2. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Heritage University RCRA Review Training Alfred A. Capuano, Ed.D.,CET V.P - Safety & Training

3. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved RCRA  More than 250 million metric tons of hazardous waste are produced yearly  That’s more than a ton for every man, woman & child  Most from large manufacturers, refineries, factories & producers  Some from printers, laundries, photo labs, gas stations & other small facilities

4. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Managing Hazardous Waste  Treating, storing & disposing hazardous waste means different things to people  Businesses owner - comply with Federal law  Government official - ensure no harm to people or property  Concerned citizen - assurance that everyone handling HW knows what to do

5. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA & RCRA  Resource Conservation Recovery Act established in 1976  EPA develops specific requirements for handling HW to protect human health & environment  EPA gave us a Christmas tree  OSHA, DOT & Coast Guard are also involved

6. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Before RCRA  Rivers, lakes & streams polluted  News stories everyday concerning random dumping

7. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Main Players  Generators - companies producing HW  Transporters - moves it from one place to another  Waste Managers - treat, store & ultimately get rid of HW

8. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved What Is Hazardous Waste  Any solid, liquid or gas waste, which if not properly discarded would cause harm to human health or environment  Characteristics of HW:  Ignitable  Corrosive  Reactive  Toxic

9. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Where It Comes From  EPA estimates that 90-95% of HW generated by large companies  Other 5-10% generated by small companies (SQG’s - small quantity generators)

10. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Listed Wastes  Non-Specific Sources - ”generics”- solvents, electroplating rinses, waste-water treatment sludges & other metal treating sludges  Specific Sources - from specific industries - paint, lead, ink, petroleum, pesticides, etc  Discarded commercial products - or not used for their intended purpose

11. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Generator Requirements  Bear principle responsibility for their waste and:  Determine hazardability  Obtain EPA ID number  Use HW Manifest  Proper packaging  Proper labeling  Ensure proper disposal

12. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Generators  Treat & dispose on site - 96%  Hire off-site managers - 4%  Ensure companies have EPA authorization - waste managers & transporter

13. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Uniform Manifest  EPA form 870-22 tracks waste from “Cradle to Grave”  Passed from one person to next in the chain  The Manifest Identifies:  Type & quantity of waste  Transporter  TSD where waste is being shipped

14. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Manifest  Generator must sign manifest, ensure packaging & labeling meet DOT requirements, obtain transporters signature & supply at least six copies of manifest

15. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Generator Notified  In 35 days or call to find where waste is located  In 45 days or call the EPA

16. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Packaging & Labeling  HW properly packaged to ensure there is no significant release to environment  Meet DOT requirements  Containers properly labeled & placarded to identify what is being transported, where it’s from, where it’s going, & provide special handling instructions

17. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Storing Waste  Generators of more than 2200 lbs in one month may accumulate & store any amount up to 90 days  Storage requirements apply

18. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Storing  Generators of 220-2200 lbs may store up to 2200 pounds on site for 180 days or 270 days if waste is being shipped more than 270 miles

19. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Transporters  Responsible for transport spills  Ensure wastes don’t spread, notify proper authorities & arrange cleanup  Must have EPA ID number  Comply with manifest requirements  Deliver waste  Ensure proper documentation

20. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Managing Wastes  TSD’s responsible for treating, storing & disposing waste per federal requirements  General requirements  EPA ID number  Waste Analysis Plan  Permit to construct or operate  Emergency Planning (contingency plan)

21. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved TSD’s  Manifest & recordkeeping  Closure requirements

22. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Storage & Disposal  Tanks (above or under ground)  Concrete, steel or plastic  Designed so it will not overflow  If waste is fed continuously it must have equipment to control flow & alarm for overflow  Inspected regularly

23. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Land Disposal  Surface impoundments  Landfills  Waste piles  Land treatment units  Injection wells

24. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Incineration  Burning hazardous waste at high temperatures  Designed, constructed & maintained to remove all (99.99%) of hazardous elements of waste it is burning

25. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Liability Coverage  TSD’s - $1-2 million  Landfills - $3-6 million  Transporters - $5-7 million

26. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA & OSHA  EPA rules designed to protect human health & environment, focusing on off- site receptors  Little consideration of OSHA standards, & no cross references to OSHA standards  More coordination between DOT rules & EPA rules in establishment of RCRA regs  Bottom Line: Compliance with RCRA rules no assurance of compliance with OSHA standards

27. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Regulatory Program Overview

28. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Overview  Resource Conservation & Recovery Act of 1976 (RCRA), as Amended  Waste Inventory/Hazardous Waste Determination/ Determination of Regulatory Status  Notification - EPA Identification Numbers for Generators, TSD Facilities, & Transporters

29. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Overview  Permits for Treatment, Storage, & Disposal (TSD) Facilities (Permits Not Required for 90 Day Accumulation in Containers/tanks)  Standards for Generators, Transporters, & TSD Facilities  Treatment Standards for Wastes Before Land Disposal, & Minimum Technology Requirements for Land Disposal Facilities

30. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Overview  Use of manifest for transportation  State regulatory programs - authorization  Inspections & enforcement  Requirements for clean-up & ultimate responsibility of generator for disposition & environmental impact of waste - "Cradle to Grave"

31. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Basic Requirements of Hazardous Waste Generators

32. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Basic Determinations Questions asked & answered on an on- going basis  Identify Wastestreams (What are all the wastes at facility?)  Hazardous Waste Determination (Which of these wastes are hazardous, using regulatory definitions?)  Determination of Regulatory Categories (How much and what is done on-site?)

33. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Container Management  Containers must be...  In good condition  Compatible with the waste  Labeled or marked clearly with "hazardous waste“  Marked with accumulation start date

34. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Container Management  Kept closed  Managed to avoid damage & releases  Incompatible wastes not placed in same container  Subpart cc air emissions standards may apply

35. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Container Accumulation Area  Ignitable/reactive wastes must be 50 ft from the property line  "No smoking" signs must be posted  Incompatible wastes separated or protected from each other  Emergency equipment available  Adequate aisle space (2½ ft) maintained

36. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Container Accumulation Area  Inspect weekly  Inspect emergency equipment at least monthly  Shipments made every 90 days for large quantity generators  Shipments made every 180 days for small quantity generators

37. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Compliance Documentation  Contingency plan  Personnel training program & records  Inspections  Manifests & LDR forms  Biennial reports  Waste analyses/determinations  Waste minimization program

38. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA’s Definition of Solid Waste (40 CFR 261.2)

39. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Any Material  Disposed of or abandoned in lieu of disposal  Burned, incinerated or recycled  “Inherently waste-like”

40. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Please Note  EPA takes “all or nothing” approach  Secondary materials are comprehensively regulated or totally unregulated, which ignores laws of chemistry & physics, making no allowance for severity or degree of hazard  RCRA rules do not address chemical inventory issues, which are addressed under EPCRA & OSHA regs

41. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Materials which are not solid wastes 40 CFR 261.4(a)  Domestic sewage exclusion  Point source (NPDES) exclusion  Secondary materials that are reclaimed & returned to original process in which they were generated where they are reused in production process Exclusions

42. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Pertinent Exclusions Materials which are not solid wastes 40 CFR 261.4(b)  Household wastes  Petroleum contaminated media & debris (D018-D043 only) from regulated UST releases

43. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Samples - 40 CFR 261.4(d)  Treatability Study Samples - 40 CFR 261.4(e)&(f)  CESQG Hazardous Wastes - 40 CFR 261.5  Specified Recyclable Materials - 40 CFR 261.6  Residue Empty Containers - 40 CFR 261.7  PCB Wastes Exhibiting Toxicity Characteristic (D018-D043) Regulated Under TSCA - 40 CFR 261.8  Universal Wastes - 40 CFR 261.9, Referencing 40 CFR Part 273 Other Exclusions

44. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Product or raw material storage tank residues;  Residues in product or raw material transport vehicles, vessels or pipelines;  Residues in manufacturing process units while these units are in service 40 CFR 261.4(c) Other Exclusions

45. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Waste/Hazardous Waste Determinations 40 CFR 261.3

46. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Solid Waste Determination  Excluded from definition of solid waste - 40 CFR 261.4(a) or by reuse or recycling  Excluded from definition of hazardous waste - 40 CFR 261.4(b)

47. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Determination  Listed - 40 CFR 261, Subpart D  Mixture of Solid Waste & Listed Hazardous Waste - 40 CFR 261.3(a)(2)(iv)  Solid Waste Derived from T, S, or D of Listed Hazardous Waste - 40 CFR 261.3(c)(2)(i)  Waste Exhibits any Characteristics of Hazardous Waste - 40 CFR 261, Subpart C - either by testing or knowledge of waste

48. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Wastes Lists 40 CFR Part 261, Subpart D Four Lists:  F- list  K- list  P- list  U-list

49. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Wastes from Non-Specific Sources 40 CFR 261.31 F-List

50. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved F-List  Spent Solvents (F001-F005)  not commercial products or manufacturing process wastes - “solvent mixture rule”  All spent solvent mixtures/blends containing, before use, a total of 10% or more (by volume) of one or more of the solvents listed in F001, F002, F004 and F005 are now regulated

51. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved F-List  Determine if F001, F002, F004 or F005 solvents are present in trade name solvents or solvent blends.  Electroplating wastes (F006, F007, F008, F009)  Metal heat-treating wastes (F010, F011, F012)  WWT sludges from chemical conversion coating of aluminum (F019)  Miscellaneous

52. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Wastes From Specific Sources 40 CFR 261.32 K-List

53. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved K-List  Wood preservation  Inorganic pigments  Organic chemicals  Inorganic chemicals  Pesticides  Explosives

54. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved K-List  Petroleum refining  Iron & steel  Primary copper  Primary lead  Primary zinc  Primary aluminum

55. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved K-List  Ferroalloys  Secondary lead  Veterinary pharmaceuticals  Ink formulation  Coking

56. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Commercial Chemical Products Lists Acute Hazardous (H) Waste (40 CFR 261.33(e)) – “P-List” and Toxic (T) Wastes (40 CFR 261.33(f)) – “U-List”

57. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved P-List  Pesticides, toxic organics, pure cyanides, & heavy metal compounds  Listings include unrinsed containers/liners & spill residues  Lower small quantity generator exclusion (1 kilogram/100 kilograms spill residue)

58. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Mostly natural & synthetic organics  Listings include spill residues U-List

59. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Commercial chemical product listings do not apply to spent materials or manufacturing process wastes containing listed chemicals. Listings apply to technical grade chemicals or formulations where the listed chemical is the sole active ingredient. Commercial chemical products listings apply if & when chemicals are spilled, discarded or intended to be discarded. Listings should be consulted prior to disposal of virgin chemical spill residues, off- specification chemical products, manufacturing chemical intermediates, obsolete chemical inventory, excess or surplus inventory, or expired chemical products. Note

60. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Characteristics of Hazardous Waste (40 CFR Part 261, Subpart C) A Focus on Acute Hazards, Except for the Toxicity Characteristic

61. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Ignitability (I) D001 (40 CFR 261.21)  Liquid, with closed cup flashpoint <140  F  Nonliquid, capable of spontaneous and sustained combustion and when ignited, burns so vigorously & persistently as to create a hazard  DOT oxidizers & ignitable compressed gases

62. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Aqueous, pH  2 or pH  12.5  Liquid, Corrodes SAE 1020 Steel > 1/4" Per Year at 130  F  Federally, no recognition of corrosive solids Corrosivity (C) D002 (40 CFR 261.22)

63. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Reactivity (R) D003 (40 CFR 261.23)  Unstable, reacts violently  Water ‑ reactive or forms potentially explosive mixtures with water  Forms toxic gases, vapors, or fumes endangering health when mixed with water  Cyanide or sulfide containing waste which can generate toxic gases at pH conditions between 2 & 12

64. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  EPA Guidance: Reactive Cyanide (SW846-9010): 250 mg HCN/kg Waste 250 mg HCN/kg Waste Reactive Sulfide (SW846-9030): 500 mg H 2 S/kg Waste 500 mg H 2 S/kg Waste Reactivity (R) D003

65. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Reactivity (R) D003  Capable of detonation or explosive reaction  DOT explosive divisions 1.1 to 1.3 (Class A or B)

66. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Toxicity (E) D004-D043 (40 CFR 261.24)  Toxicity characteristic leaching procedure (TCLP) extract of waste analyzed for specified heavy metals and toxic organics.  Zero headspace extraction (ZHE) required for volatile organic constituents.

67. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Toxicity (E) D004-D043  TCLP extraction developed to simulate effects of waste mismanagement upon the groundwater in a municipal landfill co-disposal scenario  Regulatory thresholds are derived by multiplying the chronic toxicity level (Typically MCLs) by the dilution attenuation factor (DAF)  DAF is currently set at 100

68. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved When Does a Solid Waste Become a Hazardous Waste?

69. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Waste Becomes Hazardous….  When it first meets listing description  For mixtures, when listed hazardous waste is first added to solid waste (“Mixture Rule” - 40 CFR 261.3(a)(2)(iv))  When waste exhibits any characteristics of hazardous waste  Note: point of generation to be used for regulatory purposes (before aggregation, consolidation or treatment)

70. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Residues  Sludges  Treatment residues  Spill residues  Ash  Air emission control sludge/dust  Leachate  Derived from rule- 40 CFR 261.3(c)(2)

71. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories

72. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories  Conditionally - exempt generator or CEG (<100 Kg/Mo)  Small quantity generator or SQG (100 - 1000 Kg/Mo)  Generator who accumulates on-site in containers or tanks for less than 90 days (large quantity generator or LQG)  Note: these categories are mutually exclusive at any one point in time

73. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories  Generator/Shipper (to Off-site TSD)  Used Oil Generators, Transporters, Processors/re-refiners, Burners and Marketers  Owner/Operator of Underground Petroleum Or Hazardous Substance Storage Tank  Commercial TSD Facility

74. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Standards For Generators (40 CFR 262)

75. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time 40 CFR 262.34  Use and Management of Containers (40 CFR 265 ‑ Subpart I and Subparts AA, BB, and CC as Applicable)  Tank Systems (40 CFR 265 ‑ Subpart J, Except 265.197(c) and 265.200 and Subparts AA, BB, and CC as Applicable)  Containment Buildings (40 CFR 265 - Subpart DD)

76. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Accumulation start date marking (90 day limit ‑ 30 day extension possible)  Satellite accumulation - 40 CFR 262.34(c)  Excess accumulation date starts 90 day period  Hazardous waste marking/labeling

77. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Preparedness & prevention - 40 CFR 265 subpart C  Contingency plan & emergency procedures - 40 CFR 265 subpart D  Personnel training - 40 CFR 265.16

78. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Closure performance standards - 40 CFR 265.111 & 265.114  Control of post-closure releases  Removal & proper disposal of all hazardous wastes, residues & contaminated soil

79. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Note  Satellite accumulation provisions at 40 CFR 262.34(c)  Small quantity generator provisions at 40 CFR 262.34(d)

80. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness & Prevention (40 CFR Part 265, Subpart C)

81. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness & Prevention  Maintain & operate facility so as to minimize possibility of fire, explosion or unplanned release (265.31)  Provision of certain required equipment (265.32) :  Internal communications or alarm system  Telephone or two-way radio  Portable fire extinguishers, fire control equipment, spill control and decon equipment  Water at adequate volume & pressure

82. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness & Prevention  Testing & maintenance of equipment (265.33)  Aisle space required to allow emergency response (265.35)

83. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness & Prevention  Arrangements with local authorities must be attempted, as appropriate(265.37):  Police, fire, & emergency response teams  Agreements designating primary fire & police authorities  Agreements with state emergency response teams, emergency response contractors, & equipment suppliers  Local hospitals

84. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Contingency Plans 40 CFR Part 265, Subpart D

85. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Contents  Actions of facility personnel in response to HW emergencies  Arrangements made with local authorities  List of emergency coordinators  Emergency equipment list  Evacuation plan

86. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Personnel Training 40 CFR 265.16

87. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Personnel Training  Who gets trained?  What should training consist of & accomplish?  Who performs training?  How often is training performed?  What constitutes appropriate documentation?

88. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Note  Compliance with RCRA HWM training requirements is not adequate training for OSHA hazard communication standard or DOT subpart H, 49 CFR 172.700 compliance, and may not be adequate for compliance with the OSHA hazardous waste and emergency response operations standard.

89. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements for 100-1000 Kg/Month Small Quantity Generators (40 CFR 262.34(d))

90. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Notify & obtain U.S. EPA ID number  Accumulate no more than 6,000 kg on-site for up to 180 days (270 days if TSD over 200 miles away)  Mark each container with “hazardous waste” & accumulation start date

91. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Follow container or tank accumulation requirements  Preparedness & prevention requirements  Emergency planning & notification of releases

92. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Utilize planning & notification of releases  Follow DOT requirements re: packaging, labeling & marking  Use uniform hazardous waste manifest  Limited exception reporting requirements if return copy not received within 60 days of shipment

93. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Accumulation 40 CFR 262.34(c)

94. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Points  Areas “at or near any point of generation where wastes initially accumulate, which is under control of operator of process generating waste"  Satellite accumulation points are not subject to 90-day accumulation standards that apply to central accumulation/storage areas

95. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Requirements  Wastes placed in containers that are in good condition  Wastes compatible with containers  Containers always closed, unless wastes are being added or removed

96. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Requirements  Containers marked with accumulation start date when "excess accumulation" begins (when the container is filled to capacity)  Full containers moved to 90-day accumulation area within 3 days after being filled to capacity

97. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Practical Approach to Land Disposal Restrictions 40 CFR 268

98. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Land Disposal Restrictions (LDR) are found at 40 CFR Part 268  LDR regulations developed to reduce toxicity and/or mobility of hazardous waste constituents that are land disposed  Majority of hazardous wastes do not meet treatment standards as generated

99. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Hazardous wastes must meet LDR treatment standards before land disposed  Treatment standards based on best demonstrated available technology (BDAT)  Technology based rather than health or risk-based. LDR treatment standards attach at the point of initial generation

100. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Definition of "wastewater" under LDR regulations is a waste that contains less than 1% total suspended solids and less than 1% total organic carbon  Subcategories further categorize certain hazardous wastes  Not all waste codes have subcategories

101. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Three types of treatment standards:  Total Waste Standards (totals analysis)  Waste Extract Standards (TCLP analysis)  Specified Technology Standards (specify a treatment technology by five letter code, rather than constituent concentration)

102. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Concentration-based Universal Treatment Standards (UTS) specify a single numerical treatment standard for each organic, metal and cyanide constituent, regardless of the type of waste, that must be met prior to land disposal

103. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  There is one table at 40 CFR 268.40 that specifies all treatment standards for the various hazardous wastes  Waste code, description/subcategory, regulated hazardous constituents, and wastewater/non-wastewater treatment standards  One treatment standard for wastewater and one for non-wastewater for each waste code

104. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Generator Requirements

105. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved 8 Elements for LDR Compliance  Determine, at point of generation, all applicable codes, category (WW or non-WW), & subcategory (if any) for each restricted waste  Determine which treatment standard applies to each restricted waste

106. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved 8 Elements for LDR Compliance  Identify underlying hazardous constituents (where required)  Determine, through specified analytical techniques or knowledge of the waste, whether the treatment standard has been achieved  Comply with time limitations

107. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved 8 Elements for LDR Compliance  Comply with prohibitions on evaporation & dilution  Prepare notifications & certifications required for onsite or offsite waste management  Comply with recordkeeping requirements to maintain all LDR documentation

108. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA/DOT Regulatory Requirements

109. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Select appropriate shipping description and determine if RQ is being shipped in a single container  Perform LDR determinations  Comply with DOT requirements for packaging, labeling and marking

110. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Verify that transporter & designated TSD facility have valid EPA identification numbers & relevant permits

111. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Prepare uniform hazardous waste manifest (EPA form 8700-22), utilizing appropriate form per acquisition hierarchy  Prepare appropriate notice for restricted waste shipments to treatment facilities  Prepare appropriate certification(s) for restricted waste shipments to land disposal facilities

112. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Offer transporter appropriate placards  Sign & date manifest, certifying shipment meets EPA & DOT pre- transportation requirements. Signature certifies that waste minimization program is in place, & method of T, S, or D selected is environmentally appropriate

113. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Obtain signature of transporter & date of acceptance  Retain one copy of signed manifest & give remaining copies to transporter

114. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Shipping Off-Site  Monitor manifest tracking system  Submit exception reports  Prepare & submit biennial reports including a description of waste minimization efforts & achievements  Keep copies of manifests, land disposal restriction notices/ certifications, biennial reports, any exception reports, & waste analyses/determinations

115. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved