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One-Time LDR Notification

by Karen Hale

Under the land disposal restriction (LDR) rules, which are located in Ohio Administrative Code (OAC) Chapter 3745-270, most hazardous wastes cannot be disposed of unless they meet the treatment standards listed in OAC rule 3745-270-40. If sending hazardous waste off-site for treatment, the generator must complete and provide a one-time LDR notification to the treat- ment facility to ensure they can properly treat the waste to meet the required LDR standards.

The generator must provide the following information to the treatment facility:

  • the waste code(s) that describe the waste;

  • a statement informing the treatment facility that the hazardous waste is subject to the LDR rules;

  • for F001-F005 wastes, a list of the chemical name(s) of the solvent(s) in the waste;

  • for F039 waste, a list of all of the hazardous constituents in the waste that exceed the treatment standard;

  • for characteristic hazardous wastes, a list of all of the underlying hazardous constituents (unless the treatment facility treats hazardous wastes for all underlying hazardous constituents);

  • a determination indicating whether the waste is a wastewater or non-wastewater; and

  • a determination of the subcategory of the waste (if applicable).

This information must be provided to the treatment facility with the initial waste shipment or any time the hazardous waste changes resulting in a change of the applicable LDR treatment standard. The generator also must keep a copy of the notification.

Although not required by the LDR rules, generators should know how the hazardous waste will be treated (for example, incineration, stabilization, distillation) to ensure proper treatment. Additionally, LQGs are required to report how the waste is treated in their Annual Report.

Ask the Inspector:

Generator Training Requirements

by Andy Kubalak

As a large quantity generator (LQG):

1. Am I required to provide hazardous waste training to all of my employees?

No. Ohio Administrative Code (OAC) rule 3745-65-16 requires only that all LQG personnel involved with hazardous waste management receive training. The training program must teach facility personnel hazardous waste management procedures relevant to their position. Hazardous waste management activities could include:

  • properly evaluating waste to determine whether it is hazardous;

  • properly handling hazardous waste;

  • responding to facility hazardous waste emergencies;

  • implementing the facility’s contingency plan;

  • labeling and dating containers used to store hazardous waste;

  • filling out the uniform hazardous waste manifest;

  • conducting inspections of areas where containers of hazardous waste are stored;

  • conducting inspections of required emergency equipment;

  • using, repairing and replacing emergency equipmen;

  • using, repairing and replacing communication or alarm systems; or

  • using, repairing and replacing emergency systems, and automatic waste feed cut-off systems

continued on page 10...

Notifier-Winter 2006



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