LAND DISPOSAL UNIT OPTIONS FOR HAZARDOUS WASTE
Land Disposal Units
Posted December 16, 2015 in Articles
The improper treatment and disposal of hazardous waste can pose a serious risk to individuals and the environment. When toxic products are not properly remedied and disposed of, both air pollution and ground water pollution can occur. A land disposal unit (LDU) is a site that treats hazardous waste for storage and disposal. Subtitle C of the Resource Conservation and Recovery Act (RCRA) establishes guidelines and requirements for the management and disposal of hazardous waste at land disposal units. RCRA §3004(k) defines LDUs to include:
- Surface impoundments
- Waste piles
- Land treatment units
- Injection wells
- Salt dome formations
- Salt bed formations
- Underground mines
- Underground caves
EPA Land Disposal Restrictions Program
In 1984 Congress established the EPA Land Disposal Restrictions (LDR) program. The intent of the LDR program is to ensure that the toxic and harmful components present in hazardous waste are properly treated and remedied before the waste is disposed into or onto the land. The program sets forth standards and requirements that owners and operators of treatment, storage and disposal facilities (TSDFs) must meet for the land disposal of hazardous waste. The EPA’s Land Disposal Restrictions: Summary of Requirements (Revised August 2001) publication explains that the LDR program has three primary components:
- Disposal Prohibition: Sets forth specific treatment standards that must be met before hazardous waste can be disposed on land.
- Dilution Prohibition: Requires hazardous wastes to be properly treated rather than being simply diluted in an effort to "mask the concentration of hazardous constituents."
- Storage Prohibition: Provides for hazardous waste to be treated promptly rather than being stored for an indefinite period.
Unit-Specific Technical Standards
The EPA has established unit-specific technical requirements for four of the nine LDUs: landfills, surface impoundments, waste piles and land treatment units. These unit-specific requirements are codified in 40 CFR Part 264/265, Subparts K through N. The regulations are lengthy and are broken up into four separate subparts, each subpart covering one of the four LDUs. The subparts set forth a broad range of requirements for LDU owners and operators, including: design and operating standards, release response actions, special requirements for certain types of waste, inspection, monitoring, and closure and post-closure care.
Beyond the unit-specific technical standards codified in Subparts K through N, LDUs managing hazardous waste must also comply with the general facility standards set forth in 40 CFR Part 264/265, Subparts A through E, as well as specific financial assurance, monitoring and closure and post-closure requirements.
Injection wells, salt dome formations, salt bed formations, underground mines and underground caves are considered to be “miscellaneous units.” Miscellaneous LDUs do not fall under the unit-specific technical standards in 40 CFR Part 264/265, Subparts K through N. However, they must meet certain environmental performance standards to ensure the protection of human health and the environment which are set forth in 40 CFR Part 264, Subpart X. The requirements and standards for owners and operators of facilities that treat, store and dispose of hazardous waste are highly involved. The global network of consultants at Mithras Investments LLC can help guide you through the complex regulatory framework for hazardous waste disposal.Contact us today.