Search

Choosing the Right LDR Paperwork for Your Hazardous Wastes

Posted on 8/23/2016 by Joel Gregier

If your site generates hazardous wastes, you will likely deal with Land Disposal Restrictions (LDRs) at some point. In a nutshell, hazardous waste may not be placed in a landfill or surface impoundment until it has been treated to make it safer for the environment. Because these hazardous wastes will sit in landfills for long periods of time, it's critical that the hazardous constituents in the waste are at a safe level before disposal. LDR treatment standards apply at the point of generation of a hazardous waste, and they continue to apply throughout the life of the waste—even if the waste is "de-characterized" so that it no longer meets the EPA's definition of "hazardous." [66 FR 27269, May 16, 2001]

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.
LDR certifications must also include a very specific certification statement that says, in essence, the waste already meets LDR treatment standards, so it can be disposed of without further treatment.

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)]
Build the confidence to effectively manage compliance with the RCRA land disposal restrictions! Mastering LDRs will help you simplify this sometimes complex process and be sure you're not overpaying for needless or redundant treatment of your hazardous waste.

Sign up for the Land Disposal Restrictions Online Course 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

Find a Post

Compliance Archives

Lion - Quotes

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

Download Our Latest Whitepaper

Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.