Hazardous Waste Management

Do Land Disposal Restrictions Apply to You?

Generators

Generators must properly identify the waste at the point of its generation and determine if it has to be treated before land disposal. If the wastes are above the LDR treatment standard, the generator must either treat the wastes on-site before having them disposed of, or send them off-site for proper treatment and ultimate disposal. If the hazardous waste meets the applicable LDR treatment standard, additional treatment is not necessary before disposal.

The generator must inform the receiving TSDF of the status of the hazardous waste in accordance with 40 CFR 268.7(a). See Notification and Recordkeeping in this section. Note that wastes generated by conditionally exempt small quantity generators (CESQGs) are not subject to LDR.

Are you a hazardous waste generator? See this Advisor article to help you find out.


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TSDFs

Facilities receiving the restricted wastes must follow strict standards in managing the wastes, including testing representative samples of the waste, providing notification and certification if shipping the waste to another facility, and maintaining tracking records of the waste.

Transporters

Transporters must comply with the dilution prohibitions of 40 CFR 268.3 and the storage restrictions set forth in 40 CFR 268.50.

What Are LDR?

The LDR identify hazardous wastes that are restricted from land disposal and describe the treatment standards that must be met for an otherwise "restricted waste" to be land disposed. The objective of the LDR, as they are sometimes referred to, is to protect groundwater, which the LDR accomplish by requiring that hazardous wastes undergo fundamental physical or chemical changes that render them less of a threat to groundwater.


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To comply with the LDR, the waste handler must either treat the waste to reduce its toxicity through destruction or removal of harmful contaminants, or reduce the waste’s leachability by immobilizing the hazardous constituents in the waste. The LDR:


  • Require that certain restricted wastes be pretreated before disposal.
  • Prohibit dilution of wastes to meet treatment standards.
  • Prohibit the storage of certain restricted wastes.
  • Establish recordkeeping and tracking requirements for the disposal of restricted wastes.
  • EPA determined three prohibitions for LDR:
    • The Disposal Prohibition. Before a hazardous waste can be land disposed, treatment standards specific to that waste must be met, either by treating hazardous chemical constituents in the waste to meet required treatment standards or by treating hazardous waste using a treatment technology specified by EPA. The idea is to reduce the toxicity of the restricted waste or reduce the likelihood of migration of hazardous constituents from the waste. There is a treatment standard for each of the restricted wastes that specifies how a waste must be treated before disposal.
    • The Dilution Prohibition. Waste must be properly treated and not simply diluted in concentration by adding large amounts of water, soil, or nonhazardous materials.
    • The Storage Prohibition. Waste must be treated and cannot be stored indefinitely in order to avoid treatment. Waste may be stored, subject to LDR, but only for the purpose of accumulating quantities necessary for proper treatment and disposal.

Wastes must be classified at the point of generation to determine if they are subject to land disposal restrictions. See tomorrow’s Advisor to find out if your wastes fall under LDR.