**Summary of Stakeholder Comments By Topic (Land Disposal Restrictions)**  Stakeholder: State of Wyoming Topic: Clarify requirements Comment: More clarification needs to be provided for hazardous waste generators concerning the **LDR requirements** and only those requirements addressing generators should be included. **Stakeholder: State of Michigan Topic: Reduced requirements for wastes treated**  **prior to disposal** Comment:

- LDRs need to be applied at the point where wastes are land disposed. Wast es directed for treatment, prior to land disposal, could have reduced requirements applied (40 CFR Part 268)

- The LDR for adding all applicable waste codes to the manifest should be eliminated

- LDR forms have served their usefulness and should be considered for modification or elimination Stakeholder: ESS Group Topic: Reduced requirements for wastes treated prior to disposal **Comment: 4**  **0 CFR 268.7**

. **For generators that are not directly land disposing their wastes, the requirements of 40 CFR 268**  **.7 are overly burdensome and provide little environmental benefit.**  Wastes not being sent directl y for land disposal by the generator of the waste are sent to facilities such as incinerators, wastewater treatment facilities, and, most commonly, to transfer facilities. Ty

picall y for treatment facilities, such as incinerators and wastewater treatment facilities, the waste from many generators is treated in succession or mixed together prior to treatment. Prior to land disposing of the ash, an incinerator must ensure the land disposal regulations are complied with. P rior to land disposing of wastewater treatment sludge, such a facility must ensure the land disposal regulations are complied with. Transfer facilities may send wastes to treatment facilities such a s those described above or to land disposal facilities. In many cases, new notifications for such transfers may be prepared. **We believe that the paperwork burden can be reduced with no increase in the potential for harm to the environment if the**  **requiremen t to prepare a land disposal notification is the responsibility of the company that**  **is sending the waste** directly for land disposal. Stakeholder: ESS Group Topic: Waste anal ys is plan Comment: 40 CFR 268.7(a)(5). **This section requires generators treati ng hazardous waste in**  **tanks and containers to meet treatment standards to prepare and implement a waste analysis plan**  . Many

generators treat hazardous waste in tanks that are part of a wastewater treatment sy stem and discharge the wastewater in compliance with wastewater discharge permits. Sludge from the s ys tems is properl y managed in accordance with applicable regulations. It would seem that such treatment requires the development and implementation of a waste anal ys is plan,however, since the discharge and management of the sludge is already regulated under other

regulations, there does not seem to be an environmental benefit to the development and implementation of the waste anal ys is plan. We suggest that this requirement be removed.
Stakeholder: ESS Group Topic: Managing a restricted waste

- one - time notice in the site’s files **Comment: 40 CFR 268.7(a)(7)** . Since the land disposal restrictions appl y at the point of generation, 40 CFR 268.7 requires that if a generator is managing a restricted waste that is excluded from the definition of solid or hazardous waste or is exempted under 40 CFR 261.2

- 261.6 subsequent to the point of generation, the generator must place a one - time notice in the site’s files. There is no environmental benefit to th is paperwork burden. We suggest that this requirement be removed. Stakeholder: ESS Group Topic: Managing a restricted waste

- one - time notice in the site’s files **Comment: 40 CFR 268.9(b)** . This requirement is confusing. Additional specific guidance for ty pical wastes generated from industrial facilities should be provided.
Stakeholder: P hRMA Topic: Remove the reference to 268.7(a)(5) entirely and rel y on 268.1(b) Comment: 262.34(a)(4) & 268

- The specific reference to 268.7(a)(5) contained in 262.34(a)(4), (d)(4), (g)(4)(v), & (j)(7) would make it appear that 268.7(a)(5) is the onl y provision of 268 that large and small quantity generators need to comply with, but 268.1(b) makes it clear that generators must comply

with essentially

all of part 268 unless otherwise noted. R eferring only to 268.7(a)(5) in 262.34 is somewhat misleading and could result in confusion. P hRMA recommends that EPA either remove the reference to 268.7(a)(5) entirel y and rely on 268.1(b), or make it clearer in 262.34 that generators must also comply with part 268 unless otherwise noted.
Stakeholder: State of Florida Topic: LDR regulations are especiall y difficult to understand Comment: LDRS: Part 268. LDR regulations are especiall y difficult to understand, and includ e obsolete date references. Newl y re gulated wastes should be addressed in a separate section. FDEP requests an extension of time to submit specific suggestions for revising Part 268.
Stakeholder: Graphic Arts Coalition (GAC) Topic: Eliminate LDR form

Comment: T here has been considerable change to the Land Disposal Restriction formrequirements and clarification as to when they are needed and when are they not required. Since the land ban has been in effect for quite some time, the need to use the form has expired and GAC strongl y recommends that EPA eliminate the need for it. Stakeholder: Department of Energy Topic: LDR paperwork Comment: 1. DOE laboratory facilities generate many

different chemicals with many LDR treatment standard waste codes. Anumber of these waste streams consist of a pure, unused, excess chemical (not a manufactured product) that has been characterized and c ontainerized properl y for the applicable hazards. T hey are not bottles containing mixtures of waste chemicals, contaminated soil, or lab packs. F or these latter waste streams, the LDR notification requirements in 40 CFR 268.7(a) allow generators to send a one - time notice with the initial shipment to a TSDF. In the case of pure chemicals, however, a notice must be sent with each shipment of a different chemical. b y the EPA did not alleviate this paperwork burden. **As a result, DOE laboratory facilities,**  **as well as other research laboratories that generate small volumes of multiple waste types, incur a much greater LDR paperwork burden than**  **industries generating uniform, large -**  **volume waste streams. F**  **urthermore, the LDR paperwork reductions already impleme**  **nted** To address the continuing LDR paperwork burden experienced b y laboratories, DOE requests that the EPA consider designating pure, unused, excess chemicals as a single “waste stream” for purposes of LDR notification requirements. T his waste s tream would consist of pure chemicals, potentially including those having waste codes D001 through D043, F027, and any P

- or U

- code. D OE further requests that a one

- time, LDR notice to receiving TSDFs be allowed for the pure chemicals waste stream. T his notice should identify waste codes for all of the pure chemicals that the generator expects to send to the TSDF as part of the pure chemicals waste stream. T hereafter, an y p ure chemical included in the original notice could be sent to the TSDF without for warding an additional notice with each shipment. Asubsequent notice should be required only if new pure chemicals are expected to be sent. It should be noted that this comment addresses onl y LDR notification requirements. D OE recognizes that a hazardous waste manifest would still be required to accompany each waste shipment. 7 commenters; 10 comments