VARIANCE ASSISTANCE DOCUMENT:
LAND DISPOSAL RESTRICTIONS TREATABILITY VARIANCES &
DETERMINATIONS OF EQUIVALENT TREATMENT
U.S. Environmental Protection Agency
Office of Solid Waste
Waste Treatment Branch
401 M Street, SW
Washington, DC 20460
Mail Code 5302-W

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TABLE OF CONTENTS
Page
1.0 INTRODUCTION		1-1
1.1	Introduction and Purpose		1-1
1.2	Determination of Equivalent Treatment 		1-3
1.3	Treatability Variance 		1-3
1.4	Organization	 1-4
2.0 LDR VARIANCE PETITION CONTENTS 		2-1
2.1	Administrative Information		2-1
2.1.1	Submission of Completed Applications 		2-1
2.1.2	Identifying Information 		2-2
2.2	Background Information		2-2
2.3	Petition Development and Information Gathering Process		2-3
2.3.1	Identification of Applicable Waste Codes		2-4
2.3.2	Identification of Applicable LDR Standards		2-4
2.3.3	Characterization of Initial Wastestream and Treatment
Residuals		2-4
2.3.4	Conduct Engineering Evaluation Showing that Either the
Treatment Standard Cannot be Met or the BDAT Used to
Develop the Standard is not Appropriate for the Waste		2-8
2.3.5	Description of Waste Generation Process 		2-9
2.3.6	Description of Current Waste Treatment Process		2-9
2.3.7	Description of Proposed Waste Treatment Process 		2-10
2.3.8	Gather Data on Proposed Waste Treatment Process 		2-10
2.3.9	Evaluation of the Proposed Waste Treatment Process
with Respect to BDAT Criteria		2-13
3.0 PETITION REVIEW PROCESS		3-1
3.1	Receipt of Variance 		3-1
3.2	Preliminary Review		3-1
3.3	In-Depth Review 		3-2
3.4	Public Notice and Comment		3-3
3.5	Notification of Final Decision		3-4
4.0 BIBLIOGRAPHY		4-1

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LIST OF APPENDICES
Page
Appendix A List of Applicable RCRA Regulations	 A-l
Appendix B List of Applicable BDAT Background Documents	 B-l

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1.0 INTRODUCTION
1.1	Introduction and Purpose
The Hazardous and Solid Waste Amendments of 1984 (HSWA), require the
Environmental Protection Agency (EPA) to promulgate regulations restricting the land disposal of
untreated hazardous waste. This effort is generally referred to as the Land Disposal Restrictions
(LDR) program. The LDR program identifies levels or methods of treatment that substantially
reduce the toxicity of a waste or the likelihood of migration of hazardous constituents from the
waste. These levels or LDR standards come in two basic forms:
Numerical standards expressed as the concentration of hazardous constituents in the
residuals from treatment, and
Technology-specific standards that require the use of a specific technology.
Both types of LDR standards are based on the performance of the Best Demonstrated
Available Technology (BDAT).
The land disposal restrictions are effective immediately upon promulgation unless the
Agency grants a national variance based on the lack of available BDAT treatment capacity. If
EPA determines that adequate BDAT treatment capacity is not available, HSWA allows EPA to
establish an alternative effective date based on the earliest date when adequate capacity will be
available, but in no case longer than 2 years. These national capacity variance determinations are
made on a national level and do not require any type of petition or application from affected
generators.
In addition to national capacity variances, case-by-case capacity extensions are also
available. (See 40 CFR 268.5.) Case-by-case extensions require generators to file a petition
demonstrating "...that a binding contract has been entered into to construct or otherwise provide
alternative capacity that cannot reasonably be made available by the effective date due to
circumstances beyond the applicant's control" (51 FR 40579, November 7, 1986). In addition,
there are 6 other demonstrations required for case-by-case extensions to an effective date. (See
40 CFR 268.5.) National and case-by-case capacity variances are designed for cases where the
waste, presumably, can be treated to meet the LDR standard, but where insufficient BDAT
capacity exists. These variances, therefore, provide temporary relief only from the effective date
of the LDR standards, not from the standards themselves.
In addition to capacity extensions, generators can obtain a variance from the LDR
standards through a "no migration petition." (See 40 CFR 268.6.) No migration petitions must
demonstrate that there will be no migration of hazardous constituents from the disposal unit (e.g.,
landfill, underground injection well, surface impoundment) for as long as the waste remains
hazardous. These petitions are wastestream and disposal unit specific and, if granted, exempt the
wastestream/disposal unit combination from the LDR standards (specifically, Subpart C of 40
CFR 268).
Consequently, national capacity variances, case-by-case capacity variances, and "no
migration petitions" are not applicable to wastes that cannot meet the LDR standard. To handle
cases where the waste cannot meet the LDR standards, EPA has established equivalent treatment
and treatability variance procedures. These two types of variances correspond to the two basic

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types of LDR standards. Determination of equivalent treatment applies to LDR standards
expressed as a specific technology; a treatability variance applies to numerical LDR standards.
The purpose of this Document is to assist petitioners in submitting complete applications
for either determination of equivalent treatment or a treatability variance (for process wastes
only). This Document describes the two types of variances and discusses the situations to which
they apply. It also discusses the required contents for each type of petition and provides an
overview of EPA's petition review process.
1.2	Determination of Equivalent Treatment
As mentioned above, a determination of equivalent treatment applies to
technology-specific LDR standards (i.e., those requiring the use of a specific technology as
opposed to a numerical standard). The requirements for determination of equivalent treatment
petitions (also referred to as equivalency petitions) are contained in 40 CFR 268.42(b).
Successful equivalency petitions must demonstrate that the proposed alternative treatment
technology can achieve a measure of performance equivalent to that of the BDAT technology.
Petitions must also demonstrate that the proposed treatment system is in compliance with Federal,
State, and local requirements and is protective of human health and the environment.
In general, EPA has established technology-specific standards for only wastes that contain
certain hazardous constituents that cannot be routinely or accurately measured using EPA
analytical techniques. Consequently, equivalency is normally judged on a qualitative rather than
quantitative basis. Section 2.3.5 of this document presents EPA's general rationale in evaluating
these petitions.
1.3	Treatability Variance
Treatability variances may be granted for wastes that have LDR standards that are
expressed as concentrations of hazardous constituents in the waste or waste extract (i.e., a
numerical standard). The requirements for treatability variance petitions are contained in 40 CFR
268.44.
In order to be granted, treatability petitions must demonstrate that the waste of concern
cannot be treated to the specified levels because its physical or chemical properties differ
significantly from the waste used to establish the LDR standard.
Treatability variances may be generic or site-specific. A generic variance can result in the
establishment of a new treatability group and a corresponding LDR treatment standard that
applies to all wastes that meet the criteria of the new waste treatability group (55 FR 22526,
June 1, 1990). A site-specific variance may be granted administratively and may be considered a
non-rulemaking that applies only to a specific wastestream from a specific facility.
1.4	Organization
Section 2 of this Document describes the required contents of both a determination of
equivalent treatment petition and a treatability variance petition. Section 3 provides an overview
of EPA's process for reviewing the petitions, and Section 4 provides a list of references.

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2.0 LDR VARIANCE PETITION CONTENTS
2.1	Administrative Information
LDR variance petitions should be submitted in accordance with 40 CFR 260.20. (See
Appendix A-l.) In addition, determination of equivalent treatment petitions must also satisfy the
requirements 40 CFR 268.42(b), and treatability variance petitions must comply with 40 CFR
268.44. The requirements of these regulations are explained in the following paragraphs.
2.1.1	Submission of Completed Applications
One copy of the completed petition should be sent by certified mail to:
The Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
An additional copy marked "Treatability Variance" or "Determination of Equivalent Treatment"
should be sent by certified mail to:
Chief, Waste Treatment Branch
Office of Solid Waste (5302-W)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington D.C. 20460
Petitions containing Confidential Business Information (CBI) should be sent double wrapped with
"Treatability Variance" or "Determination of Equivalent Treatment" and "Confidential Business
Information" marked clearly only on the inner envelope. The contents of the petition should be
marked in accordance with the requirements of 40 CFR Part 2.
2.1.2	Identifying Information
Both types of petitions must contain the petitioner's name and address, and the name,
address, and EPA identification number of the facility generating the waste. The name and
telephone number of the facility contact should also be provided.
2.2	Background Information
According to 40 CFR 260.20(b)(3), both types of petitions should include a description of
the proposed action. The type of variance requested (i.e., treatability or determination of
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equivalent treatment) should also be clearly stated.
Petitions, per 40 CFR 260.20 (b)(2), must include a statement of the petitioner's interest in
the proposed action (i.e., why the petitioner is seeking the variance). This statement should
discuss the specific LDR standard from which a variance is requested and the technology upon
which that standard is based (i.e., BDAT). At this point, the petitioner should also present the
rationale for the variance request. This rationale should discuss why the waste of concern cannot
be treated to the specified levels for treatability variance requests, or by the specified methodology
for determinations of equivalent treatment. The petition should also discuss the specifics of the
proposed equivalent treatment.
In addition, per 40 CFR 268.44(c), petitions must include the following statement signed
by the petitioner or an authorized representative:
I certify under penalty of law that I have personally examined and am familiar
with the information submitted in this petition and all attached documents, and
that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the submitted information is true, accurate,
and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment.
2.3	Petition Development and Information Gathering Process
This section details the information needed to accurately and completely prepare a
variance petition or a determination of equivalent treatment petition. These subsections are
applicable to both variance petitions and determination of equivalent treatment. The following is
a list of the subsections that discuss the key components of these petitions:
2.3.1
Identification of Applicable Waste Codes
2.3.2
Identification of Applicable LDR Standards
2.3.3
Characterization of Initial Wastestream and Treatment Residuals
2.3.4
Conduct Engineering Evaluation
2.3.5
Description of Waste Generation Process
2.3.6
Description of Current Waste Treatment Process
2.3.7
Description of Proposed Waste Treatment Process
2.3.8
Gather Data on Proposed Waste Treatment Process
2.3.9
Evaluation of the Proposed Waste Treatment Process with Respect to

BDAT Criteria
2.3.1	Identification of Applicable Waste Codes
The petition should identify and discuss the waste code or codes that apply to the
wastestream.
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2.3.2	Identification of Applicable LDR Standards
After the applicable EPA hazardous waste code(s) have been identified, the applicable
treatment standard should be determined. Note that the LDR program defines wastewaters as
those wastes that contain less than 1 percent total organic carbon [TOC] by mass and less than 1
percent total suspended solids [TSS], Nonwastewaters are defined as those wastes that contain
greater than or equal to 1 percent TOC, or greater than or equal to 1 percent TSS. (See 55 FR
22537, June 1, 1990.)
If the wastestream is represented by more than one waste code, the waste must meet the
LDR standards for all applicable waste codes. If the LDR standards overlap for any hazardous
constituents (i.e., if two applicable waste codes have a different LDR standards for the same
hazardous constituents), the more stringent standard applies. See 40 CFR 268.9(a). Information
on treatment standards may also be obtained from the RCRA Docket for specific rulemakings and
by contacting the RCRA/Superfund hotline at 1-800-424-9346.
2.3.3	Characterization of Initial Wastestream and Treatment Residuals
The initial wastestream should be characterized to determine if the wastestream meets the
applicable LDR without requiring treatment. If the treatment standard can be achieved, no
treatability variance is necessary. The effective date for the LDR standard should also be
checked. The characterization of the treatment residuals should include concentrations of
appropriate BDAT constituents.
2.3.4	Conduct Engineering Evaluation Showing that Either the Treatment Standard Cannot
be Met or the BDAT Used to Develop the Standard is not Appropriate for the Waste
An engineering evaluation should be conducted demonstrating that the specified
technology is inappropriate for the waste or that the treatment standard cannot be met.
For example, if a waste has a significantly different matrix from that of the waste used to
develop the standard, an engineering analysis should show the effects of the matrix on the
treatment process. This analysis could be based on sound engineering principles or on actual
bench-scale data developed specifically to determine if the waste can be treated to the treatment
standard. The bench-scale data must demonstrate that the technologies used to establish the
standard are not applicable or are ineffective in meeting the standard for this waste matrix.
Another example is a waste with radioactive components that, if treated by the BDAT,
would significantly increase the risk to human health and the environment. For this waste, the
engineering evaluation should show that using the BDAT would pose a greater total risk than
disposal. The evaluation must describe the potential exposure levels encountered by personnel
operating the process and the health risk related to those exposure levels.
2.3.5	Description of Waste Generation Process
The waste generation process should be described for both the treatability variance and
determination of equivalent treatment petitions. This description should include the feed materials
generating the waste and the generation rate. The potential variability in the waste generation
process and subsequent variations in the waste characteristics should also be described. A

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detailed description of the chemical and physical processes generating the waste should be
provided if user knowledge is the basis for waste characterization. Further, for either type of
petition, the waste generation rate should be presented using the average monthly, maximum
monthly, and/or annual generation rates of the waste.
2.3.6	Description of Current Waste Treatment Process
If the petitioner's current waste treatment system differs from the process proposed in the
petition, the current system should be described, including process design and treatment and
disposal practices. This description should be developed for both determination of equivalent
treatment petitions and variance petitions.
2.3.7	Description of Proposed Waste Treatment Process
For both types of petitions, the proposed waste treatment process should be described
including the process design, physical equipment, chemical reagents, control systems, design
criteria, and operating conditions. The process description should include specifications
demonstrating that the facility is well designed and well operated. In order to determine if a
treatment technology is applicable to a particular wastestream, EPA considers all parameters and
characteristics associated with a hazardous waste that could affect selection of the technology.
EPA uses Waste Characteristics Affecting Performance (WCAPs) and Parameters Affecting
Treatment Selection (PATs) to judge the performance of technologies and to determine if they are
well designed and well operated for the waste of concern. EPA's list of PATs is shown on Table
1. The petition should also demonstrate that the facility is equipped to handle all constituents of
concern, as well as nonhazardous constituents that could affect the system's performance in
treating hazardous constituents.
The description should address compliance with applicable Federal, State, and local
requirements, including how the system may be regulated (i.e., Subpart X, state air emission
standards).
2.3.8	Gather Data on Proposed Waste Treatment Process
The petitioner should include data from the proposed treatment process. For generic
petitions, data should be collected from all affected facilities [51 FR 40606, November 7, 1986],
Samples must be collected for the waste to be treated and the treatment residue and appropriate
operating parameters recorded. These data will be reviewed by EPA with respect to the
achievability of the BDAT treatment standard and for making a determination of equivalent
treatment.

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Table 1. List of Parameters Affecting Treatment Selection (PATS)
•	BDAT list metals content
•	BDAT list organics content
•	Content of other BDAT list constituents (e.g., sulfides and fluorides)
•	Biological oxygen demand (BOD)
•	BTU content
•	Presence of complexed metals
•	Cyanide content
•	Filterable solids content
•	Oil and grease content
•	Oxidation state
•	pH
•	Total organic carbon (TOC) content
•	Total organic halides (TOX) content
•	Viscosity
•	Water content
•	Selectivity value
•	Sublimination temperature
•	Ash fusion temperature

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Any sampling data collected should include:
Dates of sampling and testing;
Operating conditions at the time of sampling;
A description of the methodologies and equipment used to obtain representative
samples;
A description of the sample handling techniques, including techniques used for
extraction, containerization, and preservation of the samples; chain-of-custody
procedures; sample identification and marking procedures; and recordkeeping and
reporting procedures;
A description of the tests performed;
Test results; and
A description of the QA/QC measures for waste analysis and treatment.
To compare the performance of the proposed waste treatment process to the BDAT, the
treatment residues should be analyzed for total concentration in the waste, or concentration in the
waste extract, or both, as required by the applicable treatment standard. The waste and treatment
residue should be analyzed using the analytical methods specified in SW-846.
Quality Assurance/Quality Control (QA/QC) Procedures
Data on concentrations in treated waste must be adjusted for accuracy using recovery
factors specific to the laboratory tests used. (Additional information may be found in the Final
BDAT Background Document for Quality Assurance/Quality Control Procedures and
Methodology.) Data from more than one facility (generic petitions) must be compared to verify
that the performance levels are not significantly different, as described in this background
document. The applicant may evaluate these data by means of analysis of variance (ANOVA).
QA/QC procedures assure that the LDR standards are based on well-documented data
from samples that have been properly collected and analyzed and are, therefore, of known quality.
Matrix analytical detection limits must be determined for the untreated wastes and for each
treatment residual sample. Key data quality indicators for BDAT treatment standards include:
precision, accuracy, representativeness and comparability.
Precision is defined in terms of relative percent difference of the matrix spike and the
matrix spike duplicate, while accuracy is defined in terms of percent recovery of
laboratory matrix spikes.

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Representativeness refers to the selection of appropriate sampling locations and
procedures. The goal is to obtain representative matched data pairs of the untreated
matrix and treatment residues so that the performance of the treatment can be
evaluated.
Comparability is achieved by using consistent sampling and analytical procedures.
For example, grab samples should be compared to grab samples, and composite
samples to composite samples. The collection of matched data pairs should take into
account the retention time of the treatment process. The samples should be analyzed
using the same analytical techniques, and the analytical data should be reported in the
same units for each test.
2.3.9 Evaluation of the Proposed Waste Treatment Process with Respect to BDAT Criteria
The proposed treatment process should be consistent with EPA's criteria for determining
BDAT. In other words, the treatment should be protective of human health and the envrionment,
and it should provide substantial treatment. The following is a summary of EPA's criteria for
determining BDAT. (Additional information with respect to EPA criteria for determining BDAT
may be found in the BDAT Methodology Document.)
(1)	The technology must be "demonstrated." A BDAT must be used in a full-scale
operation. Where EPA does not identify any facilities treating specific wastes from a
particular group, it may "transfer" a finding of demonstrated treatment by comparing
the parameters that affect treatment of the target waste group to parameters for other
waste groups for which demonstrated treatment is known.
(2)	The technology must be "available." Available is defined by EPA as follows:
•	The technology does not present greater total risk to human health and the
environment than land disposal.
•	The technology is commercially available.
•	The technology provides "substantial treatment," which mean it substantially
diminishes the toxicity of a waste or substantially diminishes the likelihood of
migration of hazardous constituents from the waste. EPA judges substantial
treatment on a case-by-case basis.
(3)	The technology must be "best" based on effectiveness of treatment. Economic factors
are not considered. When more than one technology is identified as demonstrated
and available, the treatment data from the technologies are statistically compared (i.e.,
Analysis of Variance) to determine if the technologies provide statistically different
levels of treatment and, if so, which technology is "best."

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3.0 PETITION REVIEW PROCESS
3.1	Receipt of Variance
Following receipt of the petition, it is assigned to an EPA reviewer within the Waste
Treatment Branch of the Office of Solid Waste. EPA will send a letter to the petitioner
acknowledging receipt of the petition.
3.2	Preliminary Review
The preliminary review of the petition consists primarily of a completeness check to
determine what, if any, additional data EPA requires to evaluate the merit of the petition. Section
2 of this document discusses in detail the information that is required for EPA to review a
variance petition. This section presents a summary list of the necessary information that is
required of variance petitions. Note that submittal of incomplete variance petitions may result in
EPA requesting additional information from the petitioner [40 CFR 268.44(d)], thus delaying the
petition review process. In summary, the contents of a complete variance petition are as follows:
Identification of Applicant
Statement of Petitioner's Interest in the Proposed Variance
Description of the Waste
-	Waste generation/description of process generating the waste
-	Waste characterization
-	Waste generation rate
-	Description of current waste treatment process
Discussion of the Proposed Waste Treatment Process
-	Description of the proposed process for treating the waste/description of the
design and operating parameters to determine if the system is well designed and
well operated, etc.
Characterization of the Treatment Residues
-	Corresponding untreated and treated data should be provided and TCLP and/or
total concentration data where appropriate
Documentation of Data Collection
-	Discussion of sampling and analysis procedures used
-	Analytical methodologies used
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-	QA/QC measures
Engineering evaluation demonstrating that the BDAT is inappropriate or the standard
cannot be met
Certification Statement
-	A certification statement must be signed attesting to the truthfulness of the
petition
3.3	In-Depth Review
Following the receipt of any additional requested data, the petition undergoes a thorough
engineering review. This review considers the same information as the preliminary review, but
concentrates on evaluating the technical merit of the data and information submitted, rather than
its completeness.
After the in-depth engineering review, a preliminary decision to grant or deny the petition
is made.
3.4	Public Notice and Comment
For generic variance petitions or site-specific variance petitions that have generic
applicability or effect, EPA will give public notice in the Federal Register of the intent to
approve or deny a petition and provide an opportunity for public comment1. Upon the written
request of any interested person or at the discretion of the Administrator, EPA may hold a public
hearing to consider oral comments on the proposed decision (public hearings are not normally a
routine step in the petition review process). Written requests for a hearing must state the issues
to be raised and explain why written comments will not suffice (40 CFR 260.20(d)).
RCRA does not preclude the option of granting variances to those site-specific petitions
that have no generic applicability or effect, through a "non-rulemaking" procedure (i.e., grant of
variance through an administrative process). In such cases, the vehicle for public notification will
be determined on a case-by-case basis. Public notification, however, will usually be through
existing public participation vehicles such as permit applications or modifications, or CERCLA
Remedial Investigation/Feasibility Study documents. In cases where such opportunities do not
exist, EPA will provide public notice through publication in local newspapers, by radio broadcast,
or by other media (53 FR 31200, August 17, 1988).
After the 30-day comment period, EPA will analyze all public comments received and
prepare a comment response document, a final background document (incorporating any changes
based on comments), and a final administrative record. These documents are then placed in the
public docket. For site-specific variances, EPA will usually provide for public notice and
comment (as a matter of public policy) prior to granting a non-rulemaking variance.
'EPA may also notify petitioners directly of its intent to deny a petition to allow the petitioner the opportunity to
withdraw the petition, thus avoiding a formal denial procedure.

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3.5	Notification of Final Decision
Notification of EPA's final decision on a petition for variance from the LDR treatment
standards will be published in the Federal Register as an amendment to the treatment standards
in 40 CFR 268 Subpart D if the variance is generic in nature. For determinations of equivalent
treatment and site-specific variances, the petitioner will be notified by mail.

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4.0 BIBLIOGRAPHY
U.S. Department of Energy. Environmental Guidance Division. Obtaining Variances from the
Treatment Standards of the RCRA Land Disposal Restrictions. Washington, D.C.: DOE, 1990.
U.S. Environmental Protection Agency. Office of Solid Waste. Treatment Technology
Background Document EPA, 1990.
U.S. Environmental Protection Agency. Office of Solid Waste. Final BP AT Background
Document for Quality Assurance/Quality Control Procedures and Methodology NTIS # PB-92-
149277, October, 1991.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Test
Methods for Evaluating Solid Waste (SW-846. Third Edition). Washington, D.C.: EPA, 1986.
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Appendix A: List of Applicable Regulations
40 CFR Part 2 - CBI Information
40 CFR Part 260.20 - Rulemaking Petitions
40 CFR Part 261 - Identification and Listing of Hazardous Waste
Subpart A - General
Subpart B - Criteria for Identifying the Characteristics of Hazardous Waste
and for Listing Hazardous Wastes
Subpart C - Characteristics of Hazardous Waste
Subpart D - List of Hazardous Wastes
Appendices
40 CFR Part 268 - Land Disposal Restrictions
Subpart A - General
Subpart B - Schedule for Land Disposal Prohibitions and Establishment of
Treatment Standards
Subpart C - Prohibition on Land Disposal
Subpart D - Treatment Standards
Subpart E - Prohibition on Storage
Appendices
A-l

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Appendix B: List of BDAT Background Documents
Include:
List of Waste-code specific Treatment Technology Background Documents
BDAT Background Document for Quality Assurance/Quality Control Procedures and
Methodology, U.S. EPA, October 23, 1991.
Guidebook for Quality Assuarance/Quality Control Procedures for Submission of Data for the
Land Disposal Restrictions Program, U.S. EPA, July 3, 1991.
(These Background Documents are available from: (1) the U.S. EPA RCRA Docket located at
Crystal Gateway One, 1235 Jefferson Davis Highway, First Floor, Arlington VA, 22202, (703)
603-9230; and (2) The National Technical Information Center (NTIS) located at 5285 Port Royal
Road, Springfield, Virginia 22161, telephone number (703) 487-4600.)
A-l

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