What waste analysis procedures must a generator follow if they are treating their hazardous waste to comply with the land disposal restrictions (LDR)?
The general requirements for generators treating in tanks, containers, and/or containment buildings to meet land disposal restrictions (LDR) treatment standards are included in 40 CFR §268.7(a)(5). These requirements must be documented in a Waste Analysis Plan (WAP), and are designed to ensure that the generator has sufficient knowledge of their wastes to manage them properly, including identifying:
• Parameters to be analyzed
• Sampling methods
• Testing and analytical methods
• Frequency for re-evaluating wastes; or frequency of spot checks.
The generator must obtain a detailed chemical and physical analysis of a representative sample of any waste that they generate, treat, store, or dispose. The WAP must contain all information necessary to treat the waste in accordance with the LDR requirements. It must be kept on-site and made available to inspectors when requested.
When wastes treated on-site are shipped off-site for disposal, the generator must comply with the notification and certification requirements of §267.8(a)(3) (for wastes which meet their treatment standards prior to shipment offsite). This notice must accompany the first shipment of waste to the disposal facility and be retained in the generator's files.
Detailed guidance regarding WAP development is available in the following documents:
Waste Analysis at Facilities that Treat, Store, or Dispose of Hazardous Waste: A Guidance Manual – April 1994 https://www3.epa.gov/epawaste/hazard/tsd/ldr/wap330.pdf.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Waste: A Guidance Manual – Final - April 2015 http://www.epa.gov/sites/production/files/2015-04/documents/tsdf-wap-guide-final.pdf.