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:Addressing Land Disposal Restrictions in particular waste is more difficult to treat than the ' eiotreatrnent waste on which the standard was based.There are (Continued from page 2) two kinds of treatability variances: (1) variances with generic applicability, which apply to a spe- meaning the waste must be treated until a certain cific waste at any site, and (2) site-specific vari- concentration of hazardous constituents is attained. antes, which apply only to a particular waste at a Other wastes have technology-bated standards for specific site. For more information on site-spe- situations in which there is no analytical method. cific variances, refer to Regional Guide:Issuing Site- I*hrrr nw, i I w w;i5tr,imi o I)i, tri•.it rt;Iin 1114,t h- Slrr'rrfic 7i-olialulittl I'llriorrr'r'sfeu ['rrrrfu�ttitrrtr4.11 aril: ods, deemed Best Demonstrated Available and Debris from Land Disposal Restrictions (LDRs) Technologies (BDATs). If biotreatment cannot per- (Office of Solid Waste and Emergency Response form adequately for a waste with a concentration- based standard, a variance must be obtained or an [OSWER] Directive 9380.3-0$FS), which can be ordered by calling the RCRA/Superfund Hotline alternative technology substituted. at 800-424-9346 or 703-920-9810 in the Washing- Contaminated Debris ton, DC area. The LDR Contaminated Debris Rule defines hazard- No-migration petitions are granted if an appli- ous debris as any solid material intended for discard cant can demonstrate that hazardous waste that is contarninated with hazardous waste or that exhibits one or more of the hazardous waste charac- will not migrate from the place of disposal for teristics. To be classified as debris, the solid material as long as the waste remains hazardous. These must have a particle size in excess of 60 mrn (2.5 in.) petitions may be especially useful for biotreat- and be a manufactured ob)ect, plant or animal mat- ers considering land treatment, in which soil is ter, or natural geologic material. treated and left in place. For more information In the past, contaminated debris was subject to the on no-migration petitions for RCRA sites, see concentration-based treatment standard for the par- Variances to the Hazardous Waste Land Disposal titular waste with which the debris was contami- Prohibitions: .4 Guidance for Petitioners. For more nated. Adhering to this standard is still acceptable, information on no-migration petitions for Super- but the new rule adds the option to treat hazardous fund sites, refer to OSWER Directive 9347.3-1 OFS, debris With one or more BDATs specified for each which also can be ordered by calling the debris/contaminant combination. These tethnolo- RCRA/Superfund Hotline. gies are divided into extraction, immobilization,and destruction technologies. Biodegradation is identi- o The concept of the correctize action nrnnagerrrent fieri as a destruction technology for several types of unit (CAMU) was established by the proposed hazardous debris, including debris contaminated Subpart S under RCRA for corrective action. This with most common organic compounds, concept allows RCRA sites to treat wastes and Contaminated Soil contaminated soils within the CAMU without Phase 2 of the rule, LDRs for Newlv Listed. Waste triggering the LDRs. The CAMU portion of Sub- and Contaminated Soil, is scheduled for proposal in part S is scheduled for promulgation in Decem- Fall of 1992 and promulgation in Spring of 1993. ber 1992. For more information on CAMU These kvill be published in the Federal Register. Bio re- exemptions, refer to the Federal Register (55 FR mediation is a possible BDAT standard for contami- 30789). nated soil,so EPA encourages biotreaters in the field to evaluate the proposed rule and comment accord- • An LDR BDAT exemption for ground-wafer reinjec- ingly. Until new treatment standards for contami- tion is available. This exemption will be useful for nated soils are promulgated, however, biotreaters RCRA and CERCLA bioremediation sites where must comply with current LDRs, obtain a treatabil- ground water is pumped to the surface to be itv variance, or apply for a no-migration petition amended, then reinjected. For more information from LDR standards. on reinjection exemptions, refer to OSWER Direc- Compliance Alternatives tive 9234.1-06. Alternatives to compliance with the LDRs are avail- For more information, contact Michael Forlini of able to biotreaters: OSWER's Technology Innovation Office at 703-308- Treatability variances to concentration-based treat- 8825, or call the RCRA/Superfund Hotline at 800-424- ment standards are available in the event that a 9346 or 703-920-9810 in the Washington, DC area. 8