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WorkWaste LLC


WorkWaste LLC LDR Training/Guidance – PowerPoint PPT presentation

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Title: WorkWaste LLC

WorkWaste LLC
  • LDR Training/Guidance

Land Disposal Restrictions
  • One time notice to each treatment or disposal
    facility receiving the waste
  • With initial shipment
  • With the initial shipment of each changed waste
  • Regardless of whether such facility has received
    such waste in the past
  • Records must be maintained on-site

LDR Applicability
  • After a waste is generated, the generator must
    decide which treatment standards apply
  • As generated wastes

Waste Characteristics
  • Determine if waste is hazardous at the Point of
  • Some wastes have concentration-based standards
  • Some wastes must be treated with specified
  • Some wastes must be treated for underlying
    hazardous constituents

LDR Treatment Standards
  • What are the Treatment Standards?
  • 40 CFR 268.40 Treatment Standard Table

Goal for Treatment Standard
  • EPA has developed a treatment standard for all
    hazardous wastes
  • The objective of LDR is to develop concentration
    levels for wastes so that they may be safely land

LDR Treatment Standards
  • Column 1 Waste Code
  • This column helps you locate the EPA hazardous
    waste codes applicable to your wastes
  • Locate ALL applicable hazardous waste codes

LDR Treatment Standards
  • Column 2 - Waste Description and
    Treatment/Regulatory Subcategory
  • For listed hazardous wastes, the waste
    description defines the listed waste.
  • For characteristic waste, the waste description
    specifies the characteristic (ignitable,
    corrosive, or reactive) or the toxicity

LDR Treatment Standards
  • Column 2 - Waste Description and
    Treatment/Regulatory Subcategory
  • In some cases, subcategories for waste
    descriptions are listed because a range of wastes
    or constituents may require different levels or
    types of treatment.
  • If subcategories are included take special care
    to ensure that you are complying with the
    appropriate subcategory treatment standards.

LDR Treatment Standards
  • Column 3 Regulated Hazardous Constituents
  • Specific regulated hazardous constituents that
    must be treated for each waste code
  • Determine whether waste meets the treatment
    standard for all regulated constituents that
    apply to your waste code
  • Using waste determination (analysis or knowledge)

LDR Treatment Standards
  • Columns 4 and 5 Wastewaters and Nonwastewaters
  • Treatment standards differ depending on whether
    the waste is a wastewater or a nonwastewater
  • Wastewaters are usually aqueous
  • Wastewater - lt1 by weight total organic carbon
    (TOC) and lt1 by weight total suspended solids
  • Nonwastewaters - gt or 1 TOC or gt or 1 TSS

Underlying Hazardous Constituents (40 CFR 268.48)
  • UHCs are constituents included in the Universal
    Treatment Standards which can be expected to be
    present at the time the hazardous waste is
    generated, at a concentration above the
    constituent-specific UTS
  • UHCs do not include fluoride, selenium, sulfides,
    vanadium or zinc
  • Waste must be treated to below UTS for each UHC
    prior to land disposal

  • Informs off-site facilities of the LDR
  • Notifications/certifications are only required to
    be sent with the initial shipment
  • Recordkeeping period is 3 years

LDR Notification
  • Generator Requirements
  • Waste Codes
  • Manifest of First Shipment
  • Indication that waste subject to LDR
  • WW or NWW Category
  • Waste Analysis Data
  • Certification Statement (if claiming waste meets
    treatment standard)

LDR Notification
  • Generators Must also include
  • Constituents of concern for F001-F005 and F039
  • UHCs if applicable
  • Revised Notification required if information

Basic LDR Principles
  • Be sure waste is hazardous
  • Determine waste code(s)
  • Wastewater or non-wastewater?
  • Look up treatment standards
  • Wastes that meet standards can be land disposed
  • Fill out required paperwork

Alternative Standards for Soil
  • RCRA prohibits the disposal of hazardous soil
    until it meets treatment standards
  • Soil-specific standards (40 CFR 268.49)
  • Require reduction of 90 of constituent
    concentrations capped at 10 times UTS
    (Universal Treatment Standard)

Alternative Standards for Soil
  • Example soil with nickel at 400 mg/L
  • 90 reduction brings it to 40 mg/L
  • UTS for Ni is 11 mg/l treatment standard is 110
  • Soil is only required to be treated to 110 mg/L
  • Soil with concentrations greater than 10X the UTS
    cannot be landfilled

  • Be advised that the contents of this training
    module only cover a portion of the LDR
  • Please refer to applicable federal and
    state-specific regulations for actual regulations
    and applicability