Examples from LDR Technology Based Standards

Code

BIODG

Technology

Biodegradation

CHRED Chemical reduction

CMBST Combustion

DEACT Deactivation

MACRO Macroencapsulation

NEUTR PRECP

REMTL

Neutralization Precipitation

Description

Recovery of metals RORGS Recovery of organics STABL Stabilization

Biodegradation uses microorganisms to break down organic compounds to make a waste less toxic

Chemical reduction converts metal and inorganic constituents in wastewater into insoluble precipitates that are later settled out of the wastewater, leaving a lower concentration of metals and inorganics in the wastewater Combustion destroys organic wastes or makes them less hazardous through burning in boilers, industrial furnaces, or incinerators Deactivation is treatment of a waste to remove the characteristic of ignitability, corrosivity, or reactivity Macroencapsulation is the application of a surface coating material to seal hazardous constituents in place and prevent them from leaching or escaping Neutralization makes certain wastes less acidic or certain substances less alkaline Precipitation removes metal and inorganic solids from liquid wastes to allow the safe disposal of the hazardous solid portion Recovery of organics uses direct physical removal methods to extract metal or inorganic constituents from a waste Recovery of organics uses direct physical removal methods (e.g., distillation and steam stripping) to extract organic constituents from a waste Stabilization (also referred to as solidification) involves the addition of stabilizing agents (e.g., Portland cement) to a waste to reduce the leachability of metal constituents

Source: Adapted from U.S. EPA, RCRA Orientation Manual, www.epa.gov/waste/inforesources/pubs/orientat/rom1.pdf.

The treatment standards for most characteristic hazardous wastes entail rendering the waste non-hazardous (i.e., decharacterizing the waste or removing the characteristic). However, some characteristic waste treatment standards have additional requirements. The regulated community must examine these wastes for underlying hazardous constituents. These constituents are not what cause the waste to exhibit a characteristic, but they can pose hazards nonetheless. The underlying hazardous constituents must be treated in order to meet contaminant-specific levels. These levels are referred to as the universal treatment standards (UTS), which are listed in the Appendix of this chapter.11 This is why some characteristic wastes that no longer exhibit a characteristic must still be treated to meet additional LDR requirements. Once such characteristic hazardous wastes have been decharacterized and treated for underlying constituents, they can be disposed of in a nonhazardous waste landfill.

12.7.2.1.2 Variances, Extensions, and Exemptions

If a restricted waste does not meet its applicable treatment standard, it is prohibited from land disposal. Although most wastes become eligible for disposal by meeting the treatment standards, in some instances this may not be possible. For example, there may not be enough treatment capacity to treat a waste, or the concentration level may not be achievable. To address these situations, U.S. EPA established procedures that allow wastes to be disposed of under special circumstances. The following exemptions, variances, and extensions allow wastes to be disposed of without meeting their respective treatment standards or to be treated to a different standard1,2:

1. National capacity variances

2. Case-by-case extensions

3. No-migration variances

4. Variances from a treatment standard

5. Equivalent treatment method variances

6. Surface impoundment treatment exemptions.

While national capacity variances, when needed, are automatically granted to all affected hazardous waste management facilities, the other five exemptions, variances, and extensions require a facility to specifically petition U.S. EPA.

National capacity variance: When developing a treatment standard, U.S. EPA examines the available treatment capacity to determine whether it is sufficient to handle current and future waste management needs. If U.S. EPA determines that nationally there is not enough capacity to treat a waste, it can automatically extend the effective date of the waste's treatment standard. Such an extension to the effective date is intended to give the waste treatment industry more time to develop the capacity to handle the waste. Wastes under a national capacity variance can be disposed of, without meeting the treatment standards, in landfills and surface impoundments that meet minimum technical requirements (e.g., liners, leachate collection and removal systems, and leak detection systems).

Case-by-case extensions: A facility may petition U.S. EPA for a case-by-case extension to delay the effective date of a waste's treatment standard: upon showing that capacity does not exist for that particular waste. Similar to national capacity variances, wastes granted case-by-case extensions can be disposed of without meeting the treatment standards in landfills and surface impoundments that meet minimum technical requirements.

No-migration variances: No-migration variances differ from capacity variances in that they apply to the disposal unit instead of to the waste, and allow wastes to be disposed of in the unit without meeting the treatment standards. To obtain a no-migration variance for a disposal unit, a facility must petition U.S. EPA and demonstrate that there will be no migration of hazardous constituents from the unit (i.e., the waste will not leak or escape from the unit) for as long as the wastes remain hazardous.

Variances from a treatment standard: Variances from a treatment standard allow the regulated community to petition U.S. EPA and show that the required LDR treatment standard is not appropriate for their waste, or that the treatment standard is not achievable. If a variance is granted, U.S. EPA will specify an alternative standard to meet.

Equivalent treatment method variances: Equivalent treatment method variances allow the regulated community to petition U.S. EPA and demonstrate that a technology different from the required LDR treatment technology can achieve the same results. If approved, the applicant can use the alternative technology in place of the required technology.

Surface impoundment treatment exemptions: Surface impoundment treatment exemptions allow the regulated community to petition U.S. EPA for permission to treat hazardous waste in surface impoundments. Under normal circumstances, owners and operators cannot place untreated hazardous waste on the land, even if it is in a land-based unit for treatment. Since many facilities use surface impoundments as a means of treating waste, the surface impoundment treatment exemption allows owners and operators to conduct such treatment under certain conditions. Surface impoundments treating waste under this exemption must comply with double liner and minimum technical requirements, and provisions for the removal of sludges and treatment residues.

12.7.2.1.3 Alternative Treatment Standards

In establishing treatment standards, U.S. EPA applied the BDAT methodology to the typical forms of waste generated by industry. Some forms of hazardous waste are unique and were not taken into account by the BDAT process when treatment standards were established. As a result, U.S. EPA created a number of broad ATSs for special types of waste.2

Lab packs: Laboratories commonly generate small volumes of many different listed hazardous wastes. Rather than manage all these wastes separately, labs often consolidate these small containers into lab packs. Trying to meet the individual treatment standards for every waste contained in a lab pack would be impractical. To ease the compliance burden, U.S. EPA established an ATS for lab packs that allows the whole lab pack to be incinerated, followed by treatment for any metal in the residues. Treatment using this alternative standard satisfies the LDR requirements for all individual wastes in the lab pack.

Debris: Debris can become contaminated with hazardous waste accidental releases or spills. While such contaminated debris is typically regulated under the contained-in policy, it may also be subject to LDR treatment standards. The physical characteristics of such debris may make it difficult to meet the LDR treatment standard for the waste that is contaminating it. For example, incinerating a solvent-saturated brick wall is not necessarily going to destroy the solvent constituents that are safely nestled in between the pieces of brick. Instead of requiring debris to meet these sometimes inappropriate and difficult standards, U.S. EPA established a set of alternative standards that can be used to treat hazardous debris (40 CFR §268.45, Table 1). The alternative standards range from removing all contaminants with high-pressure washing to encapsulating the debris in order to prevent hazardous constituents from leaching. Debris treated with these ATSs meets the LDR requirements, and in many cases, can be disposed of as nonhazardous waste.

Soil: Cleanup, or remediation, of hazardous waste sites will often produce contaminated soil. Contaminated soil must be handled as hazardous waste if it contains a listed hazardous waste or if it exhibits a characteristic of hazardous waste. As with hazardous waste, land disposal of hazardous soil is prohibited until the soil has been treated to meet LDR standards. These contaminated soils, due to either their large volume or unique properties, are not always amenable to the waste code-specific treatment standards. Because of this, U.S. EPA promulgated alternative soil treatment standards in §268.49 in May 1998. The alternative soil treatment standards mandate reduction of hazardous constituents in the soil by 90% or 10 times UTS, whichever is higher. Removal of the characteristic is also required if the soil is ignitable, corrosive, or reactive.

12.7.2.1.4 Notification, Certification, and Recordkeeping

In order to properly track the hazardous waste that is generated, transported, treated, stored, and disposed of, U.S. EPA imposes certain LDR notification, certification, and recordkeeping requirements on generators and TSDFs. LDR notifications inform the next waste handler how the waste must be treated to meet the treatment standard or whether it can be disposed of without treatment. When wastes do not need to meet a treatment standard, or already meet the standard, U.S. EPA requires the handler to sign a statement certifying such a claim.

Generators must send a notification with the initial shipment of every waste. If the waste, process, or receiving facility changes, another notification is required. The information that the notification must include varies according to the status of the waste. For example, the notification requirements will differ slightly if the waste meets its treatment standard or is subject to a national capacity variance.

Treatment facilities have to send similar notifications along with the shipment of treated wastes to disposal facilities. A certification normally accompanies this notification stating that the waste meets its treatment standards and may be land disposed. Disposal facilities are the final link in the waste management chain. As a result, they have to test the waste residue that they receive to ensure that it meets the treatment standards.

Each hazardous waste handler must comply with certain recordkeeping requirements for LDR notifications and paperwork. Generators, treatment facilities, and disposal facilities must keep copies of all LDR paperwork associated with the waste they ship or receive in their facility files for three years.

Characteristic wastes that are decharacterized subsequent to the point of generation (i.e., they become nonhazardous) are handled differently. Once a waste is decharacterized and has met its full LDR treatment standards, it can go to an RCRA nonhazardous waste facility. These LDR notifications and certifications are sent to the U.S. EPA Region or authorized state rather than to the receiving facility. This is intended to protect facilities from the burden of hazardous waste paperwork.

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