DSHW-2024-006630

Generator Treatment
What is treatment?
R315-260-10(159):
"Treatment" is defined in Subsection 19-6-102(22) and includes
any method, technique, or process, including neutralization,
designed to change the physical, chemical, or biological
character or composition of any hazardous waste so as
to neutralize such waste, or so as to recover energy or material
resources from the waste, or so as to render such waste non-
hazardous, or less hazardous; safer to transport, store, or
dispose of; or amenable for recovery, amenable for storage, or
reduced in volume
Treatment Examples
*Compaction in a container
*Shredding waste or debris
*Evaporation
*Volatilization
*Stabilization
*Stripping
*Decanting
Permitting Exemptions or
Exclusions
R315-270-1(c)(2)
*Wastewater treatment units (WWTUs)
*Elementary neutralization units (ENUs)
*Totally enclosed treatment facilities (TETFs)
Allowable Treatment
R315-270-1(c)(2) also exempts generators from
permitting requirements who:
Add absorbents to wastes (to eliminate free liquids)
*Must occur at the time the waste is first placed in the
container –no adding absorbents later
*Can transfer from one container to another to add
absorbent and still get exemption
*Make sure absorbents, waste, and containers are all
compatible
Allowable Treatment or
Containment without a Permit
Immediate Response
*Examples: Using absorbents to contain a spill, neutralizing a
spilled material, building a containment dike
*Applies to:
*A discharge of HW
*An imminent and substantial threat of a discharge of HW
*A discharge of material which, when discharged, becomes a HW
*An immediate threat to human health, public safety, property, or the
environment from the known or suspected presence of military
munitions, other explosive material, or an explosive device*
*Only applies to immediate response, i.e., waste generated from
the cleanup that is them stored onsite is still subject to regs
Can I treat my waste?
*Yes and No, or it Depends –some forms of
treatment are allowed without a permit while others
will require a permit
Allowable Treatment
Treatment in 90/180/270-day accumulation units
*Can treat in tanks, containers, drip pads, and
containment buildings
*Accumulation units are still subject to the
requirements of R315-262-16 and R315-262-17
*Only applied to waste generated onsite
*If treating to meet LDRs, must follow written WAP
Allowable Treatment
YES
*Compacting solid
materials (i.e., rags)
*Filtering out solids from
liquids
*Stabilization
NO
*Burning or heating of
waste (no thermal
treatment)
*Allowing waste to
evaporate (solvents, etc.)
*Land treatment
Questions?
Email questions to [e-mail]