Choosing the Right LDR Paperwork for Your Hazardous Wastes
Navigating the LDR rules is one of the most complex elements of managing RCRA hazardous waste, not least of all because of the paperwork involved. Let's take a look at the different types of documentation that may be required to meet your Land Disposal Restrictions responsibilities.
LDR Notifications vs. LDR Certifications [40 CFR 268.7(a)]
There are many different types of LDR documentation, but the two most common are "notifications" and "certifications." These two documents require similar pieces of information, but are used for very different reasons.
A "notification" is often referred to as a "land ban form." The land ban form is used when your waste has been sent to a treatment, storage, and disposal facility (TSDF), but does not yet meet LDR standards. In other words, the waste still requires treatment before it can go onto "the land" (e.g., a landfill or surface impoundment).
A "certification," on the other hand, is used when your waste already meets LDR standards when it arrives at the TSDF. This waste can be disposed of without further treatment. An LDR certification might be used when generators treat the waste in some way on their own site to get the waste below regulatory levels.
There are no standardized forms for the LDR notification or the LDR certification, but the TSDF may ask that the generator use a specific form.
What Info Goes in the LDR Notification/Certification?
As mentioned above, the LDR certification and LDR notification require the same kind of information. Whether it's a notification or certification, the LDR paperwork must include:
- The hazardous waste codes that need to be treated for;
- The treatability group for each waste (e.g., wastewaters vs. non-wastewaters);
- The waste subcategory/description for each hazardous waste code (where applicable); and
- Any available waste analysis data available.
If a generator manages and treats hazardous waste on site to meet LDR standards, the site must develop and follow a written waste analysis plan that outlines the procedures taken to treat the wastes. [40 CFR 268.7(a)(5)]
Other LDR Paperwork
Besides the typical notifications and certifications, LDR paperwork can vary based on the specific types of wastes sent for treatment and/or disposal. Some examples of specific types of hazardous waste that would trigger unique LDR paperwork requirements include:
- Lab packs;
- Hazardous debris;
- Contaminated soils;
- Wastes excluded from regulations subsequent to the point of generation (which would use a "one-time notice to file");
- Wastes for which the TSDFs will make LDR determinations;
- Characteristic wastes with underlying hazardous constituents (UHCs); and
- Wastes that meet all LDR standards and are sent to a Subtitle D facility (which would use a "one-time notice to file"). [40 CFR 268.7, 268.9(d), and 268.42(c)]
Join an expert Lion RCRA instructor for the live Land Disposal Restrictions Webinar on September 20 and build a plan for disposing of your site's waste that protects both the environment and your company's bottom line.
Tags: EPA, hazardous waste, LDR, RCRA
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