CIVE 4310 NURAZIM IBRAHIM, PHD.

HAZARDOUS WASTE CIVIL ENGINEERING PROGRAMME

FACULTY OF ENGINEERING &
SCIENCE TECHNOLOGY, IUKL
Pollution Prevention &
Waste Minimization
Ignorance of the law excuse no man

John Selden
Pollution Prevention
What is the Pollution Prevention (P2)?
1. Often called P2, means source
reduction, or preventing pollution
at its source, before it is
generated.
2. Includes any practice that
reduces the quantity and/or
toxicity of pollutants entering a
waste stream prior to recycling,
treatment, or disposal (e.g.
equipment or technology
modifications, reformulation or
redesign of products, substitution
of less toxic raw materials, worker
training and etc)
Pollution Prevention Law

In 1990, Congress passed the Pollution Prevention Act which states:

"the Environmental Protection Agency must establish a source
reduction program which collects and disseminates information,
provides financial assistance to States, and implements the other
activities...."

EPA is responsible for implementing the law passed by Congress

called the Pollution Prevention Act of 1990.
National Pollution Prevention Policy

The Pollution Prevention Act establishes a national policy that

EPA implements:

• Pollution should be prevented or reduced at the source whenever

feasible;
• Pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible;
• Pollution that cannot be prevented or recycled should be treated in
an environmentally safe manner whenever feasible; and
• Disposal or other release into the environment should be
employed only as a last resort and should be conducted in an
environmentally safe manner.
National Pollution Prevention Policy
2010-2014 Pollution Prevention Program Strategic Plan
This plan identifies a number of opportunities to reduce: the
emission of greenhouse gases; the use of hazardous materials; and
the use of natural resources, while contributing to a more
sustainable economy.
Evaluation of EPA Efforts to Integrate Pollution Prevention
Policy throughout EPA and at Other Federal Agencies
This evaluation, from October 2008, describes key areas that could
benefit from additional attention to P2 integration and makes
connections between P2 integration activities and sustainability
policy developments.
Pollution Prevention Policy Statement - New Directions for
Environmental Protection, Carol M. Browner - then EPA
Administrator. June 15, 1993.
Other Pollution Prevention Law

Pollution Prevention Mandates in Federal Statutes

1. Pollution Prevention Act

§ 13103 - EPA mandated to develop and implement a strategy to promote source
reduction.

§ 13104 - EPA as administrator is given the authority to provide grants to the

States to promote source reduction by businesses.

§ 13105 - EPA mandated to establish a database that contains information on

source reduction.

§ 13106 - Owners and operators of businesses that are required to file a toxic
chemical release form must include a toxic reduction and recycling report.
Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

2. Clean Air Act (CAA)

§ 7402 - Encourages cooperation amongst the federal departments, states, and

local governments for prevention and control of air pollution.

§ 7403 - EPA mandated to establish a national research and development

program for prevention and air pollution control.

Also, EPA must facilitate coordination amongst air pollution prevention and control
agencies.

§ 7405 - EPA can make grants to air pollution prevention and control agencies.
Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

2. Clean Air Act (CAA)

§ 7412 - Facilities that reduce their emission of toxics into the air by 90-95% can
qualify for permit waivers.

§ 7414 - 7418 - EPA may establish record keeping, inspections, and monitoring
for all facilities that emit pollutants.

§ Subchapter I, Part C Sec 7470-7479 - Prevention of significant deterioration of

air quality-establishment of a plan that includes emissions limitations to protect
public welfare and the environment.

§ Subchapter II 12. General emissions standards.

Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

3. Resource Conservation and Recovery Act (RCRA)

§ 6907 - EPA must establish waste management guidelines.

§ 6908a - EPA may assist Indian tribes in waste management.

§ 6921 - 6925

§ 6921: Hazardous Waste requirements established for owners and operators of

facilities that produce hazardous wastes.

Under § 6922 - Generators must certify in shipping manifests that they have a
plan to reduce waste. They must also submit a biennial report indicating their
efforts to reduce volume and toxicity of wastes
Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

3. Resource Conservation and Recovery Act (RCRA)

§ 6925 - Permit required for treatment and storage of hazardous wastes.

§ 6927 - EPA can make facilities describe their waste reduction program and
inspect them to determine whether a program is actually in place.

§ 6931 - Grants appropriated to the States for assistance in development of

Hazardous Waste Programs.

§ 6981 - EPA shall render financial assistance to federal, state, and local agencies
that are researching, investigating, or providing in areas of waste management
and minimization.
Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

4. Clean Water Act (CWA)

§ 1251 - National goal is to eliminate the discharge of pollutants into navigable
waters.

§ 1252 - EPA mandated in cooperation with federal state, and local agencies and
industries to develop programs for preventing, reducing, or eliminating the
pollution of the navigable waters and ground waters and improving the sanitary
condition of surface and underground waters.

§ 1256 - Appropriation of funds to state and local agencies for pollution control.

§ 1342 - EPA can put additional restrictions on permits (not included in the act).

§ 1381 - EPA given authority to make grants to states for pollution control
revolving fund for implementation of management and conservation plans.
Other Pollution Prevention Law

Pollution Prevention Mandates in Federal Statutes

5. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)

§ 136 - All pesticides and pesticide establishments must be registered. Non-

registered pesticides may not be sold or distributed in the U.S.
Other Pollution Prevention Law
Pollution Prevention Mandates in Federal Statutes

6. National Environmental Policy Act (NEPA)

§ 4331 - Congress recognizes "the profound impact of man's activity on the
interrelations of all components of the natural environment."

§ 4363 - EPA shall establish a program for long -term research for all activities
listed under NEPA.

§ 4363a - EPA mandated to conduct demonstrations of energy-related pollution

control technologies.

§ 4368a - Utilization of talents of older Americans in projects of pollution

prevention, abatement, and control through technical assistance to environmental
agencies.

§ 4368b - Provide technical assistance to Indian Tribes for environmental

assistance on Indian lands.
Waste Minimization
INTRODUCTION
Congress outlined four major programs in RCRA, including:

• Solid Waste (Subtitle D): Focuses on traditional nonhazardous solid waste,

such as municipal garbage and industrial waste that is not classified as
hazardous waste;
• Hazardous Waste (Subtitle C): Requires EPA to develop and manage a
nationwide program that identifies wastes that are hazardous and set
standards for safely managing this waste from the moment it is
generated, through storage, transportation, recycling, treatment, and
ultimate disposal.
• Medical Waste (Subtitle J): Lays out a two year pilot program to track the
generation and management path of infectious waste;
• Underground Storage Tanks (UST--Subtitle I): Requires EPA to establish
standards for the design and operation of USTs to prevent leaks into the
ground.
What is the Waste Minimization?
1. Waste Minimization refers to the use of source reduction and/or
environmentally sound recycling methods prior to energy
recovery, treatment, or disposal of wastes.
2. Not include waste treatment, that is, any process designed to
change the physical, chemical, or biological composition of waste
streams. (e.g. compacting, neutralizing, incineration and etc)
3. EPA's preferred hierarchical approach to materials
management includes source reduction, recycling, energy
recovery, treatment, and finally, disposal.
Who Should Practice Waste Minimization?

Hazardous waste generators

• RCRA, as amended by the Hazardous and Solid Waste
Amendments of 1984, specifically requires Large Quantity
Generators of hazardous waste to certify when they sign their
manifests, and they have a program in place to reduce the volume
and toxicity of waste generated to the extent economically
practical.
• Small Quantity Generators are required to certify when they sign
their manifests, that they have made a good faith effort to reduce
the volume and toxicity of the hazardous wastes they generate.
• Additionally, all large quantity hazardous waste generators must
report biennially on waste minimization activities.
Who Should Practice Waste Minimization?

5 types of Hazardous waste generators

1.
2. 3.
The primary
The Transporter Waste Storage
generator

5. 4.
Disposal Facilities Treatment
Who Should Practice Waste Minimization?

All the producers and the recipients of waste need to follow certain
standard operative procedures (SOP) to manage the waste in
accordance with the existing law and waste regulations. Basic
data/recordkeeping, reporting, manifesting, protocols of SOP, and
contingency planning in cases of emergency are very essential for
waste tracking purpose.
Waste Minimization Approach
• Recent attention has been paid to appropriate mechanisms to
encourage or oblige waste generators to focus on waste
avoidance, waste minimization, recovery, recycling or re-use
(moving waste management up the hierarchy)
Hierarchial Approach

Source Reduction

Recycling

Recovery

Treatment

Disposal
 Source Reduction
Commonly known as pollution prevention (P2), reduces or
eliminates the generation of waste at the source and
refers to any practice that reduces the use of hazardous
materials in production processes.

Common examples of source reduction include:

• Early retirement of equipment such as mercury-containing devices

like switches and thermostats;
• Reformulating or redesigning products, such as creating new PVC
compounds without using lead;
• Using less toxic feedstocks, such as switching to the use of lead-
free solder in manufacturing;
• Improving work practices, such as reorganizing paint batches in
order to reduce cleaning operations.
 Recycling

Reclaiming value from production by-products, can

often be used when P2 is not economically practical.
Recycling includes the reuse or recovery of in-process
materials or materials generated as by-products that can
be processed further on-site or sent offsite to reclaim
value. Recycling is a broad term that encompasses the
reuse of materials in original or changed forms rather than
discarding them as wastes. Recycling can also be thought of
as the collection and reprocessing of a resource so it can be
used again, though not necessarily for its original purpose.
 Recycling

Common examples of recycling include:

• Direct use/reuse of a waste in a process to make a product, such as

reusing a purge product used to clean paint lines rather than
disposing of it by incineration.
• Processing the waste to recover or regenerate a usable product,
such as collecting vapor from dry-cleaning operations, turning it
back into liquid, and reusing the liquid to clean more clothes.
• Using/reusing waste as a substitute for a commercial product.
When mercury is recycled from old equipment like switches, it can
be used in new products that still require mercury, such as
fluorescent bulbs. Recycling of mercury has been so successful that
there is now enough recycled mercury in the U.S. that
manufacturers do not need to use new mercury from mines
 Recycling

A material is "recovered" if it is processed to recover a usable

product, or if it is regenerated. This is known as materials recovery.
In energy recovery, waste is converted into usable fuel. Read about
Energy Recovery.
 Energy Recovery
Gasification Converts Wastes Into Useable Fuel

Schematic diagram of he overall process for the gasification using thermal

plasma
 Energy Recovery

Gasification Converts Wastes Into Useable Fuel

1. Gasification converts carbon-containing materials, under high

temperature and pressure, into synthesis gas.
2. Synthesis gas or syngas is generally composed of hydrogen and
carbon monoxide but can be manufactured to contain methane and
other higher molecular weight compounds.
3. Syngas can be used as a fuel to generate electricity or as a basic
chemical building block for use in the petrochemical and refining
industries.
4. Syngas generally has a heating value that is approximately two-thirds
that of natural gas and, when burned as fuel, produces emissions that
are similar to natural gas.
5. In the petroleum refining industry alone, about seven to ten million
tons of hazardous byproducts containing carbon, currently managed
under RCRA, could be converted into useable fuel or chemicals using
gasification methods.
Government and Public Involvement

• The national and regional governments need to adopt waste

management guidelines and regulations. Allocation of adequate
resources is also desired.
• The public and the community need to be involved in the waste
management hierarchy.
• Public education is important.
• The UN agencies; (WHO, UNIDO, and UNEP) involvement in the
adoption of National Waste Management Program and control of
transboundary movement of wastes should be appreciated and
acknowledged.
 Treatment
Different technical options and alternative methods can be
employed for the treatment. The end result needs to focus on
making the waste non-harmful or less hazardous, reduce its
volume and texture, separate for re-use, and isolate it for final
disposal.
Treatment methods include:

A. Physical methods: drying, screening, grinding, evaporation,

sedimentation, filtration, fixation, etc.
B. Chemical methods: Oxidation, reduction, neutralization, hydrolysis,

etc.
C. Biological methods: composting, aerobic and anaerobic
decomposition, activated sludge, enzyme treatment, etc.
D. Thermal methods: incineration, boiling, autoclaving, UV treatment,
microwave use, etc.
 Disposal
The hazardous waste, after treatment, can be ultimately
disposed using the following methods:

A. Land farming: the treated waste can be used as a fertilizer or soil

conditioner with the approval of concerned
B. Deep well injection: a special kind of drilled well is prepared for
such purposes. Brine (40% salt solution) is usually disposed in this
manner. Precautions for water pollution need to be a concern.
C. Surface impediment: encapsulation, fixation, or containment of
the waste. This method involves arresting or demobilizing the
movement or migration of the waste by containing it in a hard
core: clay soil, thermoplastics polymers, non-corrosive metallic
containers (carbon-steel tanks), cement, lime, fire glass, rocks.
D. Ocean dumping: was mostly practiced from 1945 to the 1970s.
Despite the existing public protest, this method continuous to be
an alternative for the waste generators.
Benefits of Waste Minimization
Source reduction and/or environmentally sound recycling, reuse,
and reclamation practices have helped many organizations
reduce:

1. The quantity and toxicity of hazardous and solid waste

generation
2. Raw material and product losses
3. Raw material purchase costs
4. Waste management recordkeeping and paperwork burden
5. Waste management costs
6. Workplace accidents and worker exposure
7. Compliance violations
8. Environmental liability
Benefits of Waste Minimization

At the same time, waste minimization can improve:

1. Production efficiency
2. Profits
3. Good neighbour image
4. Product quality
5. Environmental performance
Is Waste Minimization Required by Law?

In 1984 : Amendments to RCRA established the following

national policy, making waste minimization the
nation's preferred hazardous waste management
practice (RCRA Sec.1003[b], 1984.)
In 1990 : The Pollution Prevention Act expanded the nation's
waste prevention policy beyond a RCRA-only
framework, to minimizing or eliminating toxic
releases to all environmental media and natural
resources (PPA, Section 6602[b].)
Difference between Waste Minimization and
Pollution Prevention

Pollution Prevention
Waste Minimization
The term found in the
The term found in the Resource
Pollution Prevention Act of
Conservation and Recovery Act
1990 that refers to source
(RCRA) refers to source
reduction of all toxic wastes,
reduction and environmentally
including those released to
sound recycling of RCRA
air, water and land
hazardous waste.
resources.
Why Waste Minimization is Important?

1. Saves money through avoided disposal and raw materials

purchase costs;
2. Reduces regulatory burdens and compliance costs;
3. Builds better community relations;
4. Minimizes short and long term liability;
5. Creates safer working conditions for employees;
6. Protects human health and the environment;
7. Demonstrates environmental leadership;
8. Improves competitiveness through greater efficiencies and
deceased overhead costs.
Tracking System
Introduction

EPA’s hazardous waste manifest system

Designed to track hazardous waste from the time it leaves the

generator facility where it was produced, until it reaches the off-
site waste management facility that will store, treat or dispose of
the hazardous waste.
Introduction

The “generator” is the first element of the RCRA cradle-to-grave

concept, which includes generators, transporters, treatment plants,
storage facilities, and disposal sites.

The RCRA regulations define a generator as: … any person, by

site, whose act or process produces hazardous waste identified or
listed in Part 261 of this chapter or whose act first causes a
hazardous waste to become subject to regulation (40 CFR 260.10).
or
The generator is the creator of a hazardous waste who must
analyze all solid wastes produced or use knowledge of the wastes to
determine if they meet the RCRA Subtitle C definitions or listings of
hazardous wastes.
Introduction

Three classification of Generators

1) Large quantity generators (LQG) - generator of more than 1000

kg of hazardous waste, per month, or more than 1 kg of acutely*
hazardous waste, per month.
2) Small quantity generators (SQGs) - generating between 100 kg to
1000 kg of hazardous wastes or less than 1 kg of acutely*
hazardous waste.
3) Conditionally Exempt Small Quantity Generator (CESQG) - defined
as producing less than 100 kg of hazardous waste and less than 1
kg of acutely hazardous waste per month.
Note
*Acutely hazardous wastes are wastes that the EPA has determined to be so dangerous that small amounts are
regulated in a manner similar to larger amounts of other hazardous wastes. They are, specifically, F020-F023 and
F026-F028 identified in 40 CFR 261.31 and the “p” wastes listed in 40 CFR 261.33.
Introduction

Regulatory Requirements

LQGs and SQGs are subjected to regulations contained in 40 CFR

262. These regulations require them to:

1) Identify and quantify waste generated

2) Obtained an EPA identification number (EPA ID Number)
3) Comply with accumulation and storage requirements (including
requirements for training, contingency planning, and emergency
arrangements).
4) Properly prepare wastes prior to transport
5) Track the shipments and receipt of hazardous waste by use of the
manifest system
6) Perform record keeping and reporting as required
EPA ID Number
• EPA and the primacy states monitor and track generator activity by
the assignment of a unique identification number to each
generator (and SQG), transporter, and operator of a treatment,
storage and disposal (TSD) facility.

• Generators, SQGs, and transporters obtain ID numbers by

“notifying” the EPA of hazardous waste activity, using EPA Form
8700-12.

• CESQG are not required to obtain ID numbers.

• The EPA ID number is not a certification nor an endorsement of the

assignee’s hazardous waste activity. It is for identification purposes
only (see also: U.S. EPA 1998, p. III-48).
Pre-transport Regulations

• Specify actions which the generator must take to ensure that

hazardous wastes are packaged, labelled, marked, and (if
appropriate) placarded prior to offering the wastes for
transportation.

• The pretransport requirements (40 CFR 262, Subpart C) refer to

elements of the Department of Transportation (DOT) regulations
for transporting hazardous materials (49 CFR 172, 173, 178,
and 179)
Pre-transport Regulations

• The DOT regulations require:

• Proper packaging to prevent leakage of hazardous waste,
during both normal transport conditions and potentially
dangerous situations, e.g., a drum of waste dropped from a
truck bed or loading dock
• Labeling, marking, and placarding of the packaged waste to
identify the characteristics and dangers associated with
transporting the waste

• The researcher or practitioner contemplating or having

responsibilities for pretransport preparation of hazardous waste
shipments must complete the training required by 49 CFR
Subpart H.
 Pre-transport Regulations
• The general thrust of the requirements can
be ascertained by examining the Hazardous
Materials Table column headings (Figure
5.1) and the “Eight-Step Procedure”
prepared by the DOT transportation Safety
Institute.
• The marking requirements include the
requirement for individual containers to
display a “Hazardous Waste”
• The marking must include a proper DOT
“shipping name” that uses the standardized
language of 49 CFR 172.101 and 172.102.
• The labels on individual containers must
accurately display the correct hazard class
as prescribed by Subpart E of Part 172.
Accumulation of Waste

The regulatory material contained in 40 CFR 262.34, titled

accumulation time is a “sleeper.” The material greatly
exceeds the apparent subject of accumulation time. The
EPA chose to structure the content in the form — generator
may accumulate for 90 days without a permit, provided
he/she complies with all that follows, including many
references to other regulatory material . It is a key
portion of the generator regulations and requires much of
the practitioner.
Accumulation of Waste

• A generator may accumulate hazardous waste on-

site for 90 days or less, provided the following
accumulation-related requirements are met:

• Proper Management - properly accumulated in

containers, tanks, drip pads, or containment
buildings and must be marked with the date on
which accumulation began. The generator must
ensure and document shipment of the waste off-site
within the allowable 90-day period.
• Emergency Plan — A written contingency plan and
procedures for managing spills or releases must be
developed
• Personnel Training — Facility personnel must be
trained in the proper handling of hazardous waste
 Uniform Hazardous Waste Manifest
• Key component for tracking system
• The Uniform Hazardous Waste Manifest
(Form 8700-22, Figure 5.6) is the
instrument that enables the tracking of,
and accounting for, hazardous wastes
in the cradle-to-grave system.
• Through the use of the manifest,
generators, transporters, TSDFs
(treatment, storage, and disposal
facility), and/or regulators can track
the movement of hazardous waste
from the point of generation to the
point of ultimate treatment, storage, or
Sample uniform hazardous waste manifest
disposal form.
 Uniform Hazardous Waste Manifest
• Manifest form has 2 section
1) Part A: filed out by generator
2) Part B: filled out by transporter or
TSD facility
• Six copies are distributed as follows:
1) Sent to state agency where disposal
occurs
2) Sent to state agency where
generation occurs
3) Sent to generator by TSD facility
4) Retained by TSD facility
5) Retained by transporter No. 1
6) Retained by transporter No. 2 (if
Sample uniform hazardous waste manifest
required) form.
Uniform Hazardous Waste Manifest

• RCRA manifests document the:

• Name, address, and EPA identification number of the

generator, the transporter, and the facility where the waste is
to be treated, stored, or disposed.
• Telephone number at which emergency response information
may be accessed at all times (24 hours per day) while the
shipment is enroute (see: 49 CFR 172, Subparts C and G)
• DOT description, including proper shipping name, of the waste
being transported
• Quantities of waste being transported and the type of container
Uniform Hazardous Waste Manifest

• The Uniform Hazardous Waste Manifest serves the purpose of a

“shipping paper” for hazardous waste shipments

• generators or generator representatives should become fully

familiar with the 40 CFR 262 Subpart B and Appendix and 49 CFR
172 Subparts C and G prior to preparation of hazardous waste
manifests.

• CESQGs are not subject to the EPA manifesting requirements;

however, DOT requirements may apply to small hazardous waste
shipments.
Uniform Hazardous Waste Manifest

• The hazardous waste shipper, in signing the manifest form,

certifies that:

• The shipment has been accurately described and is in proper

condition for transport.
• The generator has a waste minimization program in place at its
facility to reduce the volume and toxicity of hazardous waste to
the degree economically practicable, as determined by the
generator.
• The treatment, storage, or disposal method chosen by the
generator is the most practicable method currently available
that minimizes the risk to human health and the environment.
 Biennial Reporting Requirements

• Generators are subject to extensive record keeping and

reporting requirements as set forth in 40 CFR 262, Subpart D.

• Generators who transfer hazardous waste offsite must submit a

biennial report to the EPA Regional Administrator or state
agency on EPA Forms 8700-13A and B by March 1 of each
even-numbered year.

• The EPA does not require SQGs to submit biennial reports;

however, some state agencies require annual or biennial
reporting.
 Biennial Reporting Requirements

• The federal biennial report covers generator activities during

the previous year and includes

• EPA ID number, name, and address of the generator

• EPA ID number and name of each transporter used during
the year
• EPA ID number, name, and address of each off-site TSDF
and recycler to which waste was sent during the year
• Descriptions and quantities of each hazardous waste
generated
Exports and Imports of Hazardous Wastes

• Export of hazardous waste from the U.S. to another country is

prohibited unless:

• Notification of intent to export has been provided to EPA at

least 60 days in advance of shipment.
• The exporter obtains written consent from the receiving
country prior to shipment. This written consent must be
attached to the manifest accompanying the shipment.
• The exporter has received a copy of the EPA
“Acknowledgement of Consent.”
• The hazardous waste shipment conforms to the terms of the
receiving country’s consent (40 CFR 262.52).
 Exports and Imports of Hazardous Wastes

• Any person who imports hazardous waste from another country

into the U.S. must comply with the requirements of 40 CFR
262, i.e., the importer becomes the generator, for RCRA
regulatory purposes, including responsibility for preparation of
the manifest.

• Special instructions for importers completing the manifest for

imported wastes are contained in Subpart F of 40 CFR 262
 Generator Responsibility for Restricted
Waste Management

• The land disposal restrictions (LDRs) and the implementing

regulations are lengthy, detailed, and complex.

• In the interest of a concise overview, much of the following

material on generator responsibilities is paraphrased from the
1998 RCRA Orientation Manual (EPA 530/R/98/004).

• The reader having or preparing for responsibilities for

managing hazardous wastes that may be land-disposed should
carefully study 40 CFR 268.
Generator Requirements
• The generator must determine whether or not the waste generated
is hazardous (either listed, characteristic, or both) by conducting
waste analysis or by using knowledge of the waste.

• To prevent illegal dilution, the determination is made at the point

of generation.

• If the generator determines that the waste is hazardous, the

generator must then determine whether or not the EPA has
established a treatment standard for the particular waste code.
Generator Requirements
• If so, the waste is restricted and the generator must manage it in
compliance with all of the LDR requirements, whether on-site or
off-site, and may not dispose of it on or beneath the land until it
meets all applicable treatment standards.

• The treatment standards are based on the performance of “Best

Demonstrated Available Technology” (BDAT).

• The treatment standards are found in 40 CFR 268.40 and are

expressed as a concentration or as a treatment technology
Contents of Environmental Quality (Scheduled Wastes) Regulations
 If you can't fly, then RUN.
If you can't run, then WALK.
If you can't walk, then CRAWL.
But whatever you do,
YOU HAVE TO KEEP MOVING.

Martin Luther King, Jr. – Civil Rights Activist and Pastor