is released in 5 minutes the material contains free liquid. A graphic demonstration this test can be found in the "Sorbent Dosposal Option" brochure. AAP Sorbents can easily pass the EPA's Paint Filter Test due to the polymerization process that permanently contains a wide range of the hydrocarbons. The actual regulatory language from 40CFR & 264 and 265 section 314 (b),(o), and (d) reads: |
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"(b) the placement of bulk or noncontainerized liquid hazardous
waste or hazardous waste containing liquids (whether or not sorbents
have been added) in any landfill is prohibited.
(c) To demostrate the absence or prsence of free liquids in either containerized or as described in Test Methods for Evaluating Solid Wastes Physical/Chemical Methods. [EPA Publication No.SW-848]. (d) Containers holding free liquids must not be placed in a landfill unless: (1) All free standing liquid has been removed. |
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PROHIBITION OF BIODEGRADABLE SORBENTS IN LANDFILLS
The HSAW of 1984 also required the EPA to issue regulations that "prohibit the disposal in landfills of liquids that have been absorbed in materials that biodegrade". It is felt that landfilled biodegradable sorbents would release any residual liquids into the landfill when the sorbent breaks down. Examples of non biodegradable sorbents are given in the final rule along with two ASTM test methods that to determine if an EPA non listed sorbent is biodegradable. AAP Sorbents are non-biodegradable because the fall into the ETI's (high molecular weight synthetic polymer) category. |
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The following is EPA's actual regulatory language on non-biodegradable
sorbent prohibitions and criteria.
40-CFR & 264 and 265, sections 314(e) Sorbents used to treat free liquids to be disposed of in landfills must be non-biodegradable; Non-biodegradable sorbents are: materials listed or described in paragraph |(e)(1) of this section; materials that pass one of the tests in paragraph(e)(2) of this section;... (1) Non-biodegradable sorbents. (1) Inorganic minerals, other inorganic materials, and elemental carbon|(e.g. aluminosilcates, clays, smectites, Fuller's earth bentonite, calcium bentonite, montmorillonite, calcined montmorillonite, kaolinite, micas(illite), vermiculites, zeolite calcium carbonate (organic free limestone); oxides/hydroxides alumina, lime, silica (sand), diatomaceous earth; perlite(volcanic glass), expanded volcanic rock; volcanic ash; cement kiln dust; fly ash; rice hull ash; activated charcoal/activated carbon);; or |
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Table #1: Bilge sock test summary of products submitted in response to the BBAC-Town of
Dartmouth request for bid. Only products #7G, #7H and #5 passed all tests and criteria in the
Request for Bid. (NT= Not Tested)
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|---|---|---|---|---|---|---|---|
| initial | 3 day | ||||||
| PRODUCT# | Company-Product | Product Type | Oil Bin | absorption | 6 cup absorb | hole test | wring test |
| # 1-long | (withheld) |
"biological removal", probably emulsifier |
1 | low | fail | pass | NT |
| # 1-short | (withheld) |
"biological removal", probably emulsifier |
2 | low | fail | pass | NT |
| # 7-D-A | (withheld) |
polymer-cellulose blend, recommended by App. |
3 | High | Pass | Pass | Fail |
| # 7-D-B | (withheld) |
polypropylene in, polypropylene sock |
4 | High | Pass | Pass | Fail |
| # 7-D-C | (withheld) | Cellulose in polypropylene | 5 | High | Pass | Pass | Fail |
| # 7-D-D | (withheld) |
polypropylene in, polypropylene sock |
6 | High | Pass | Pass | Fail |
| # 7-D-E | (withheld) |
polypropylene in, polypropylene sock |
7 | Medium | Pass | Pass | Fail |
| # 7-D-F | (withheld) | polymer-cellulose Blend | 8 | Medium | Pass | Pass | Fail |
| # 7-D-G (pass) | (withheld) | Polymer absorbent | 9 | Medium | Pass | Pass | Fail |
| # 7-D-H (pass) | (withheld) | Polymer absorbent | 10 | Medium | Pass | Pass | Fail |
| # 5 (pass) | (withheld) | Polymer absorbent | 11 | High | Pass | Pass | Fail |
| # 3 | (withheld) | Not specified, Polymer | 12 | High | Pass | Pass | Fail |
| # 6 | (withheld) |
Polypropylene fibers in sock |
13 | Low | Fail | Pass | NT |
| # 9 | (withheld) | Polypropylene? Sock | 18 | Low | Fail | Pass | NT |
| # 8B | (withheld) | Propietary foam | 19 | Low | Pass | Fail | Pass |
| # 8A | (withheld) | Propietary foam | 17 | Low | Fail | Fail | NT |
| # 2 | (withheld) |
Polypropylene fibers in sock |
20 | Medium | Pass | Pass | Fail |
| # 4-No product submitted | (withheld) |
Polypropylene fibers in sock |
NA | ||||
| # 10-No product submitted | (withheld) |
Meltblown Polypropylene in nylon sock |
NA | ||||
| # 11-No product submitted | (withheld) | Meltblown Polypropylene | NA | ||||
| # 9B - square pad rejected | (withheld)-pad | square pad equivalent to sock in #9 | rejected | ||||
| Current as of Environmental Protection Agency test date | |||||||