Waste Management Overview & Land Disposal Restrictions

1
Waste Management Overview Land Disposal
Restrictions
2
Regulatory Framework for Hazardous Waste EPA
Regulation 347

• Environmental Protection Act (EPA) provides the
  ministry with the authority to govern and make
  regulations pertaining to the management of
  wastes.
• Regulation 347 made under the authority of the
  EPA is the key regulation for wastes
• Defines waste types
• Provides a cradle to grave management system
  for the management of hazardous wastes
• Identifies wastes through a series of listings,
  characterized through tests or defined as
  hazardous and require special treatment
• Sets approval and administrative requirements for
  generators, carriers and receivers of hazardous
  waste
• Identifies treatment standards through the LDR
  program.

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Regulation 347 Waste Descriptions
Waste
Liquid Industrial
Hazardous
Municipal (Solid Non-hazardous)
Subject waste (unless excluded)

• Subject waste used to describe wastes to which
  the registration and manifest provisions of
  Regulation 347 apply.
• Liquid Industrial wastes are not hazardous but
  are liquid (slump test) and industrial waste.
• Hazardous wastes are either listed, characterized
  through tests or defined.

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LDR Program Overview

• Key components of LDR program
• Treatment standards
• Notification and Reporting GRR
• Waste analysis requirements
• Treatment standards phased-in
• Exemptions and Variances
• SQG, MHSW, equivalent treatment, alternate
  treatment.

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Wastes not affected by LDR Program

• Non hazardous wastes
• Liquid industrial wastes
• Exempted wastes (e.g. agricultural wastes,
  recycled wastes)
• PCB wastes (gt50 ppm)
• Biomedical wastes
• SQE wastes

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Waste Streams Subject to LDR

• Listed hazardous wastes
• These are specific wastes that are listed in a
  series of schedules in the regulation (e.g.
  industrial waste streams, hazardous and acute
  waste chemicals and severely toxic wastes)
• Once treated, these listed wastes remain
  hazardous and can only be land disposed in a
  hazardous waste disposal facility.
• Characteristic hazardous wastes
• These include wastes that are defined as
  hazardous because they are ignitable, corrosive,
  reactive and leachate toxic. Tests for these
  characteristics are specified in the regulation
• Once the characteristic is removed and the waste
  is treated to the new standards, these wastes
  will no longer be considered hazardous and can be
  disposed of at either a hazardous or
  non-hazardous waste disposal facility.

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Hazardous Waste Subject to LDR
Acute Hazardous (Schedule 2 Part A)
Hazardous Industrial (Schedule 1 and 1.1)
Listed Waste
Hazardous Chemical (schedule 2 Part B)
Hazardous Waste
Severely Toxic (Schedule 3)
Corrosive
Ignitable
Characteristic Waste
Leachate Toxic
Reactive
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LDR Treatment Standards

• The treatment standards are based on the
  treatment standards developed as part of the U.S.
  LDR treatment standards.
• Treatment standards have been incorporated in
  Schedules in Regulation 347
• Standards are either a numerical standard or a
  technology standard
• Numerical standards are based on bulk analysis or
  TCLP as identified.

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How Treatment Standards work for Listed Hazardous
Waste as of December 31, 2009

• Treatment standards for listed wastes
• Found in Schedules 1 (Hazardous Industrial
  Waste), 2A (Acute Hazardous Waste Chemical), 2B
  (Hazardous Waste Chemical), and 3 (Severely Toxic
  Waste) of Reg. 347
• Each listed waste has identified regulated
  constituents
• Treat waste that are at or exceeds the standard
  for each constituent or by the treatment code
  specified
• Treated waste - disposed at a hazardous waste
  facility.

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Treatment Standards Listed Waste
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How the Treatment Standards work for
Characteristic Waste as of December 31, 2009

• Treatment standards for characteristic waste
  found in Schedule 5
• Treat waste to remove characteristic
• Treat regulated constituents that exceed Schedule
  6 (Note not in effect until Dec. 31, 2009)
• Includes provisions to deal with special
  situations (e.g. best efforts)
• Fully treated waste can be disposed at a
  hazardous or non-hazardous waste facility.
• Listed wastes that are also characteristic (not
  identified in the listed standard) must meet both
  treatment standards and disposed of at a
  hazardous waste facility.

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Treatment StandardsCharacteristic Waste
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How the Treatment Standards Work as of August
31, 2007 until Dec. 31, 2009
Treatment Standard will be listed in Schedules
1, 2A, or 2B using the same corresponding
hazardous waste number
Is it a Listed Waste?
Is the hazardous waste number listed in
Schedules 10, 11 or 12
Y
Y
N
No treatment required
N
N
N
Treatment Standard will be listed in Schedule 5
using the same corresponding hazardous waste
number
Is it a Characteristic Waste?
Is the hazardous waste number listed in
Schedule 13
Y
Y
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Mixed Hazardous Wastes

• Mixed hazardous wastes are only subject to the
  LDR treatment standards as of December 31, 2009.
• What is a mixed hazardous waste
• A mixture of hazardous wastes having both a
  hazardous characterization that is found in
  Schedules 10, 11, 12 and 13 and a hazardous
  characterization that is not found in Schedules
  10, 11, 12 and 13 (but found in Schedules 1, 2a,
  2b, 3 and 5).

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Alternate Treatment Standards

• Alternate treatment standards set out in
  Regulation for
• Soils that exhibit a hazardous characteristic
• Debris that are listed or characteristic.
• Alternate standards provided to
• Address uniqueness of hazardous soils and debris
• Facilitate remediation of contaminated sites.

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LDR Requirements - Generator

• Generator is responsible for determining if a
  waste or residue from the treatment of that waste
  is to be land disposed.
• As the treatment standards take effect the
  generator is required to amend their GRR and
  determine if the completion of the LDR
  Notification part of the GRR (Part 2B) is needed.
• Provides needed information to receivers about
  the waste.
• Changes to GRR must be made within 15 days of the
  phase in dates
• August 31, 2007 treatment of wastes in
  Schedules 10 to 13
• December 31, 2009 treatment of all listed and
  characteristic wastes
• 2009 registration to require additional
  information for affected wastes.
• The generators notification is the LDR
  Notification - Part 2B in the most recent
  generator registration report (GRR) or any
  subsequent supplementary GRR.
• Must be sent before or with the first shipment of
  waste to the receiver (only exception is the
  fully treated characteristic waste simple
  statement).

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LDR Requirements - Receiver

• Notification If required, generators must
  provide the receiver with the following
  information as outlined in S.84
• LDR notification Part 2B in the most recent
  generator registration report (GRR) or any
  supplementary GRR
• Notification must be provided by the generator
  before or on the first shipment of waste to the
  receiver regardless if the waste is treated or
  not (Only exception is fully treated
  characteristic waste only simple statement is
  required)
• Required to amend their GRR and determine if the
  completion of the LDR Notification part of the
  GRR (Part 2B) is needed.
• If the receiver is a transfer and/or processing
  station, then the receiver becomes the generator
  and is now required to register the residue or
  waste and if required, forward the updated LDR
  notification to the next receiver.
• Mixing, Blending and Bulking Need a CofA to mix,
  blend and/or bulk hazardous waste with any other
  waste or material during the transfer and at the
  receiving facility.

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LDR RequirementsNotification On-site Records

• Notification for Small Quantity Generators (SQG)
• SQG not subject to LDR notification requirements
  in S.84 of Reg. 347
• Notification is provided through a certificate
  placed on the outside of the sealed container for
  land disposal (S.80 of Reg. 347).
• Generators site where waste is treated to meet
  the LDR standard shall develop and follow a
  written waste analysis plan to include (S.85)
• Regular and detail chemical and physical testing
  of representative samples
• Frequency of testing
• Records of testing
• Maintain plan and records for a minimum of 2
  years.

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LDR Guidance Materials

• Additional resources at http//www.ene.gov.on.ca
  /envision/land/hazardousWaste.htm
• Site includes
• Regulation 347
• Fact sheet describing on-site storage and
  processing requirements and mixing prohibitions
  as of March 31, 2006
• Fact sheet on characterizing and registering
  hazardous and liquid industrial wastes
• Notice of the Storage of Subject Waste Form 90
  days storage notice for generators to meet the
  requirements S 17.2 of Reg. 347
• Revised Generator Registration Report (GRR),
  2007
• Series of fact sheets on various aspects of the
  LDR program
• Generator Registration Guidance Manual draft
• Additional information on classification,
  registration and management of liquid industrial
  and hazardous wastes
• Guidance on LDR requirements and related changes
• Updated information on registration and use of
  HWIN
• Land Disposal Restrictions Handbook draft
• Handbook to help generators, carriers and
  receivers of hazardous wastes understand and
  assess how the program affects their operations.