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WorkWaste LLC workwaste

WorkWaste LLC www.workwaste.com. 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

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WorkWaste LLC workwaste

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  1. WorkWaste LLCwww.workwaste.com LDR Training/Guidance

  2. 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”

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

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

  5. LDR Treatment Standards What are the Treatment Standards? 40 CFR 268.40 – Treatment Standard Table

  6. 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 disposed

  7. 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

  8. 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 characteristic.

  9. 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.

  10. 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)

  11. 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 - <1% by weight total organic carbon (TOC) and <1% by weight total suspended solids (TSS) • Nonwastewaters - > or = 1% TOC or > or = 1% TSS

  12. 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

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

  14. 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)

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

  16. 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

  17. 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)

  18. 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 mg/L • Soil is only required to be treated to 110 mg/L • Soil with concentrations greater than 10X the UTS cannot be landfilled

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

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