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Comprehensive Guide to LDR Treatment Standards

Learn about Land Disposal Restrictions (LDR) treatment standards for hazardous waste disposal. Understand the columns, applicability, and compliance requirements. Get insights on waste characterization, treatment methods, and regulatory subcategories.

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Comprehensive Guide to LDR Treatment Standards

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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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