United States
             Environmental Protection
             Agency
Office of
Solid Waste
EPA/53CKBW-84-012
October 1984
             Solid Warn
oEPA      Waste Analysis Plans
             A Guidance Manual
                                                  m

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This report has been reviewed by the Offfice of Solid Waste,
U.S. Environmental Protection Agency, and approved for publication.
Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

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                   WASTE ANALYSIS PLANS

                    A Guidance Manual
  This publication (EPA/530-SW-84-012)  was prepared for
the Office of Solid under contract no.  68-03-3149-1-3 and
      is reproduced as received from the contractor.
           U.S.  ENVIRONMENTAL PROTECTION AGENCY
                           1984

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                                 CONTENTS



   1.  Introduction to Manual  	       1

   2.  Regulatory Requirements   	       2

   3.  Preparing a Waste Analysis  Plan   	       3

   4.  Checklists for Writing or Reviewing  Waste  Analysis  Plans  ....      15

References	      24


Appendices

   A.  40 CFR 264.13 General Waste Analysis  	    A- 1

   B.  Example Waste Analysis Plans  	    B- 1

       Container Storage

       Tank Storage


       Surface Impoundment

       Waste Pile

       Land Treatment

       Inci neration

       Chemica^l  Treatment
                 ,  ' .*.,,-
       Landfill         ' .''."'

       References                   .  

   C.  How to Use a Random  Numbers Table for Waste  Sampling	    C- 1

   D.  Drummed Wastes - Estimating Sampling  Size   	    0-1

   E.  A Ranking Exercise to Select  Frequency of  Waste
       Recharacterizations   	    E- 1

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                                  TABLES
Number                                                                  Page

 4-1     Waste Analysis Plan Checklist - General  Information 	   16

 4-2     Waste Analysis Plan Checklist - Specific Hazardous
         Waste Management Process	   19

 4-3     Optional  Items to Consider When Preparing a Waste
         Analysis  Plan	   22

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                               ACKNOWLEDGEMENTS
     This manual  was written by Marion Deerhake and  Carrie Kingsbury of the
Research Triangle Institute under Contract  Number 68-03-3149-1-3 from the
U.S. Environmental  Protection Agency,  Office of Solid  Waste,  Washington, D.C.
Dr. Alan Senzel  also assisted in collecting data and preparing the initial
draft report.

     The authors  wish to thank the Office of Solid Waste and  EPA Regional
Offices for their participation in the preparation of  this manual.  In
particular, Mr.  David Friedman, EPA Technical  Project  Monitor, has contributed
significantly throughout the development of this manual.

     Critical reviews of the draft by  representatives  of industry and
government were  especially helpful.
                                   iv

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                          1.  INTRODUCTION TO MANUAL
     The Resource Conservation and Recovery Act (RCRA) was passed by Congress
to assure the proper treatment, storage, and disposal of hazardous wastes.  As
a result of this Act, RCRA permits are required for hazardous waste management
facilities.  Such permits are issued to those management facilities that can
demonstrate an ability to safely and effectively manage specific hazardous
wastes or waste categories.  The EPA document "Permit Applicants' Guidance
Manual for the General Facility Standards of 40 CFR 264" (SW-968) provides
general guidance on preparing the various sections of a RCRA Part B permit
application.

     An important aspect of hazardous waste management is the process by which
the information needed to manage the wastes is obtained.  One of the
requirements of the Federal regulations is that this process be set forth in a
waste analysis plan and submitted as part of the RCRA permit application.  The
waste analysis plan should describe how one decides what information is
needed, the nature and extent of the information needed, and the method by
which the information will be gathered.

     The purpose of this manual  is to provide guidance to both permit
applicants and reviewers/writers on how to prepare and evaluate waste analysis
plans.  This manual  provides

          an explanation of the RCRA regulations that require a
          waste analysis plan,

          a discussion of the purpose and objectives of a waste
          analysis plan and a recommended approach for preparing a
          plan,

          checklists to assist the preparer/reviewer in
          assuring that the analysis plan is complete, and

          example waste analysis plans for various hazardous
          waste management scenarios.

By following the guidance in this manual, a permit applicant should be able to
develop a waste analysis plan that satisfies the intent of the regulations and
that can be reviewed easily by the permitting official.

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                         2.  REGULATORY REQUIREMENTS
     Title 40 of the Code of Federal Regulations,  Part  264.13  establishes  the
requirement for a waste analysis plan and describes the  information  that  is
required in such a plan (see Appendix A). These  regulations  are  applicable to
all types of hazardous waste management facilities.   In  addition  to  the  above
general requirements, management-specific requirements  are described in  the
following sections of the regulations:
     40 CFR 264.170 to 264.178
     40 CFR 264.190 to 264.199
     40 CFR 264.220 to 264.230
     40 CFR 264.250 to 264.258
     40 CFR 264.270 to 264.282
     40 CFR 264.300 to 264.316
     40 CFR 264.340 to 264.351
     40 CFR 265.370 to 265.382
     40 CFR 265.400 to 265.406
                                     Containers  (Subpart  I)
                                     Tanks  (Subpart  J)
                                     Surface  Impoundments  (Subpart  K)
                                     Waste  Piles  (Subpart  L)
                                     Land Treatment  (Subpart  M)
                                     Landfills  (Subpart  N)
                                     Incinerators  (Subpart  0)
                                     Thermal  Treatment  (Subpart  P)
                                     Chemical, Physical,  and  Biological
                                       Treatment  (Subpart  Q)
     The waste analysis plan regulations distinguish between  two  types  of
hazardous waste management facilities:

         Onsite facilitythe facility that manages only those  hazardous
         wastes that are generated on its own geographic site (see  40  CFR
         260.10 for more information), and

                                                                   hazardous
         Offsite facilitythe facility that  receives  and manages
         wastes that are generated outside the site  in question.

Certain parts of the waste analysis plan  requirements  pertain  to  all  hazardous
waste management facilities while others  apply only  to offsite  facilities.

     While the regulations governing waste analysis  plans are  extensive  and
complex, their objectives are simple.  These  are

     1.  to ensure that sufficient information is available  to  determine
         whether the wastes considered for management  at a hazardous  waste
         management facility fall within  the  scope of  the facility's  permit,

         and

     2.  to ensure that the facility has  sufficient  information about the
         wastes to properly manage the wastes once they are  accepted.

     To comply with the regulations, each waste analysis plan  must  address  the
procedures that will  be followed to accomplish these objectives.

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                       3.  PREPARING A WASTE ANALYSIS PLAN


 3.1 OBJECTIVE AND PURPOSE OF PLAN

      The objective of a waste analysis plan is to describe the  procedures  that
 will  be undertaken to obtain sufficient waste information to operate a
 hazardous waste management facility in accordance with its permit  (i.e., to
 ensure that wastes accepted by the facility fall within the scope  of the
 facility's permit, and that the process performance standards are  met). The
 waste analysis plan establishes the hazardous waste sampling and analysis
 procedures that will  be routinely conducted as a requirement of the RCRA
 permit.  If the plan  is followed properly, any waste-related discrepancies
 with  the permitted management activities will  be identified before waste
 management begins.  These objectives are the same for both onsite  and offsite
 facilities.  However, the Agency believes that a waste generator owned and
 operated facility will  tend to know more about the waste generation process
 than  would a facility not owned and operated by the waste's generator.  Thus,
 offsite facilities are required by the regulations to conduct more frequent
 checks on wastes than onsite facilities.

      A waste analysis plan should demonstrate to EPA or State permitting
 officials that the facility owner/operator knows what information  is needed to
 operate the facility  properly and has  in place a program to gather the
 necessary information.   Once the plan  is approved, it will  serve as an
 operating plan for waste sampling and  analysis.


 3.2 CONTENT AND ORGANIZATION

      The RCRA regulations do not require a specific format  for the waste
 analysis plan.   For ease oT~review,  however,  the plan should be organized to
 present the reviewer  with the required information in a logical  manner.
 Applicants  may  thus want to organize the application in such a manner that the
 description  of  the facility or  process to  be  permitted  is  clearly identified.
 Sufficiently  detailed information  will  be  needed by the permit application
 reviewer to  judge  the degree  to which  the  plan  addresses  the following
 questions.

 I.  What  are  the  specific  wastes  or types  of wastes that  will  be managed
 within  each  process?

 II.   What are  the  waste-associated  properties  that  are  of concern  in  ensuring
 safe  and  effective management  (e.g., kcal/g  (Btu)  content,  % water)?

 III.  What are  the specific waste  parameters that  have  to be  quantified  in
order to  satisfy the  data  needs?

 IV.  How will the  necessary data be obtained,  including what  sampling  and
analysis procedures,  and what attendant  quality  control/quality  assurance
procedures are  to  be  carried  out by the  permitee?

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     It is recommended that a waste analysis plan be organized  based  on  these
four questions.  The plan's organization should  be keyed  to  the
decision/review process, presenting the logical  approach  and decision tree
used by the permit applicant in arriving at  answers to each  data  need
question.  It should be designed to lead the reviewer through the thought
process employed by the applicant.

     Usually other portions of the  RCRA permit  application will contain  an
indepth description of the facility and the  processes to  be  permitted.   Those
sections will establish the types and the characteristics of wastes to be
managed and any process constraints.  The waste  analysis  plan should  reference
these other sections of the application, and it  is suggested that the
applicant summarize those points that are particularly germane  to the plan  in
order to assist the reviewer and user.
3.3  ABBREVIATED EXAMPLE PLAN

     In order to illustrate how the above questions  might  be addressed  in  a
logical, easy to understand manner, an abbreviated example of portions  of  a
waste analysis plan follows.  This example is not intended to represent an
actual  facility plan.  Examples of representative plans  for various  types  of
facilities are presented in Appendix B.

     The sections of the example plan that follow the Facility Description are
written from the perspective of an applicant and  discuss areas that  would  have
to be addressed in any waste analysis plan.


                            Facility Description

     An offsite facility requesting a RCRA permit for its  hazardous  waste
incinerator will be assumed in this example.  The facility would receive
wastes in both drums and tank trucks and would store the waste in either the
receiving drums or in large blending tanks until  sufficient waste was on-hand
for an incinerator run.

     A permit is being requested for a facility which would be allowed  to  burn
liquid wastes containing up to 5 percent organochlorine  content, as  long as
the wastes accepted contain PCBs at <50 ppm, dioxin at <1  ppb, or chromium at
<5 ppm.


                   Identification of Wastes  to be Managed

      Issues to be Addressed                            Response

What wastes do we want a permit           Liquid  wastes  or wastes that  can
to manage?                                  be made pumpable by blending or
                                            heating.

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What wastes can we not handle
and thus need to be prevented
from being accepted?
PCB-containing materials (>50 ppm),
Dioxin-containi ng materials
(>1 ppb chlorinated dioxins).
Chromium wastes (>5 ppm Cr).
                           Process Tolerance Limits
What waste properties do we need to
be concerned with to ensure that
the incinerator operates within the
permit envelope?
Constituents in the incinerator
  waste feed must have heats of
  combustion of at least 4.44 kcal/g
  (8,000 Btu/lb). This value is
  based on the heating value of the
  POHC used in the trial burn test.

Feed to the incinerator must be a
  liquid with less than 85% water
  to maintain burning efficiency.

Waste feed must have less than 5%
  organochlorine and an ash content
  of less than 40% to comply with
  emissions standards.
                      Waste Parameters to be Monitored
What parameters will be measured to
ensure that the above properties are
mai ntai ned?
How will  we avoid accepting wastes
which are outside the facility's
permit?
Heat of combustion
Viscosity
Water content
Ash content
Organochlorine content
EP metals content
Compatibility with materials of
  construction.
Compatibility with other wastes that
  it may contact.

[Applicant should also include
  rationale for selection of each
  parameter.]

Prior to agreeing to accept waste
  from a generator, the client
  will be required to submit the
  following information about the
  waste, including ranges for each
  property to be expected in routine
  production:

Heat of combustion
Vi scosity

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How will incoming shipments be
screened to ensure that they are as
manifested and are ones that we have
agreed to accept?
Water content
Ash content
Reactivity
Ignitability (flash point)
Corrosivity
Acidity or alkalinity
EP metals concentrations
Major inorganic constituents
Total organic carbon
Major organic constituents
  and their heats of combustion
PCB
Dioxin
Instability properties

If any of the properties fall
  outside of the acceptable
  characteristics described under
  "Wastes To Be Managed,"
  the waste would be refused.

For those wastes provisionally
  accepted, the client would be
  required to submit and certify a
  representative sample of the
  waste(s).  This sample will  be
  analyzed by XYZ Laboratory to
  confirm the data submitted by the
  client.

If the properties are within our
  specifications, the waste would be
  deemed acceptable for treatment.

[Applicant should indicate frequency
  of recharacterizing generator's
  wastes.]

A series of fingerprint properties
  characteristic of each waste would
  be selected,  and used to screen
  each incoming shipment before the
  waste is accepted at the facility.

If the fingerprint analysis finds an
  unacceptable  discrepancy, the waste
  will be analyzed further and either
  returned to the client or sent to a
  facility permitted to accept such
  wastes.

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    Waste Sampling, Analysis, and Quality Assurance/Quality  Control  Procedures
How will the wastes be sampled to
ensure representativeness of
samples tested?
                                          Since only  liquid  wastes  are  to
                                            be accepted,  drums  will  be  sampled
                                            using a Coliwasa  device.

                                          Drums will  be  sampled depending  on
                                            the number of drums in  each lot
                                            received. The number of drums
                                            sampled will  be  based on  the
                                            cubed root equation.  [See
                                            Appendices C  and  D  of this  manual
                                            for further  information.]

                                          If out of specification drums are
                                            found, all remaining drums  in  that
                                            shipment  will  be  sampled  prior to
                                            acceptance.

                                          Each tank truck will  be sampled
                                            using a Coliwasa  if a suitable
                                            sampling  port is  available.  If
                                            such a port  is unavailable, the
                                            waste will be pumped into a
                                            holding tank  and  a  composite
                                            sample collected  during pumping.
What specific test methods will be
used to measure each parameter?
                                          Heat of combustion  -  ASTM1  D240
                                          Viscosity  -  ASTM  01824
                                          Water content  - ASTM  095
                                          Ash Content  -  APHA2 209E
                                          Reactivity - SW-8463  Section  2.1.3
                                          Ignitability - SW-846  1010/1020
                                          Corrosivity  -  SW-846  1110  and/or  9040
                                          EP metals  -  SW-846
                                            Arsenic  -  7060
                                            Barium - 7081
                                            Cadmium  -  7131
                                            Chromium (VI) - 7195
                                            Lead - 7421
                                            Mercury  -  7470
                                            Selenium - 7740
                                            Silver - 7761
                                          Major inorganic constituents  -  SW-846
                                            6010
lASTM  American Society for Testing and Materials.
       Am^-;^,CT o,.ki-io u,n-h Association  Standard Methods  for  the  Examination
2APHA  American Public Health
 of Water and Wastewater 1980.
3SW-846"Test Methods for Evaluating
                                      Solid Waste"  July  1982.

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What quality assurance/quality control
procedures will be followed for
sampling and analysis?
Total organic carbon - APHA 505
Major organic constituents - SW-846
  8010-8150 (based on suspected
  constituents)
PCB - SW-846 8080
Dioxin - SW-846 8280
Instability properties - Dupont OTA
  [Method would be described in
  an appendix]

Quarterly review of staff skills in
  sampling and analysis.
Maintaining a field log of samples
  taken.
Labeling samples.
Following SW-846 QA/QC procedures
  for each test method.
Inspection and maintenance of
  sampling and analytical  equipment.
Documentation and filing of all
  sampling and analysis information.
3.4  DISCUSSION OF THE PLAN INFORMATION NEEDS

Facility Description

     Before the reviewer can evaluate the adequacy of the proposed testing,  the
permit applicant needs to identify the waste management processes  that  operate
at the facility.  Enough information is needed concerning what  wastes  can and
cannot be properly managed by their facility so that the application reviewer
can judge whether the testing proposed is adequate.

     While this information will  generally be exhaustively described and
discussed in other sections of the permit application, it would be useful  to
include a summary of this information in the waste analysis plan since  the plan
may later serve as an operating manual during facility operation.   In  addition,
it is helpful  to application reviewers to have a waste analysis plan that
stands alone.
Identification of Wastes to Be Managed

     This section of the plan should include--

          a list of the wastes or waste types  that the applicant  wants  to  be
          permitted to manage in each process  operating at  the  facility,

          a list of any wastes known not to be manageable,  and

          known waste properties which, if exhibited  by the waste,  would
          preclude the waste's acceptance at the facility.

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This information is necessary to evaluate the adequacy of the proposed  testing
program.  If the applicant chooses, the information may be placed  in other
parts of the permit application.  However, incorporation of this  information  in
the waste analysis plan will  make the application easier to review and  also
allow the plan to stand alone and be used as an operating manual.

     Before conducting extensive testing to determine the waste properties that
might be acceptable for management at a given type of facility, the applicant
may want to refer to EPA background documents or other sources on  the specific
waste or management process of interest.  In addition to EPA background
documents, other sources of information include published scientific or
engineering literature; data from trial tests and waste analyses;  and previous
experiences.  For example, 40 CFR Part 261, Appendix VII enumerates major
hazardous constituents in each RCRA listed waste.  "A Method for  Determining
the Compatibility of Hazardous Wastes" (EPA-600/2-80-076) provides helpful
information on compatibility of chemical classes and their relation to
industry. This supplemental information may help identify what waste
information should be obtained by analysis and what analytical  methods  to  use.

     At this point it is appropriate to introduce the "boundary condition"
concept that will be used in the example waste analysis plans in  Appendix  B.
Boundary conditions are the maximum and minimum values of waste properties
which, if exceeded, would alert the operator that the waste does  not meet  its
typical properties and requires further attention before acceptance.


Process Tolerance Limits

     A second concept that will be used in the example plans is that of
"tolerance limits."  Tolerance limits represent those characteristics of a
waste or waste mixture that a waste management process can handle  while
maintaining permit compliance.  These limits can be quantitative  or
qualitative.  The tolerance limits are generally linked to the performance
goals of the waste management process.  The waste analysis plan should  address
these tolerance limits and describe the rationale for their selection.

     Tolerance limits may thus be based on considerations of

          the efficiency at which the process is designed to operate (e.g.,
          99.99% destruction and removal efficiency for incineration),  and

          potential incompatabilities between new wastes and the  process raw
          materials, structure, and currently managed wastes.

     Questions that might need to be answered about process limitations are,
for example--

          How much supplemental fuel will have to be blended with  the
          waste for proper incinerator operation?

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          How much lime needs to be added  for  proper  neutralization?

          What storage tank construction materials  are  compatible with
          the waste?

          What pretreatment if any is  needed before waste  management
          processing?


Waste Parameters to be Monitored

     This section addresses

          waste parameters to be analyzed  for  characterization  and  the
          rationales for parameters selected,

          frequency of recharacterization,  and

          waste shipment screening and key  ("fingerprint")  parameters for
          screening.


     Waste Characterization

     Waste parameters must be selected to  represent those  characteristics
necessary to manage the waste in compliance with  permit conditions.  The
rationale for selecting each parameter, addressing  how  well  the parameter
represents the information needed for  compliance,  should be described in the
waste analysis plan.

     Waste analysis parameters should  be selected  after 1)  reviewing existing
information on the waste properties (e.g.,  40  CKR  261 Appendix  VII, EPA  listing
and delisting background documents, process engineering studies,  industry
association waste characterization studies), 2)  noting  what properties best
indicate any change in a waste's composition,  and  3)  comparing  this information
to the facility's design criteria and, if  appropriate,  trial  treatment test
results.

     Waste analysis plans need to include  procedures  for complying  with  the
specific waste management requirements described  in 40  CFR 264.17 and 264.341.
40 CFR 264.17 addresses three waste parameters:   ignitability,  reactivity, and
incompatibility. Incompatible wastes,  if brought  together,  could  result  in heat
generation, toxic gas generation, and/or explosions.  A waste analysis plan
must therefore address measures to identify potentially ignitable,  reactive,
and incompatible wastes.  Standard tests to identify  ignitable  wastes can be
found in Section 2.1.1 of "Test Methods for Evaluating  Solid  Waste"  (SW-846).
Reactive wastes are also defined in this document,  although standard tests are
not yet available to measure the reactivity of all  wastes.   Waste compatibility
                                      10

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experiments can serve to establish compatibility  between  wastes  of  interest  for
a given process.  An EPA document, "A Method  for  Determining  the Compatibility
of Hazardous Wastes" (EPA-600/2-80-076), contains  procedures  to  evaluate
qualitatively the compatibility  of various  categories  of  waste.   Standard
compatibility tests have not  been published to  date  by  EPA.

     40 CFR 264.341 addresses waste  information required  for  incineration
facilities.  Waste analysis plans for incineration facilities  should  include
routine analyses of waste parameters that are required  as  a  result  of a trial
burn.  Trial burns (or comparable information)  are required  before  such a
facility is permitted to operate.  A "trial burn  plan," required for  these test
runs, includes analyzing each hazardous waste to  be  incinerated  for certain
hazardous constitutents listed in 40 CFR 261, Appendix  VIII  (i.e.,  Principal
Organic Hazardous Constituents (POHCs). The analytical  data  serve as  references
for measuring incineration performance.  A  comparison  of  hazardous  waste
constitutent concentrations before incineration to the  levels  emitted from the
incinerator allows the calculation of the destruction  and  removal efficiency.
This information provides a measure  of how  efficiently  the facility is
destroying and removing the hazardous waste.  Additional  information
requirements for specific hazardous  waste management processes can  be found  in
Section 4, "Checklists for Writing or Reviewing Waste  Analysis Plans." EPA's
"Guidance Manual for Hazardous Waste Incinerator  Permits"  (SW-966)  also
elaborates on waste analyses  and trial burns.   However, to obtain information
on current EPA test methods,  refer to SW-846.


     Recharacteri zation

     Since consistent performance in a hazardous  waste  management process  is
important, hazardous wastes may  need to be  characterized  periodically in more
detail  than is involved in "fingerprint analysis"  (analyzing  for a  few key
parameters). Such detailed analysis  (recharacterization)  serves  to  detect  any
changes in the concentrations of chemical constituents, the  appearance of  new
constituents, or variations in physical properties.  An owner  or operator  must
recharacterize a waste when its  generation  source  has  changed  in order to
identify any changes in waste characteristics.  Such  a  change  in  generation
sources may result from engineering modifications  or from  malfunctions/changes
in operation.  While the generator should notify  the waste management facility
operator of such occurrences, the owner/operator,  particularly for  an offsite
facility, should set up a program to look for waste  changes  that may  occur even
without any notification from the generator.  Appendix  E  of  this manual
presents a method for selecting  the  frequency of  waste  recharacterization.   It
is aimed at offsite facilities but can be easily  modified  for  use by  onsite
facilities.
     Shipment Screening

     Offsite hazardous waste management facilities are  required  by  40  CFR
264.13 to comply with additional regulations that help  minimize  the  potential
for incorrectly identified and unacceptable waste shipments  being handled.   The
offsite facility waste analysis plan must specify the waste  analysis data  that
                                      11

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the generator of the waste  provides.   It  is  important  that  the  plan
describe the procedures to  be taken  by  the facility  owner/operator  in  order to
determine  how well the generator's data  represents the waste  to be  managed.

     Since the  owner/operator of  the  offsite  facility  is  not  able to monitor
waste  generation operations  daily, the  exact  waste characteristics  of  each
shipment will not  be known.  Hence,  an  offsite  facility must, at a  minimum,
visually inspect and compare the  contents of  each shipment  to the accompanying
manifest to identify the waste.   The  shipment is sampled  and  analyzed  only to
the extent necessary to verify that  it  meets  permit  waste specifications
(fingerprint analysis). An  owner  or  operator  must recharacterize a  waste  when
a  shipment does not match the manifest  description.  Shipment screenings  may
also be necessary  for onsite facilities  particularly when the facility
receives a variety of wastes. The level  of screening to be  required  for an
onsite facility is a function of  the  facility operator's  knowledge  about  the
generation process.

     Typically, waste shipments are  sampled  and analyzed  for  a  few  key
chemical and physical parameters.  These  key  parameters are selected  from the
initial waste characterization parameters measured before the owner/operator
agrees to  handle the generator's  waste.   The  parameters should  reflect
characteristics that substantiate the waste  composition as  described  in the
RCRA permit.  Criteria that  one might consider when  selecting key parameters
are:

          the need to identify restricted wastes,

          parameters representative  of  the incinerator's  chemical/physical
          design criteria and performance,

          the potential ignitability, reactivity, or incompatibility  of the
          wastes, and

          parameters that best indicate  changes in waste  characteristics.

     While fingerprint parameters are often a subset of characterization
parameters, this may not always be the  case.  For example,  one  may  use
screening tests to detect constituents  that are not  normally  present  in the
waste even though the tests  do not identify the specific  contaminant.   The
Agency does not currently have an approved set of test procedures for  such
purposes.  However, reference might  be made to  "Test Methods  for Evaluating
Solid Waste" (SW-846) and "Design and Development of a Hazardous Waste
Reactivity Testing Protocol" (EPA-600/52-84-057) for suggested  fingerprint
analysis procedures.

     Selecting a few key parameters  for analysis of  each  shipment
("fingerprinting") expedites waste characterization, which  is important because
of the time and labor involved in receiving shipments.  The test methods  for
these key parameters are based on the initial waste  characterization test
methods which are described  in "Test Methods  for Evaluating Solid Waste"
(SW-846) and other EPA publications.  Any changes in waste  characteristics that
could affect the performance of the  hazardous waste  management  process should
be detectable by conducting these tests.
                                      12

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Waste Sampling, Analysis, and Quality Assurance/Quality Control Procedures

     This section of the plan includes--

          waste sampling procedures,

          waste analysis methods, and

          their related quality assurance/quality control procedures.

     Appendix I of 40 CFR Part 261, Representative Sampling Methods,  describes
standard sampling methods developed by the American Society for Testing  and
Materials (ASTM) and others that can be used when sampling hazardous  waste.
Discussions on representative sampling and descriptions of sampling devices
are also available in the EPA document "Test Methods for  Evaluating Solid
Waste" (SW-846).  Appendix C of this manual addresses  random  sampling  and
demonstrates how to use a random numbers table for waste  sampling.  Appendix  D
contains the ASTM method for estimating the number of  containers to sample.
The permit applicant should contact the application reviewer  if he or  she  is
uncertain about how to estimate the number of samples  to  take.  If wastes
cannot be sampled by the standardized methods and approved devices, the
applicant must develop a suitable sampling method and  include  a detailed
description and rationale for the method in the waste  analysis plan.

     Test methods for selected waste characterization  parameters have  been
standardized by EPA.  These EPA-approved methods are described in detail  in
EPA's "Test Methods for Evaluating Solid Waste" (SW-846).  This document is a
compilation of analytical methods that have been approved by  EPA for  use in
the RCRA program.  SW-846 methods for determining various parameters  are
accepted by EPA without further justification by the generator or facility
owner/operator.

     EPA continually updates SW-846 to provide additional or  improved  test
methods.  Sometimes, however, it may be appropriate to employ  a special  test
method that has not been approved by EPA.  If such a method is proposed  for a
particular analysis, approval must be received from EPA prior  to its  inclusion
in the waste analysis plans.

     40 CFR Part 261, Appendix III, Chemical Analysis  Test Methods, is another
useful source of methods. This appendix lists analytical  procedures for
determining if a waste contains a specific toxic element  or compound.  It
contains three tables of information on analyzing for  toxic waste
constituents - Tables 1 and 2 list analytical methods  for specific organic and
inorganic constituents, respectively, and Table 3 lists ways  to prepare
samples and introduce them into a system for analysis.

     40 CFR 270.30, "Conditions applicable to all permits," addresses  quality
assurance in paragraph (e), "Proper operation and maintenance."  It states
                                      13

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           "Proper operation and maintenance includes effective
           performance, adequate funding, adequate operator
           staffing and training, and adequate laboratory and
           process controls, including appropriate quality
           assurance procedures."

This quote is the extent of regulatory requirements for quality  assurance  and
quality control.  Further information, however, may be found in  Section  10 of
"Test Methods for Evaluating Solid Waste" (SW-846).  An adequate quality
control/quality assurance assurance program must address all of  the  technical
aspects of such a program described in Section 10 of SW-846.  Appendix B
contains example waste analysis plans for various hazardous waste management
scenarios.  These examples should be reviewed to gain insight as to  an
appropriate level of detail  for a quality assurance/quality control  program for
various levels of hazardous waste management facilities.  As shown in the
examples, quality assurance/quality control  programs may be presented best as
an appendix to a waste analysis plan.

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           4.  CHECKLISTS FOR WRITING OR REVIEWING WASTE ANALYSIS PLANS
     This section presents "checklists" of information needed in a waste
analysis plan.  These checklists are intended to help agency permit writers to
review permit applications more expeditiously and uniformly.  They are also
useful to permit applicants as a convenient check to make sure the application
contains the necessary information.  The checklists address the items that are
required in a "complete" plan as well as additional items which, if present,
will make the plan more useful and assist the reviewer in evaluating the
application.  The checklists are designed to allow one to check off if an item
is or is not properly addressed.  By properly addressing the checklist items,
an applicant can minimize the chances of submitting an incomplete application.
For the convenience of the user, the checklist items not required by the
regulations are footnoted.

     Table 4-1, "Waste Analysis Plan Checklist- General  Information," applies
to all hazardous waste management facilities.  The checklist can be used
regardless of the specific hazardous waste management process(es) operated at
the facility.  It is divided into five major categories:

          Facility Description

          Identification of Wastes to be Managed

          Process Tolerance Limits

          Waste Parameters to Be Monitored

          Waste Sampling, Analysis, and Quality Assurance/
          Quality Control (QA/QC) Procedures.

These five categories correspond to the example provided in Section 3.3,
"Abbreviated Example Plan."  Applicable RCRA regulations are cited within the
checklist.

     Table 4-2, "Waste Analysis Plan Checklist - Specific Hazardous Waste
Management Process," presents additional  checklist items specific to
particular hazardous waste management processes.  These  checklists include
information items that are required in addition to the general  checklist
information.  They are based on 40 CFR 264, 265 (thermal, chemical, physical,
and biological  treatment), and 270 information requirements.  Only those
portions dealing with the specific process will  be applicable to a given
facility's waste analysis plan.

     Table 4-3, "Optional Items to Consider When Preparing A Waste Analysis
Plan," contains information that is not specifically required under RCRA.
However, this information may contribute to a more complete waste analysis
plan, making it more useful  to operators on a day-to-day basis.   Permit
reviewers should use this table with discretion when reviewing  waste analysis
plans since the regulations do not require this material.
                                      15

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       TABLE 4-1.  WASTE ANALYSIS PLAN CHECKLIST - GENERAL INFORMATION


I.   FACILTIY DESCRIPTION1

     a.  Are all  hazardous waste management processes identified?	yes 	no
     b.  Is sufficient information provided for each process to
         confirm that the wastes can be properly managed at the
         facility?                                                	yes 	no

II.   IDENTIFICATION OF WASTES TO BE MANAGED*

     a.  Is there a list of wastes or description of waste types  	yes 	no
         to be permitted for each process?
     b.  Are the properties of the wastes that are pertinent
         to the process provided?                                 	yes 	no
              Physical properties, physical state, chemical
              properties
              Ignitability, reactivity, and/or incompatability
              RCRA number and basis for RCRA hazard designation
              Documented waste data from a source other than one's
              waste analyses, e.g., data from a similar process
     c.  Does the owner/operator identify any waste characteristic
         limitations?                                             	yes 	no
              Boundary conditions of waste properties
              Restricted wastes

III.  PROCESS TOLERANCE LIMITS1

     a.  Does the plan address any process tolerance limits
         (e.g., the minimum Btu/lb of waste or waste mixture that
         can be incinerated to 99.99%)?                           	yes 	no
     b.  Is any process pretreatment specified in order to
         meet tolerance limits?                                   	yes 	no

IV.   WASTE PARAMETERS TO BE MONITORED

     40 CFR 264.13 (b)(l)

     a.  Does the plan include parameters that are measured
         to characterize the waste?                               	yes 	no
     b.  Are rationales provided for the parameters?                 yes    no

     40 CFR 264.13 (a)(3) and (b)(4)

     c.  Does the owner/operator address recharacterizing
         the waste?                                               	yes 	no
              Potential for wastes restricted from the
              facility being included by mistake
              Process design limitations
              Variability of waste composition
              Chemical/physical instability of the waste
              Prior history of the generator's performance
              and reliability
                                      16

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                            TABLE 4-1.   (continued)
     d.  Are there procedures in place should recharacterization
         prove a waste is unacceptable by the facility?           	yes 	no

     40 CFR 264.13 (b)(5)

     e. 2Are any wastes analyzed outside the facility?            	yes 	no
              Documentation of analytical procedures and
              representative sampling

     40 CFR 264.13 (c)

     f. 2Does the plan include waste shipment screening
         procedures?                                              	yes 	no
              Procedures to review shipment's manifest
              Procedures to inspect shipment visually
              Frequency and % of shipment inspected, sampled,
              and/or analyzed annually
              Procedures when a shipment arrives that  is
              unacceptable by the facility
              Key parameters for shipment analysis of  each waste
              or waste type  t *:*< feri.-*'-i")

     40 CFR 264.13 (a)(3)(1)

     g.  Are there procedures should the owner/operator be
         notified or suspicious that the waste generation
         process or operation has changed?                        	yes 	no
              Procedures to obtain information needed
              Sampling and analysis procedures
              Criteria to evaluate waste change information
              Procedures for handling wastes proven
              unacceptable by the facility

V.   WASTE SAMPLING, ANALYSIS, and QA/QC PROCEDURES

     40 CFR 264.13 (b)(3)

     a.  Does the plan include representative waste sampling
         procedures?                                              	yes 	no
              Sampling method number and reference
              Sampling device
              Description of any method not approved by EPA
              Statistically representative sampling technique
              (simple, stratified, or systematic random sampling;
              composite or grab sampling; subsampling)
              Practicality of statistically representative
              sampling (physical  barriers, alternative methods)
              addressed
              Number of sampling sites
              Waste containment device when sampling
              Physical  state(s)/layers of waste


                                      17

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                          TABLE 4-1.   (continued)
            Precision and accuracy of sampling procedures
            Rationale for sampling strategy selected

   b. ^Are any samples taken by nonfacility people?             	yes 	no
            Certification/documentation of representative
            sampling procedures

   40 CFR 264.13 (b)(2)

   c.  Is waste analysis information provided?                  	yes 	no
            SW-846 test method and number if EPA-approved
            Detailed description and reference of any method
            not EPA-approved

   40 CFR 270.30 (e)

   d.  Does the plan include a QA/QC program for waste
       sampling and analysis?                                   	yes 	no
            Goals of program
            Intended use and quantity of data to be gathered
            Acknowledgement that QA/QC will  be followed as
            described in specific test methods in SW-846.
   e.  Does the program include the performance evaluation
       of trained sampling and analysis personnel?              	yes 	no
            Frequency of evaluation and rationale
            Documentation of evaluation
   f.  Is there a sample chain of custody procedure?            	yes 	no
            Container labeling and seals
            Field logbook
            Receipt and logging of samples by lab personnel
            Chain of custody records
            Sample analysis request sheet
            Method of containment and preservation
            Confirmation sheet of sample delivery to lab
   g.  Does the internal or commercial  lab document the lab
       aspects of chain of custody?                             	yes 	no
            Numbering and documenting path of sample through
            labs
            Destiny of remaining sample after analysis
            Documentation and forwarding of test results
            to manager for filing
   h.  Is lab equipment inspected, maintained, and serviced
       periodically?


^Inclusion of this information is recommended 1) to make the application
 easier to review, and 2) to allow the plan to stand alone for  use as an
 operating document.  This information is not required in a waste analysis
 plan by regulation; chemical  and physical analyses of the waste  (40 CFR
 270.14 (b)(2)) may be referenced from another Section of Part  B.
^Applies primarily to offsite facilities.
                                    18

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    TABLE 4-2.  WASTE ANALYSIS PLAN CHECKLIST - SPECIFIC HAZARDOUS WASTE
                              MANAGEMENT PROCESS
CONTAINERS

Does the waste analysis plan include
procedures for the following where
appropriate:

1.  Determining compat-
ibility of a waste to a
container (if not deter-
mined when containers
were first selected)?     	yes	no

2.  Determining compat-
ibility of a waste to
other wastes stored nearby
in containers, piles, open
tanks, or surface impound-
ments?                    	yes	no
3.  Determining compat-
ibility of a waste to
wastes previously held in
reused containers that
were not decontaminated?  	yes	no
4.  Analyzing ignitable/
reactive containerized
wastes?                   	yes	no
5.  Analyzing liquids that
are collected in a storage
area?                     	yes	no

TANKS

Does the waste analysis plan include
procedures for the following where
appropriate:

1.  Determining compat-
ibility of a waste to a
tank (if not determined
when tank was first
selected)?                	yes	no
ITANKS (cont'd.)

12.   Determining  compat-
[ibility  of a waste to any
|raw materials or other
 wastes potentially or
 previously held  in the
 tank?

J3.   Analyzing ignitable/
[reactive wastes  managed in
|tanks?

I SURFACE  IMPOUNDMENTS
               yes	no
               yes	no
I Does the waste
[procedures for
[appropriate:
analysis plan
the following
include
where
                                                                     yes	no
|1.   Determining cornpat-
jibility of a waste to the
jimpoundment's materials of
[construction (if not deter-
[mined when materials were
[first selected)?
I
 2.   Determining the compat-
[ibility of a waste to any
|raw materials or other
[wastes potentially held in
[the impoundment?

[3.   Procedures for ana-
[lyzing ignitable/reactive
[wastes managed in impound-
[ments?

[WASTE PILES

 Does the waste analysis plan include
 procedures for the following where
[appropriate:

[1.   Determining the compat-
[ibility of a waste to the
[pile's materials of con-
jstruction (if not deter-
jmined when materials were
[first selected)?          	yes   no
               yes	no
               yes	no
                                      19

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                            TABLE 4-2.  (continued)
WASTE PILES (cont'd.)

2.  Determining the compat-
ibility of a waste to other
wastes potentially held in
the same pile, other piles,
container, open tanks, or
surface impoundments
onsite?                    	yes

3.  Determining the compat-
ibility of a waste to
wastes  previously held on
the pile base if it was not
decontaminated (unless it
can be proven the wastes
are the same)?                yes
         (INCINERATION  (cont'd.)
         I
         |2.  Sampling  and analysis
         |procedures for item 1.
         (parameters?

         (THERMAL TREATMENT
                                  yes
no
4.  Analyzing ignitable/
reactive wastes managed in
waste piles?
yes
5.  a) Sampling and
analyzing leachate
collected beneath the pile,
and b) managing the
leachate if hazardous?     	yes

INCINERATION
         I
     _no|Does the waste analysis plan include
         the following information:

         1.  Additional waste
         (characteristic parameters
         jrequired:
       Heat  value
 no|-   Halogen content and
   j    sulfur content
   |*   Concentrations of
   |    mercury and lead,
_noj    unless documented data
   |    show  the elements
   |    aren't present?

   |2.   Sampling and analysis
   {procedures for these
 no|parameters?
                                       yes
no
                                       yes
no
Does the waste analysis plan include
the following information:

1.  Additional waste
characteristic parameters
required as a result of an
EPA-approved trial  burn:

  Heat value
  Viscosity (if applicable)
  Appendix VIII constituents
  POHCs1 designated from
  Appendix VIII con-
  stituents?                  yes   no!
        IPHYSICAL, CHEMICAL, AND BIOLOGICAL
        |                TREATMENT

        JDoes the waste analysis plan include
        |the following:
         jl.  Any additional waste
         (characteristic parameters
         jrequired as a result of an
         j EPA-approved trial test?   	yes	no

         2.  Sampling and analysis
         procedures for these
         specific parameters?       	yes	no
                                      20

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                             TABLE 4-2.  (continued)
 PHYSICAL, CHEMICAL, AND BIOLOGICAL
          TREATMENT (cont'd.)

 3.  Procedures to deter-
 mine the compatibility of
 a waste to process
 structure (if not deter-
 mined when structure  was
                                    no
first selected)?          	yes

4.  Procedures to deter-
mine the compatibility of
a waste to any raw mater-
ials or other wastes
potentially or previously
held in the process
structure?                	yes   no
 5.   Procedures  for
 analyzing  ignitable/
 reactive wastes  man-
 aged  in the  process
 structure?                   yes    no

 LAND  TREATMENT

 Does  the waste  analysis  plan include
 the  following:

 1.  Any additional waste
 characteristic  parameters
 required as  a result of  an
 EPA-approved land treatment
 demonstration, e.g.,      	yes
 Appendix VIII PHCs2?            "

 2.  Sampling and analysis
 procedures for  Item 1.
 parameters?                  yes

 3.  Procedures to deter-
mine the compatibility of
a waste to any raw mater-
 ials or other wastes
potentially applied in a
given treatment zone?     	yes   no
                                   no
                                   no
                                       4.   Procedures  for  ana-
                                       lyzing  ignitable/reactive
                                       wastes  to  be treated?

                                       LANDFILL
                           	yes	i
no
 Does the waste analysis plan include
 procedures for the following where
 appropriate:

 1.  Inspecting containers
 for free liquids before
 disposal and for handling
 any unacceptable free
 liquids that may appear?   	yes	no
|2.  Inspecting containers
|for 90% volume by waste
|and for handling any
|containers of waste that
jare unacceptable by the
|facility that may appear?  	yes	no

|3.  Determining the compat-
 ibility of a waste to land-
 fill  liner(s) and leachate
 collection system materials
 (if not determined when
 materials  were first
 selected)?                    yes   no
 4.   Determining  the compat-
jibility  of a  waste to any
|other  wastes  potentially
(disposed in the  landfill?  	yes	no

 5.   Analyzing ignitable/
 reactive wastes  to be
 disposed?                     yes
                                                                           no
                                       6.   a)  Sampling  and  ana-
                                       lyzing  leachate  collected
                                        and b)  managing the
                                       leachate if  hazardous?
                                                                     yes
                                     no
   POHC - Principal Organic Hazardous Constituent.
   PHC - Principal  Hazardous Constituent.
                                      21

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 TABLE 4-3.  OPTIONAL ITEMS TO CONSIDER WHEN PREPARING A WASTE ANALYSIS  PLAN1
I. IDENTIFICATION OF WASTES TO BE
             MANAGED

An identification number for a waste
that may indicate its generation
source

Known health and environmental effects

Any analytical  data sheets on waste

Any existing documentation on the
waste's compatibility or
incompatibility

Certification of validity of any
waste data provided by a generator


II.  WASTE PARAMETERS TO BE MONITORED

Screening procedures^

  .  Reference  to reviewing shipment
     manifests  for information
     such as

     -  Manifest document number

     -  Generator's name, address, and
        EPA I.D. number

        Each transporter's name and
        EPA I.D. number

     -  The destination of each ship-
        ment, i.e., HWMF, address, and
        EPA I.D. number

     -  An alternative HWMF, address,
        and EPA I.D.  number

     -  DOT shipping  name and number

     -  Quantity/volume of waste in
        shipment
II.  WASTE PARAMETERS TO BE MONITORED
    (cont'd.)

     -  Number and type of containers

     -  Signed certification and date

 .   Visual  inspection of shipment

        Number and type of containers
        match  manifest

     -  Shipment labels/placards/marks,
        i.e.,  RCRA and DOT, match
        manifest description

     -  Presence of free liquids and
        consistency with manifest
        description

     -  Irregularities with shipment,
        e.g.,  leaks

     -  Wastes restricted from the
        facility that are visibly
        present

     -  Waste  color's consistency with
        the characterization form's
        description

     -  Consistency between the waste's
        visible physical  state and the
        characterization form's
        description

    Acceptance/rejection procedures

     -  Documentation of acceptance
        when  results of waste inspec-
        tion  and analysis agree with
        waste  characterization data
                                      22

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                            TABLE 4-3.  (continued)
        Reanalysis procedures for a
        waste shipment when test
        results are inconsistent with
        characterization data

          notifying generator of in-
          consistency

          agreement to reject or
          reanalyze waste shipment
          (document)

          analysis of an unused
          original sample's replicate
          or a new sample

          notifying generator or waste
          acceptance or rejection

        Rejection procedures for an
        unacceptable waste

        Agreements with generator if a
        waste is unacceptable

        Temporary storage plans before
        unacceptable waste is shipped
        offsite for other management
III.  WASTE SAMPLING, ANALYSIS, AND
      QA/QC PROCEDURES

Comments on sampling

     .  Protective gear required

        Sample container
     .  Weather constraints

     .  Storage instruction

     .  Sample life

Diagrams of sampling points

Detection limits of analytical
method

Rationale for selecting a test
method if more than one method is
available
    s information is not required by 40 CFR 264.13; however, it may contribute
to a more complete and useful waste analysis plan.

2|Jsed primarily by offsite hazardous waste management facilities.
                                      23

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                                  REFERENCES
1.  Permit Applicants' Guidance Manual for the General Facility  Standards  of
40 CFR 264.  SW-968, U.S. Environmental Protection Agency, Washington,  D.C.
1983.  Available from Superintendent of Documents, U.S. Government  Printing
Office, Washington, D.C.

2.  Hatayama, H. K., J. J. Chen, E. R. de Vera, R. D. Stephens,  and  D.  L.
Storm.  A Method for Determining the Compatibility of Hazardous  Wastes.
EPA-600/2-80-076, U.S. Environmental Protection Agency, Cincinnati,  Ohio,
1980.  149 pp.  Available from Superintendent of Documents, U.S.  Government
Printing Office, Washington, D.C.

3.  Test Methods for Evaluating Solid Waste.  Physical/Chemical  Methods.
SW-846, 2nd Edition, U.S. Environmental Protection Agency, Washington,  D.C.
1982.  Available from Superintendent of Documents, U.S. Government  Printing
Office, Washington, D.C.

4.  Design and Development of a Hazardous Waste Reactivity Testing  Protocol.
EPA-600/52-84-057, U.S. Environmental Protection Agency, Municipal
Environmental Research Laboratory, Cincinnati, Ohio.  1984.  Available  from  the
National Technical Information Service (NTIS Mo. PB84-158807).

5.  Permit Applicants' Guidance Manual for Hazardous Waste Land  Treatment,
Storage, and Disposal Facilities.  SW-84-004, U.S. Environmental  Protection
Agency, Washington, D.C.  1983.  Available from Superintendent of Documents,
U.S. Government Printing Office, Washington, D.C.

6.  Guidance Manual for Hazardous Waste Incinerator Permits.   SW-966, U.S.
Environmental Protection Agency, Washington, D.C. 1983.  Available  from
Superintendent of Documents, U.S. Government Printing Office,  Washington,  D.C.
                                      24

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                             APPENDIX A

               40 CFR 264.13  GENERAL WASTE ANALYSIS
     (a)(l) Before an owner or operator treats, stores, or disposes  of
any hazardous waste, he must obtain a detailed chemical and physical
analysis of a representative sample of the waste.   At a minimum,  this
analysis mist contain all the information which nust be known to  treat,
store, or dispose of the waste in accordance with  the requirements of
this part or with the conditions of a permit issued under Part 270
and Part 124 of this chapter.
     (2) The analysis may include data developed under Part 261 of this
chapter, and existing published or documented data on the hazardous  waste
or on hazardous waste generated from similar processes.
     (3) The analysis must be repeated as necessary to ensure that it  is
accurate and up to date.  At a minimum, the analysis must be repeated:
     (i) When the owner or operator is notified, or has reason to
believe, that the process or operation generating  the hazardous waste  has
changed; and
     (ii) For off-site facilities, when the results of the inspection
required in paragraph (a)(4) of this section indicate that the hazardous
waste received at the facility does not match the  waste designated on  the
accompanying manifest or shipping paper.
     (4) The owner or operator of an offsite facility must inspect and,
if necessary, analyze each hazardous waste movement received at the
facility to determine whether it matches the identity of the waste
specified on the accompanying manifest or shipping paper.

     (b) The owner or operator must develop and follow a written  waste
analysis plan which describes the procedures which he will  carry  out to
comply with paragraph (a) of this section.  He will keep this plan at  the
facility.  At a minimum, the plan must specify:
     (1) The parameters for which each hazardous waste will  be analyzed
and the rationale for the selection of these parameters (i.e., how
analysis for these parameters will provide sufficient information on the
waste's properties to comply with paragraph (a) of this section);
     (2) The test methods which will be used to test for these
parameters;
     (3) The sampling method which will be used to obtain a
representative sample of the waste to be analyzed.  A representative
sample may be obtained using either:
     (i) One of the sampling methods described in  Appendix I of Part 261
of this chapter; or
     (ii) An equivalent sampling method.
     (4) The frequency with which the initial  analysis of the waste  will
be reviewed or repeated to ensure that the analysis is accurate and  up to
date; and
                                A-l

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     (5) For off-site facilities, the waste analyses that hazardous waste
generators have agreed to supply.
     (6) Where applicable, the methods which will  be used to meet the
additional waste analysis requirements for specific waste management
methods as specified in 264.17 and 264.341.

     (c) For off-site facilities, the waste analysis plan required in
paragraph (b) of this section must also specify the procedures which will
be used to inspect and, if necessary, analyze each movement of hazardous
waste received at the facility to ensure that it matches the identity of
the waste designated on the accompanying manifest or shipping paper.  At
a minimum, the plan must describe:
     (1) The procedures which will be used to determine the identity of
each movement of waste managed at the facility; and
     (2) The sampling method which will be used to obtain a
representative sample of the waste to be identified, if the
identification method includes sampling."
                                A-2

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                                  APPENDIX B

                         EXAMPLE WASTE ANALYSIS PLANS
     The model waste analysis plans presented in this Appendix pertain to
hazardous waste management procedures for hypothetical  facilities.  The purpose
of including these examples in this manual  is to demonstrate approaches to
preparing complete waste analysis plans for each of the basic hazardous waste
management scenarios.

     The model plans included here address  the following hazardous waste
management practices:

                 Container storage         Land treatment
                 Tank storage              Incineration
                 Surface impoundment       Chemical treatment
                 Waste pile                Landfill.

     Each case study has been kept as simple as possible in an effort to focus
on the necessary elements of the waste analysis plan.

     On July 20, 1984, EPA proposed "a standard RCRA permit application form
for use by a select group of facilities whose only activity subject to RCRA
permitting consists of storing in above-ground tanks or containers hazardous
wastes that have been generated on-site."  (49 FR 29524).  This application
form was developed because certain types of storage facilities "present
regulatory control issues that are essentially identical."   This proposed
application form is scheduled to be finalized by mid-1985.   Some storage
facilities may not fit into this waste management classification or may be
located in a state that would not use the form.  For these  reasons, along with
the proposed status of the form, model waste analysis plans for container and
tank storage facilities that are based on existing regulations are included in
Appendix B.

     The following tests are not addressed  in the Appendix  B model  waste
analysis plans:

          waste management compliance monitoring (e.g., groundwater
          monitoring, incinerator stack monitoring),

          waste management process operation monitoring (e.g., groundwater
          monitoring, incinerator stack monitoring),

          pre-permit process performance analyses (e.g., trial  burns, land
          treatment demonstrations), and

          closure plan analyses.
                                      B-l

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These tests are not a part of waste analysis plans.  Such tests should
be addressed in other portions of Part B applications.

     These models are not intended to be inflexible formats for writing uaste
analysis plans; rather, they are examples furnished to vrovide guidance to both
the permit applicant and the permit writer.  The numerical values for physical
properties and chemical analyses in this Appendix have been selected
arbitrarily and do not necessarily reflect actual levels in the types of
streams described. Where possible, however, the industry descriptions and
stream compositions were based on information provided in the RCRA background
information document, "Identification and Listing of Hazardous Waste" (EPA
1980)l.  Comments regarding safety precautions for sampling were taken from
Toxic and Hazardous Industrial Chemicals Safety Manual prepared by the
International  Information Institute (Japan 1976)2.
ill.S. Environmental  Protection Agency.  (Identification and Listing of
Hazardous Waste Under RCRA, Subtitle C, Section 3001:  Listing of Hazardous
Waste (40 CFR 261.31 and 261.32).  PB81-190035, National  Technical Information
Service, Springfield, Virginia, 1981.

2The International  Technical  Information Institute.  Toxic and Hazardous
Industrial  Chemicals Safety Manual.  The International  Technical   Information
Institute,  Japan, 1976.
                                      B-2

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                                         Model  WAP - Container:   Page 1  of 15


                          MODEL WASTE ANALYSIS PLAN

                              CONTAINER STORAGE


                          1.  Facility Description


     The Aircraft Parts Manufacturing Company uses trichloroethylene (TCE)  as
a cold cleaning solvent to remove grease, oil,  and dirt from its products
before shipment.  There are three principal  manufacturing processes at the
company's plant, each of which generates one waste stream of spent solvent
degreaser consisting of trichloroethylene, oil, grease, and dirt.  This spent
solvent degreaser represents the only hazardous waste generated  onsite.  This
waste is designated RCRA hazardous (FOOD due to the toxicity of trichloro-
ethylene.  It is stored in 55-gallon drums on a sheltered cement slab near  the
loading dock until  45 to 50 drums have accumulated.  The waste is shipped to a
commercial  solvent  reclamation facility at approximately 6-month intervals.

     The Aircraft Parts Manufacturing Company is requesting a RCRA permit to
store spent trichloroethylene in drums at the designated area onsite described
above.  The storage area will be permitted to hold only the spent
trichloroethylene.

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                                         Model  WAP - Container:   Page 2  of 15


                   2.  Identification of the Spent Solvent


     Table 1 lists the characteristics of each  hazardous  waste stream
generated onsite that we consider pertinent to  the proper operation of the
storage facility. The three waste streams we manage range in composition from
80 to 95 percent trichloroethylene by volume, with the remainder being oil  and
grease and an immeasurable amount of dirt.   The data listed  reflect analysis
results from three samples taken at 4-month intervals at  each generation
process area.  The waste characterization was performed by  an offsite
commercial laboratory, Smith Labs.  The Lab's analytical  results are found in
Appendix I.  Quality assurance and quality control  programs  associated with
this lab are described in Appendix II.

     The following boundary conditions have been established for the spent
solvent characteristics:

           +_ 15 percent of the specific gravities listed  in  Table 1, and

           flash point less than 60 C.

Not meeting these conditions will alert us that the waste is not typical  and
may require special  handling or analysis before shipment  offsite. Any wastes
that exceed the boundary conditions will  be handled according to the
procedures described in Section 4, "Parameters  to be Monitored."  Our
experience with this waste has led us to establish these  conditions, and we do
not expect the waste to vary outside these boundaries. Supporting analytical
data are available upon request.

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                                       TABLE 1.   WASTE CHARACTERISTICS
                                  Basis for
                                Hazard  Listing
                           Physical
                          Properties^
                                   Chemical
                                 Composition
                               (or % by volume)
      Spent Solvent
      Degreaser (TCE)
      Spent Solvent
      Degreaser (TCE)
      Spent Solvent
      Degreaser (TCE)
TCE (Toxic)
TCE (Toxic)
TCE (Toxic)
Specific gravity:
1.30 to 1.46
Flash point:
73 to 77 C

Specific gravity:
1.26 to 1.41
Flash point:
77 to 81 C

Specific gravity:
1.28 to 1.44
Flash point:
75 to 79 C
TCE:  85 to 95% by volume
Oi1  and grease:
5 to 15% by volume
Dirt:  negligible

TCE:  80 to 90% by volume
Oil  and grease:
10 to 20% by volume
Dirt:  negligible

TCE:  82 to 92% by volume
Oil  and grease:
8 to 18% by volume
Dirt:  negligible
o
o.
^Process code for all  streams is SOI,  container storage.
2"A", "B", and "C" refer to process areas.
3A11  streams are assigned RCRA number  F001  (40 CFR 261.31).
   1  streams are liquid with one layer.   The specific gravity of pure TCE is 1.465, and
 the  flash point is 32 C.
                                                                                                                o
                                                                                                                o
                                                                                O)
                                                                                tt>
                                                                                -5
                                                                                                                CQ
                                                                                                                n>
                                                                                                                 CO

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                                         Model  WAP  -  Container:   Page  4   of  15


                      3.   Drum Storage Tolerance  Limits


     The storage process  is limited by the amount of  space  available for
holding drums and the spill  containment capacity  of the  area.   The  type of
storage drum selected to  hold the spent trichloroethylene is  compatible with
the waste and approved by the Department of Transportation  (49  CFR  172.101).
These drums are not affected by the concentration of  trichloroethylene in the
waste.

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                                         Model WAP - Container:   Page 5  of 15


                        4.  Parameters to be Monitored
     The spent trichloroethylene must be capable of safe storage in 55-gallon
drums for up to 6 months.  We believe that the spent solvent degreaser we
generate meets this criterion because 1) the storage drums were selected for
their chemical compatibility to the waste and 2) our parts cleaning process is
routine and produces wastes of relatively consistent composition.

     We have reviewed existing information on the waste properties (including
a search for ignitability/reactivity), noted what properties best  indicate any
change in a waste, and compared this information to our storage facility's
design criteria.  Since the only facility limitations are waste storage and
spill containment capacity, the waste analysis parameters to be measured were
selected to verify the nature of the waste.

     Review of our operating records indicates that the characteristics of the
spent solvent probably will change only in the proportion of oil  and  grease
dissolved in the solvent. Only one hazardous (toxic) constituent,
trichloroethylene, is generated onsite; therefore, it has been selected as a
parameter to be determined.  Specific gravity was selected as a parameter to
provide an indication of the spent solvent's variation in contaminants.

     Since no other hazardous wastes are stored onsite, no potential  exists
for hazardous waste incompatibilities.  The drums are purchased new and
uncontaminated; therefore, no potentially incompatible wastes have been held
in these drums before the spent solvent is placed in them.  When the  filled
drums are shipped offsite, they are not returned to us for reuse;  however, we
are credited by the reclaimer for empty drums.

     We decided how often we felt it necessary to characterize the spent
solvent with these tests by considering 

          the potential  for other materials onsite being mistakenly
          placed in these drums,

          the variability of the spent solvent  composition,  and

          the likelihood of the spent solvent undergoing changes that  alter
          its permitted  characteristics.

     Our trichloroethylene wastes seldom change since 1) only one  type of
hazardous waste is generated onsite, and 2) the generating process is  routine.
Therefore, we believe that annual  characterization is sufficient to maintain
our file of chemical  information should a waste spill  occur  onsite.   The
characterization will  be performed by Smith Labs.   The offsite solvent
reclamation facility that receives our waste takes samples and analyzes them
for its own needs.

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                                         Model  WAP  -  Container:   Page  6  of  15


     If characterization analyses  ever indicate that  the waste is  either
unacceptable by the reclaimer or incompatible with  our wastes stored onsite,
we will follow the procedures described in  the  following paragraphs.

     Should one of our process area  personnel ever  notify  us that  the  solvent
degreasing process or its means of operation has changed,  we will  check to see
if the spent tn'chloroethylene has changed  in character.   As much  information
about the change will be obtained  as our personnel  can provide.   We will
obtain an unscheduled sample (according to  our  sampling procedures) and submit
it to Smith Labs for analysis.  We will inform  Smith  personnel of  any  known
property changes and they will analyze the  waste according to the  agreed
analysis procedures.  As per our standard agreement with Smith,  should they
detect any change of greater than  15 percent in specific gravity,  a flash
point below 60 C, or an unexpected  constituent in  the gas chromatogram, Smith
Labs will notify us.

     We will notify the commercial reclamation  contractor  of any change, so
that the contractor can decide if  the waste is  still  acceptable  at his
facility.  If the waste is not acceptable,  we will  make every effort to find
another reclaimer to receive the waste.  In the interim, the waste will remain
stored onsite.

     The storage pad is already designed to comply  with RCRA regulations for
storing ignitable waste if the waste flash  point ever becomes less than 60  C.
Should any wastes be incompatible  with the  wastes currently in storage, we
will contact our reclaimer and, if acceptable,  load and ship the wastes to him
in order to avoid common storage with the typical wastes.

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                                         Model  WAP - Container:   Page  7   of  15


                       5.   Waste Sampling and Analysis
Sampling
     We sample one drum from each process area since 1)  we generate  such  small
volumes of solvent, and 2)  the solvent has a very low potential  for  varying  in
composition within the process area.   The specific drums to be sampled  will  be
selected using the simple random sampling method for containers  as described
in "Test Methods for Evaluating Solid Wastes"  (SW-846),  Section  1.4.1.   Simple
random sampling entails using the random numbers table to select drums  to
sample.  [See Appendices C  and 0 of this manual.]  All  containers are the same
type of 55-gallon drum and  are easily accessible for sampling  through the
bung.  Since the waste is homogeneous, a representative sample can be obtained
even though the sampler is  limited to a single vertical  area.

     A glass Coliwasa device will be used to sample the spent  solvent.   Glass
is inert to chlorinated organics so analysis should be free of interference.
Samples will be stored in glass sample containers with teflon-lined  Bakelite
caps.  These materials will  not react with chlorinated organics.

     The storage facility is designed to prevent any run-on of precipitation.
No direct precipitation should collect in our  facility because it is sheltered
from the weather.  However,  if any liquid is collected in the  storage sump,  it
will be sampled by taking a  Coliwasa grab sample and analyzed  for the same
parameters as the drummed waste.  If the sump  liquid is hazardous as defined
in 40 CFR Part 261, it will  be drummed, labeled, and stored along with  the
other trichloroethylene waste.

     Our sampling personnel  will take special  precautions when sampling any
wastes related to trichloroethylene because of its known toxicity.   We
reviewed the scientific literature and our previous work history to  identify
any needs for special handling procedures for  the waste in order to  protect
our personnel and keep the  samples representative.

     A summary of our sampling procedures is provided below. The approach
pertains to characterization as well  as to unscheduled sampling  of the  spent
trichloroethylene.

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                                         Model  WAP - Container:   Page 8  of 15
  Containment Device             55-gallon drums

  Sampling Technique             Simple random sampling
                                 Grab samples

  Sampling Device                Coliwasa

  Number of Drums Sampled        One drum from each stream

  Comments                       1.   Wear goggles, rubber gloves, and apron.
                                 2.   Have area well-ventilated.
                                 3.   Get sample from midlevel  of drum.
                                 4.   Place sample in glass bottle with  teflon
                                        cap.
                                 5.   TOXIC WASTE.

  References                     Technique:  SW-846^, Section 1.4.1
                                 Device:  SW-846, Section 1.2.1.1
1SW-846 "Test Methods for Evaluating Solid Waste"  July 1982.


     Quality assurance and quality control procedures for waste sampling are
described in Appendix II.


Analysis

     Table 2 identifies the test method to be employed to measure each waste
parameter. All  parameters and test methods apply to all  three of the wastes
streams due to their similarity.  The test methods were chosen from the
American Society for Testing and Materials (ASTM)  compendium  of test methods
and EPA's "Test Methods for Evaluating Solid Waste" (SW-846). Quality
assurance and quality control procedures for analyzing the waste are discussed
in Appendix II.

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                                         Model  WAP - Container:   Page 9  of 15
       TABLE 2.   WASTE ANALYSIS PARAMETERS AND METHODS FOR STREAMS A, B,
                    AND C OF SPENT SOLVENT DEGREASER (TCE)1
   Parameters
   Analytical Methods     Rationale for Parameters
Specific gravity
ASTM D891, Method A
(Hydrometer)
Identification of spent TCE
Flash point
Halogenated volatile
organics
SW-8462, Method 1010
(Pensky-Martens)

SW-846, Method 8010
(Gas chromatography--
measure retention time
for TCE)
Identification of spent TCE
Identification of spent TCE
^These wastes are recharacterized annually.
2SW-846 "Test Methods for Evaluating Solid Waste" July 1982.

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                                         Model WAP - Container:  Page 10 of 15
                                  APPENDIX I
                              SMITH LABORATORIES
                           Date:  January 21, 1983
Sample Number:  Drums 01-1
                      18-1
                      30-1
Collected:  January 18, 1983
Received:  January 18, 1983
                          Client:
Sample
Drum
Number

01-1
18-1
30-1
Process
Area
Stream
  Parameter

Speci fie
gravity

Flash point

%Trichloroethylene
 (by volume)

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)

Specific
gravity

Flash point.

%Trich1oroethylene
 (by volume)
                     Aircraft Parts Mfg. Co.
                     Address
 Results

1.38


75.2 C

90%
                                      1.34
                                      1.36
Test Method

   ASTM1


   10102

   80102
                    ASTM1
79.4 C
85%
10102
80102
                    ASTM*
77.7 C
87%
10102
80102
1 ASTM  American Society for Testing and Materials
2 "Test Methods for Evaluating Solid Waste" SW-846 July 1982.
Signature of Certification:
                            Jdrin Smith, President

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                                         Model WAP - Container:  Page  11 of 15
                              SMITH LABORATORIES
                             Date:  May  15,  1983
Sample Number:  Drums 03-1
                      16-1
                      28-1
Collected:  January 18, 1983
Received:  January 18, 1983
                          Client;
Sample
Drum
Number

03-1
16-1
28-1
Process
Area
Stream
  Parameter

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)
                     Aircraft Parts Mfg. Co.
                     Address
Results

1.42


76.5 C

92%
                                      1.29
                                      1.30
Test Method

   ASTM1


   10102

   80102
                    ASTM1
77.8 C
87%
10102
80102
                    ASTM1
77.5 C
85%
10102
80102
1 ASTM  American Society for Testing and Materials
2 "Test Methods for Evaluating Solid Waste" SW-846 July 1982.
Signature of Certification:
                                   ith, President

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                                         Model WAP - Container:  Page 12 of 15
                              SMITH LABORATORIES
                          Date:  September 19, 1983
Sample Number:  Drums 05-1
                      14-1
                      25-1
Collected:  January 18, 1983
Received:  January 18, 1983
                          Client:
Sample
Drum
Number

05-1
14-1
25-1
Process
Area
Stream

  A
  Parameter

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)

Specific
gravity

Flash point

%Tri chlo roethylene
 (by volume)

Specific
gravity

Flash point

%Trichloroethylene
 (by volume)
                     Aircraft Parts Mfg. Co.
                     Address
Results

 1.45


 74.2 C

 87%
                                      1.40
                                      1.42
Test Method

   ASTM1


   10102

   80102
                     ASTM1
80.0 C
86%
10102
80102
                     ASTM1
78.4 C
89%
10102
80102
1 ASTM  American Society for Testing and Materials
2 "Test Methods for Evaluating Solid Waste" SW-846 July 1982.
Signature of Certification:
                                    th, President

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                                         Model  WAP - Container:   Page 13 of 15

                                 APPENDIX II

                  Quality Assurance/Quality Control  Program
Program Goal
     Our program's goal is to obtain accurate and precise data on waste
characteristics and to maintain an up-to-date log of those data.   The
analytical data we obtain are available 

          should a spill occur onsite, or

          so we can notify our solvent reclamation contractor if  a process
          or operation change occurs.

Since the only hazardous waste constituent we store onsite is
trichloroethylene, our data need to center around their properties.   We
measure only three parameters in our waste, so the quantity of data  we need  is
minimal.


Sampling Program

     We sample our own waste.  One person is the sampler.  He has been
properly trained to sample the waste using the equipment described in Section
5.  A description of his training is found in our "Training Program"  chapter
of Part B.  His sampling skills are evaluated semi annually by our
environmental  manager; we feel this is a sufficient frequency since
characterization sampling routinely occurs annually.

     Once a sample is taken, the Coliwasa is decontaminated as directed by the
device's manufacturer.  When samples are taken, our employee logs vital  data
in a field book, labels the containers (See Figure II-l), and hand carries
them to a designated room for cool storage until Smith Labs picks the samples
up (within 24 hours).  The employee prepares a request for analysis  (see
Figure II-2), which accompanies the samples to Smith Labs to specify waste
samples and analytical data needed.


Analysis Program

     All analytical procedures required by our company have been  specified in
a contract with Smith Labs.  Smith is a commercial laboratory with trained
analysts who are retrained annually.  They maintain a rigorous quality
assurance/quality control program which is available for review by EPA upon
request.  All  of the hazardous waste analyses they conduct are performed
within 48 hours of receipt and comply with SW-846 quality assurance/quality
control procedures for specific test methods.

     Analytical data are documented, returned to us for evaluation by our
environmental  manager, and then filed.

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                                         Model  WAP  - Container:   Page  14 of 15
Collector
                                             Sample  No.     /?-/
Place of Collection   r
                                  UA/iJ
Date Sampled Y)ory*ml)4jt)   /6; (3$3	Time  Sampled   3 I )6>p>m
Field Information
                    Figure II-l.   Sample  container label.



    Source:   "Test  Methods for  Evaluating Solid Waste"  SW-846, July  1982.

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                                         Model WAP - Container:  Page 15 of 15
Collector
            /
           rf.
           |
Affiliation of Sampl &r   (^
                                ~    -~'~
                                                                 QOflQO
          number    street

Telephone foop) 5^5 - /3 73
                                     city            state

                                 Company Contact
                                                                   zip
LABORATORY
SAMPLE
NUMBER
                                                         jy
                COLLECTOR'S
                SAMPLE NO.

                  It'l
                     TYPE OF
                     SAMPLE1


                       11AML-
                                                    FIELD INFORMATION
                                                       tf/t Tb\LXC, .
                                                           n
A
Received by
                    /
Analysis Required d thrU.  AA,
                    --        '
                                                                   1 1?  X
                                                          Date  II  1?  X3
                                                                 7   ^^
^Indicate whether  sample  is  soil,  sludge, etc.
2(Jse back of page  for  additional information relative to sample location.
                  Figure  II-2.   Sampling analysis request.

    Source:   "Test Methods  for  Evaluating Solid Waste" SW-846.  July 1982.

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                                             Model  WAP - Tank:   Page 1  of 12


                          MODEL WASTE ANALYSIS PLAN

                                 TANK STORAGE

                          1.   Facility Description


     The Solid Fuel  Company formulates nitrocellulose-based propel 1 ants.   We
generate wastewaters originating from --

          cleaning of blending, packaging, and handling equipment and
          storage facilities;

          wet milling of propel 1 ant castings;

          air pollution wet scrubber control  devices;  and

          loading, assembling, and packaging  of ordnance.

These wastewaters are physically treated onsite in  settling pits where they
produce a single-layer sludge which is a RCRA reactive hazardous waste due to
its nitrocellulose content.*

     The Solid Fuel  Company requests a RCRA permit  to  store the wastewater
treatment sludges in two open concrete tanks  onsite.   The tanks were designed
specifically to contain the nitrocellulose-based sludge.  We would  accumulate
the sludge until  the tanks reach capacity and then  transport it to  an offsite
hazardous waste management facility.  The storage promotes sludge drying  and
is cost-effective.  The tanks must be managed in the  following  ways  to assure
safe storage:  1) they will not be used for any waste  that is incompatible
with the sludge, 2)  the sludge moisture content will  not be allowed  to fall
below 70 percent, and 3) the  tank will be protected from any sources that
might initiate reaction.
    CFR 261.32 lists this waste as "K044 - wastewater treatment sludges from
the manufacturing and processing of explosives."   This waste category can be
reactive due to one or more explosives industry products, nitrocellulose in
this case.

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                                             Model  WAP - Tank:   Page 2  of  12


                         2.  Identification of Sludge


      Table 1 contains the sludge characteristics that need  to  be controlled
within specified limits if we are to operate the tank in compliance with
anticipated permit conditions.   The sludge entering the tank is a flowable
liquid with approximately 5 percent solids.  The water content  of the sludge
is reduced by the time the tank is emptied, but the sludge (approximately 25
percent solids) still  remains flowable.

      The sludge characterization yielding the data in Table 1  was performed
by the analysts on our wastewater treatment plant staff.  Our staff sampled
and analyzed the two sludge streams four times over the past 2  years of our
RCRA interim status operation.   Sampling and analysis procedures followed
those described in this plan.  Quality assurance and quality control
procedures used to characterize the sludge are described in  the appendix of
this waste analysis plan.

      Boundary conditions have  been established to alert us  that the sludge
generating process is  not operating normally. The sludge entering the storage
tank must always have  a water content greater than 90 percent.   The sludge,
during its storage and upon leaving the tank, should never contain less than
70 percent water.  Sludge pH should not be below 6.0.  The water contents are
maintained to decrease the potential for reaction due to drying.  Too acidic a
pH may also trigger sludge reaction.  These boundary conditions were
established based on our experience with the sludge and its  potential  for
reacting.

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                                             Model  WAP  -  Tank:   Page  3  of  12
                      TABLE  1.   SLUDGE  CHARACTERISTICS
               Stream^
          Chemical  Composition
1.   Sludge entering tank
2.   Sludge leaving tank
Nitrocellulose:  not more than 5% by
                 volume
Water:  at least 95% by volume
Other constituents:  negligible
pH:  8.0 to 10.0

Nitrocellulose:  not more than 25% by
                 volume
Water:  at least 75% by volume
Other constituents:  negligible
pH:  8.0 to 10.0
iRCRA number:   K044 (40 CFR 264.32).
 Process code  is S02,  tank storage.

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                                             Model  WAP - Tank:   Page  4   of  12


                  3.   Tank Storage Process Tolerance Limits


      In addition to  the sludge boundary conditions described  previously, the
tank storage process  is limited by the volume of sludge the  tanks  can hold
safely.   (Tank design information is in another chapter of this  Part  B
application.)  The tank should also not be allowed  to receive  wastes  that may
be incompatible with  the sludge due to the potential  for reaction.  The  tanked
sludges  must never be exposed to any sources of reaction because they may
contain  concentrations of reactive nitrocellulose that could be  triggered.

     These tolerance  limits represent those qualitative and  quantitative waste
characteristics that  the tank structure can manage  within the  RCRA  permit
conditions.

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                                             Model  WAP  -  Tank:   Page  5  of  12


                    4.   Waste Parameters  to  be Monitored
      The sludge must be safely stored  in  an  open  tank  for  up  to  6 months to
dry without reacting.  It can be managed for  this  period  because  1) the tanks
were designed specifically to store the reactive sludge,  and 2) our years of
operating data, which cover a broad range  of  production rates,  indicate that
the sludge fed to the tanks remains relatively  consistent in composition.
Also, variations in sludge composition  are not  sufficient to offer a  serious
threat of unexpected constituents.

      To select the proper parameters to monitor storage  performance, we  1)
reviewed existing information on the sludge properties  (including its
reactivity), 2) noted what properties best indicate  change  in  a waste, and  3)
compared this information to the tank design  criteria  so  we can assure
compliance with RCRA permit conditions. These  steps included  identifying the
tank design and operating limitations described in Section  3.

      The wastewater treatment sludge generated by nitrocellulose production
contains nitrocellulose and water.   The sludge  characteristics  are expected to
change only in the ratio of solids-to-water and perhaps pH. Parameters were
chosen based primarily on the most  significant  sludge  property-reactivity (or
explosivity).  The sludge pH, percent moisture, and, in turn,  explosivity are
measured to provide a sufficient indication of  any important variation in
sludge character.

      When the tanks are emptied for offsite  transport  of the  sludge, they  are
not decontaminated because they are being  refilled with the same  type of
sludge that the tanks previously held.   Therefore, no  potential waste
incompatibilities can occur and there is no need to  monitor waste
characteristics for incompatibilities.   The transport  vehicles are
decontaminated by their owners before receiving the  sludge, and they  are
constructed of materials that are compatible  with  the  sludge to eliminate the
potential for reactions.

      Our in-house wastewater treatment plant staff  will  recharacterize the
sludge semiannually as a load is prepared  for offsite  shipment.   We prefer
semiannual recharacterizations, because 

      1)  our years of operating experience indicate that the  sludge's primary
          constituent, nitrocellulose,  remains  consistent;  only its
          concentration relative to the moisture content  and pH may vary  in
          the sludge within a safe range (operating  data  available upon
          request);

      2)  the offsite hazardous waste management facility that accepts the
          sludge also analyzes it for their own purposes; and

      3)  the sludge samples are most  representative when taken during tank
          drainage.

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                                             Model  WAP - Tank:   Page  6   of  12
      The wet sludge is the only waste pumped to the two  tanks,  and  we  have
made every design effort to ensure that no unpermitted  wastes  enter  the tanks.
The wet sludge is pumped to the tank via a pipe isolated  from  other  wastes.
The storage tanks are located in an area protected  from sources  that might
initiate reaction (see 40 CFR 264.190 to 264.199).   Other chapters of this
Part B application describe further how protection  is accomplished.

      Should the nitrocellulose process or its means of operation  ever  change,
we will determine if the sludge characteristics have changed.   First, we will
obtain as much information about the process or operation change as  our
personnel can provide, and we will  take an unscheduled  sample  of the most
recent sludge placed in the tanks and analyze it according to  EPA-approved
procedures.  Any nonroutine parameters for constituents that we  suspect are
present will also be measured.  If we detect a change in  the time  required for
the sample to react, we will  make every effort to identify the source of the
change in reactivity.

     Our offsite hazardous waste management facility contractor  will  be
notified of any change in order to determine if the waste is still acceptable
at his or her facility.  If the waste is not acceptable,  we will make every
effort to find another facility to receive it.  In  the  interim,  the  sludge
will remain stored onsite in a special  holding tank.

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                                             Model  WAP  -  Tank:   Page  7   of  12


                       5.   Waste Sampling  and Analysis


Sampli ng

     The wastewater treatment  sludge is  sampled  semiannually  at  two locations:
1) the inlet pipe directly at  the storage  tanks,  and  2) the effluent  pipe that
drains the tanks. These sampling points  were  chosen because limited access  to
areas within the tanks limits  the sample representativeness.  The  inlet  pipe
sludge is grab sampled during  normal  operations.   The effluent is  sampled as a
tank is emptied for offsite shipment.   It  typically takes 1 hour to drain each
tank, so we grab sample the initial  effluent  from the tank outlet  pipe and
continue to sample the effluent at 30-minute  intervals.   Each sample  is
containerized separately for analysis,  giving us  data on  one  sludge sample
before it enters the tank  and  on effluent  samples from  three  depths in the
tank as it is drained.  We do  not composite these samples because  the true
reactivity of the sludge may be diluted.

     We sample the flowing sludge with  a dipper  made  of a glass  beaker and
fiberglass pole, both of which are not  reactive  to the  sludge (SW-846,
1.2.1.3).  The samples are stored in nonreactive glass  containers.

     Sampling for semiannual  sludge recharacterizations and any  unscheduled
sampling follows the procedures described  above.

      We reviewed the scientific literature and  our previous  work  history to
identify any needs for special  sludge handling procedures during sampling.
This enables us to be certain  that our  employees  are  protected and our samples
remain representative during storage.

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                                             Model WAP - Tank:  Page 8  of 12


     The following information summarizes the previously described sampling
procedures:
  Containment Device                Lines leading to and exiting tank

  Sampling Technique                Grab samples

  Sampling Device                   Dipper

  Number of Samples Taken           Stream 1.  - one
                                    Stream 2.  - three, at beginning, midway,
                                         and end of tank drainage

  Comments                          1.   Wear rubber gloves, face shield, and
                                         self-contained breathing apparatus.
                                    2.   Make sure ventilation is adequate.
                                    3.   Place sample in linear polyethylene
                                         container.
                                    4.   Do not let sample dry out.
                                    5.   Protect sample from excessive heat
                                         and direct sunlight.
                                    6.   Potentially REACTIVE.

  References                        Technique:  SW-846*, Section 1.4.2
                                    Device:  SW-846, Section 1.2.1.3
!sW-846 "Test Methods for Evaluating Solid Waste" July 1982.

     Quality assurance and quality control procedures for waste sampling are
described in the appendix.


Analysis

     The wastewater treatment sludge has been characterized to confirm its
compliance with anticipated permit conditions.  Section 4 describes how we
selected the waste characterization parameters.  Table 2 identifies the test
method selected for each parameter and the rationale for selecting the
parameter.  All analytical methods listed in Table 2 are from EPA's "Test
Methods for Evaluating Solid Waste" (SW-846) or the American Society for
Testing and Materials (ASTM) compendium of test methods. Quality assurance and
quality control procedures for waste analysis are discussed in the appendix.

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                                             Model  WAP - Tank:  Page 9  of 12
     TABLE 2.  WASTE CHARACTERIZATION/RECHARACTERIZATION FOR WASTEWATER
                          TREATMENT PLANT SLUDGE1.2
Parameters
     Analytical  Method
  Rationale for
Parameter Selection
Reactivity    U.S. Gap Test or U.S.
              Internal Ignition Test^

% Water       ASTM 095 - Distillation, or

              ASTM D1796 - Centrifuge
                                   Assure storage safety
                                   Value used to assess
                                   reactivity
pH
pri Meter Method 9040 (SW-8464)      Verification of waste
^Applicable to both sludge streams (1 and 2).
^Semiannual recharacterization is planned.
^[Author's note:  These explosivity tests are currently under development by
the Bureau of Mines for EPA.]
4SW-846 "Test Methods for Evaluating Solid  Waste" July 1982.

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                                             Model  WAP  -  Tank:   Page  10  of  12
                                 APPENDIX

                  QUALITY ASSURANCE/QUALITY CONTROL PROGRAM
Program Goal
     Our program's goal  is to obtain accurate and  precise sludge
characteristics data resulting from sampling and analysis and  to  maintain
up-to-date documentation of those data.   The analytical  results we  obtain  are
available --

          to identify any anomalies that could lead  to  the sludge
          reacting or exploding,

          should a spill  occur onsite, and

          so we can notify our offsite hazardous waste  management facility
          contractor if a process or operation change is reflected  in  the
          sludge characteristics.

The amount of data we need to attain our goal  is minimal.  We  have  no  onsite
disposal; our offsite hazardous waste management facility analyzes  the sludge
themselves, and reactivity is the only potential threat the sludge  poses.
Therefore, determining sludge reactivity constitutes our primary  reason for
analysis.


Sampling Program

     The sludge is sampled by two people on our wastewater treatment  plant
staff.  They have been properly trained  to use the sampling and analytical
equipment described in Section 5, and their training program is described  in
another chapter of this application.

     Employee sampling skills are observed annually  by  our environmental
manager during the removal of sludge from tanks.  We feel this frequency is
sufficient since sampling with a dipper  is simple and characterization
sampling routinely occurs semiannually.   Once a sample  is taken,  the dipper is
decontami nated.

     When samples are taken, our employee logs vital  data in a field book,
labels the containers (see Figure A-l),  and hand carries the samples to the
treatment plant laboratory where he or she begins  analyzing them  within 24
hours.  Until analysis begins, the samples are stored in a designated  area
free from any sources of reaction.

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                                             Model  WAP - Tank:   Page 11 of 12
Collector
Place of Collection
                                              Sample No.
Date Sampled
Field Information jA
Time Sampled
'OSa-sri 
                                                                     p 
                    Figure A-l.  Sample container label.



   Source:  "Test Methods for Evaluating Solid Wastes"  SW-846, July 1982.

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                                             Model  WAP - Tank:   Page 12 of 12
Analysis Program
     The two trained analysts are monitored by the environmental  manager
during sludge analysis.  The tests for measuring moisture,  water, and pH
follow quality assurance/quality control  procedures outlined in the methods
descriptions.  The analytical data generated are documented and kept on file
in our environmental manager's office.

     The lab equipment is inspected and serviced semi annually and as required
on a nonroutine basis.  Any leftover sample is returned to  the storage tank.

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                                      Model  WAP -  Impoundment:   Page  1   of  16


                          MODEL WASTE ANALYSIS  PLAN

                             SURFACE IMPOUNDMENT


                          1.   Facility Description


     The Jones Company manufactures automobile  parts.   One  area  of our
manufacturing involves electroplating.  Our  primary  electroplating process  is
segregated cadmium, which uses the metals cadmium  and  chromium.   The  spent
plating/coating solution and  rinse water generated by  this  process are  sent to
our wastewater treatment plant, where chromium  and cadmium  are  precipitated
out of solution as a sludge.  Cyanide is destroyed  to a negligible complexed
concentration.  This sludge category is designated RCRA toxic due to  its
potential to contain cadmium, chromium, and  complexed  cyanide.

     The wastewater treatment sludge is transferred  to the  onsite surface
impoundment for storage and some dewatering.  Any  wastewater that separates
from the sludges is decanted  and piped to the wastewater treatment plant.  The
impoundment usually reaches sludge containment  capacity after 4 months  of
normal operation.  As the impoundment approaches capacity,  the  sludge is
removed and transported to an offsite hazardous waste  management facility.

     The surface impoundment  was designed specifically to store and partially
dewater the toxic wastewater  treatment sludges  from  the electroplating
process.  It is equipped with a butyl rubber liner that was selected  because
it is compatible with the electroplating sludges.  All other materials  of
construction of the impoundment were also selected to  be compatible with the
sludge.  Another chapter of this Part 8 application  provides a  detailed
description of the impoundment design.

     The Jones Company is requesting a RCRA  surface  impoundment storage permit
for wastewater treatment sludges generated by the electroplating process.  The
impoundment would be permitted to hold only  these sludges.

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                                      Model WAP - Impoundment:  Page 2  of 16


                    2.   Identification of  Impounded Sludge


     Table 1 lists the pertinent characteristics of the sludge to he impounded
onsite.  The data in Table 1 are based on three sets of samples collected and
analyzed over the past year.  Sludge characterizations were performed by the
analysts on our wastewater treatment plant staff and by ABC Labs.  Analytical
results from ABC Labs are found in Appendix I.  These data are consistent with
the background information document (BID) data published for this industrial
waste stream (F006).  The quality assurance and quality control procedures
used to characterize the sludge are described in Appendix II of this waste
analysis plan.

     Based on sludge analysis data collected in the past 5 years, we plan to
use the following sludge characteristics as boundary conditions:

          free and complexed cyanide < 100 ppm

          cadmium < 25,000 ppm

          total  chromium < 67,000 ppm

          pH 5.5 to 11

          total  organic carbon <0.5%

(Supporting sludge data are available upon request.)   Setting  these boundary
conditions helps alert us if a disturbance in the  waste generating  process
and, in turn,  waste characteristic changes have occurred.   Meeting  these
conditions will  help maintain the integrity of the surface impoundment
structure.

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           TABLE 1.  CHARACTERISTICS OF ELECTROPLATING WASTEWATER TREATMENT PLANT SLUDGE
Basis for Hazard
 Classification*
                            Physical
                             State
                         Process Code
                        Chemical  Composition^
Cadmium, hexavalent
chromium, nickel^
complexed cyanide,
(reactive, toxic)
Sludge, single-
  1 ayer
S044
                                                                         Total  and Amenable Cyanide:
                                                                                            Negligible

                                                                         Cadmium:  17,000 to 22,000 ppm

                                                                         Total  Chromium:  50,000 to
                                                                                          62,000 ppm

                                                                         Water:  70 to 80% by weight

                                                                         pH:  7.0 to 9.5

                                                                         Total  Organic Carbon: Negligible
                                                                                                                o
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                                                                                                                n>
!This sludge is assigned the RCRA Number F006 (40 CFR 261.31).
^Refers to characteristics of the sludge as it leaves the impoundment.
^Nickel is not used in this electroplating process.
^Refers to surface impoundment storage.
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                                      Model  WAP  -  Impoundment:   Page 4  of  16


                   3.   Surface Impoundment  Tolerance  Limits


     The surface impoundment has  the following limitations:

          the volume of sludge in the impoundment  must  not exceed the design
          capacity in order to prevent overflow  and contamination of adjoining
          areas,

          the impoundment should  not receive any wastes  that are incompatible
          with its butyl  rubber liner, e.g., organics,  so that it remains
          impermeable to the heavy metals;  thus  the total organic carbon in
          the wastes must be negligible,  and

          the impoundment should  not receive any wastes  that are incompatible
          with the metallic sludge, reacting to  damage  the liner or emit
          dangerous gases; this includes  free and  complexed cyanide that
          must remain negligible  in the waste.

These qualitative tolerance limits were established to  assure that the surface
impoundment safely stores the sludge without threatening environmental
contamination.

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                                      Model  WAP  -  Impoundment:   Page  5  of  16


                     4.   Waste Parameters  to be  Monitored
     To select waste parameters,  we 1)  reviewed  existing  information on the
sludge properties such as 40 CFR  261, Appendix VII,  and the  BID on RCRA waste
F006, 2) noted what properties  best indicate  any change in a waste, and 3)
compared this information to our  storage  facility's  design criteria so that we
can prevent any noncompliance with our  RCRA permit conditions.  These steps
included identifying the impoundment design and  operation limitations
described in Section 3.

     The sludge characteristics are only  expected to change  in the cadmium and
chromium concentrations, pH, and  the percent  volume  of water; therefore, these
parameters will be monitored.   The construction  materials in the  surface
impoundment are not sensitive to  the concentration of the metals, and the
pressure on the liner is limited  by the volume of impounded  waste that is
controlled by decanting.  Although these  characteristics  are not  a common
threat to the structural integrity of the impoundment, they  will  be monitored
so that information is available  in case  the  liner is ever damaged.  We
monitor sludge pH because unusual  values  may  indicate threatening sludge
anomalies.  The sludge typically  contains a negligible amount of  complexed
cyanide with no free cyanide, but if our  wastewater  treatment plant were
upset, the potential may exist  for cyanide to enter  the impoundment.
Therefore, free and complex cyanides are  monitored.  No organics  enter the
electroplating wastewater; however, total  organic carbon  will be  monitored to
assure no liner damaging organics are present.

     Thus, the keys to preventing any sludge  reactions are to make sure that
1) the cyanide levels are low,  2) organics do not enter the  wastewater, and
3) the sludge is in its customary form.  The  fact that the sludge is
transported to the impoundment  through  an isolated pipe precludes contamination
from other process wastes.

     The surface impoundment is not decontaminated after  it  is emptied because
it will be refilled with the same type  of sludge. Therefore, no
incompatibilities should exist, and tests for incompatibilities are not
conducted routinely.  The transport vehicles  are decontaminated by their owners
before receiving the sludge, and  they are constructed of  materials compatible
to the sludge, thus eliminating the potential for reactions.

     We decided how often it was  necessary to characterize our waste with
these tests by considering 

          the potential  for other materials on our site to be placed in the
          impoundment by mistake,

          the variability of our  sludge's composition, and

          the instability of the  waste.

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                                      Model  WAP - Impoundment:   Page 6  of  16


     We chose to have our in-house wastewater treatment plant  staff and  ABC
Labs recharacterize the sludge annually.  We prefer annual  recharacter-
izations, because --

     1) our years of operating data (available upon request)  indicate the
        sludge's hazardous constituents, chromium,  cadmium,  and  a  negligible
        amount of complexed cyanide, are consistently present; only the
        concentrations of chromium and cadmium and  the volume  of water may
        vary i n the sludge;

     2) variations in heavy metal  concentrations do not affect the
        impoundment's performance;

     3) the offsite hazardous waste management facility that  accepts the
        sludge analyzes it for their own purposes;  and

     4) there is a low probability of an unusual pH, or of  a  high
        concentration of free and/or complexed cyanide, or  of  organics present
        in the sludge.

     If we are ever notified by one of our process  area personnel  that the
electroplating or wastewater treatment processes or operations have changed,
we check to see if the sludge characteristics have  changed.   We  obtain as much
information about the change as our personnel can provide and  then take  an
unscheduled sample (according to our sampling procedures) from the wastewater
treatment plant.

     The analysis procedures include forwarding a sample to  a  commercial  lab,
ABC Labs, whom we have contracted  to perform atomic absorption analyses  for
chromium and cadmium in the sludge.  We will inform ABC Labs  of  any known
sludge changes, and they will analyze a sample.  ABC Labs will make every
effort to characterize the sludge  should they detect a significant change in
cadmium or chromium concentration.

     Our personnel will analyze sludge for free and complexed  cyanide and they
will proceed to characterize the sludge more completely if  a  significant
increase in cyanide is detected.  If the process change requires that we
analyze for any nonroutine parameters, sludge samples will  be  analyzed either
in-house or sent to ABC Labs.

     We will notify our offsite hazardous waste management  facility if any
changes occur, so the owner/operator can decide if  the sludge  is still
acceptable at the facility.  If the waste is not acceptable,  we  will  make
every effort to find another facility to receive the sludge.   In the interim,
the sludge will remain stored onsite in transport tankers.

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                                      Model  WAP - Impoundment:   Page 7  of 16


                       5.  Waste Sampling and Analysis
Sampli ng
     The sampling procedures were developed by first  identifying  the sludge
physical/chemical properties and means of containment,  i.e.,  surface
impoundment.  We selected an appropriate sampling device and  sample  container
after reviewing "Test Methods for Evaluating Solid Wastes"  (SW-846).  Since
the equipment selected is listed for material  of the  same physical form  as the
sludge, we believe that the equipment is suitable. We  reviewed the  scientific
literature and our previous work history to identify  any needs for special
sludge handling procedures.  This helps us to  be certain that our employees
are protected and our samples remain representative during  storage.

     It is practically impossible to sample all  areas within  the  surface
impoundment.  Since accessible areas are primarily around the periphery  of the
impoundment, our samples are somewhat limited  in their  representativeness of
the entire impoundment.

     We randomly sample impoundment areas within reach.   The  sample  areas
selected are based on a three-dimensional grid.   We divide  the accessible
areas into imaginary, sequentially numbered cells based  on  length, width, and
depth of the sludge and then use the random numbers table to  select  the
numbered cells to sample [See Appendix C of this manual],   A  grab sample is
taken from one randomly chosen cell at each depth level.   One sample per depth
level should be sufficient since there is little likelihood of damaging  levels
of cyanide being present in the sludge.

    Weighted glass bottles are used for sampling sludge  because 1) the bottles
help isolate samples taken at different depths (SW-846,  1.2.1.2), and 2) we
have found in previous efforts that the water  content of the  sludge  is
sufficient for it to flow into the bottle.  The  samples  remain stored in these
same weighted bottles until analyses are performed.

     The waste characterization, recharacterizations, and any unscheduled
sampling will follow the sampling procedures described  in this section.

     The following information summarizes the  sampling  procedures described
above:

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                                      Model WAP -  Impoundment:  Page 8  of 16
        Containment                     Surface impoundment

        Sampling Technique              Limited simple random sampling
                                        Grab sample

        Sampling Device                 Weighted bottle

        Number of Samples Taken         Grab one sample per depth level

        Comments                        1.  Wear goggles, rubber gloves,
                                            protective clothing, respirator,
                                            and face mask.
                                        2.  Store sample away from acids
                                            and standing water.
                                        3.  TOXIC WASTE.

        References                      Technique:  SW-846,1 Section 1.1.3.1
                                        Device:  SW-846, Section 1.2.1.2
1SW-846 "Test Methods for Evaluating Solid Waste" July 1982.


     Quality assurance and quality control procedures for waste sampling are
described in Appendix II.


Analysis

     The wastewater treatment sludge has been analytically characterized with
respect to its manageability onsite.  Table 2 lists the test method selected
for each parameter and the rationale for choosing each parameter.   All
analytical methods in Table 2 are EPA-approved.  Quality assurance and quality
control procedures for waste analysis are discussed in Appendix II. Our
wastewater treatment plant staff and ABC Labs will  perform these waste
analyses.

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                 TABLE 2.  WASTE CHARACTERIZATION/RECHARACTERIZATION FOR ELECTROPLATING
                                   UASTEWATER TREATMENT PLANT SLUDGE1
Parameters
          Analytical Method
           Rationale for
       Parameter Selection
Detection
  Limit
Cadmium
Total
chromium

Cyanide
pH

Total organic
carbon
AA Direct Aspiration, Methods
3050/7130 (SW-8462)

AA Direct Aspiration, Methods
3050/7190 (SW-846)

Total and Amendable Cyanide, Method
9010 (SW-846)

pH Meter, Method 9040 (SW-846)

Combustion - Infrared Method, Method
505 (APHA3)
Verification of waste                 5


Verification of waste                50


Identify potential reactivity


Identify potential corrosivity

Identify liner damaging organics     1,000
^Annual recharacterization is planned.
2SW-846 "Test Methods for Evaluating Solid Waste," July 1982.
3APHA American Public Health Association Standard Methods for the Examination of Water and
Wastewater 15th edition, 1980.
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                                      Model WAP - Impoundment:  Page 10 of 16
Sample Number:  3-1
Collected:  May 9, 1983
Received:  May 10, 1983

         Process Area
         Stream	

         Electroplating
         Wastewater
         Treatment
         Plant Sludge
                                  APPENDIX I

                               ABC LABORATORIES

                             Date:  May 10, 1983

                                              Client:
Parameter

Total
chromium
                               Cadmi um
                        The Jones Company
Results
 Test
Methods1
62,000 ppm     3050/7190
                22,000 ppm     3050/7130
lnTest Methods for Evaluating Solid Waste,"  SW-846,  July 1982.
 (Atomic Absorption Methods)
Signature of Certification:
                             I. Johnson, Office Branch Manager

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                                      Model WAP -  Impoundment:   Page  11 of  16
Sample Number:  13-1
Collected:  July 12, 1983
Received:  July 14, 1983

         Process Area
         Stream	

         El ectroplating
         Wastewater
         Treatment
         Plant Sludge
                                  APPENDIX  I

                               ABC LABORATORIES

                             Date:  July 13, 1983

                                              Client:
Parameter

Total
chromium
                               Cadmi urn
Results
                        The Jones Company
 Test
Methods1
57,500 ppm     3050/7190
                18,200 ppm     3050/7130
luTest Methods for Evaluating Solid Waste,"  SW-846, July 1982.
 (Atomic Absorption Methods)
Signature of Certification:
                             I. Johnson, Office Branch Manager

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                                      Model  WAP - Impoundment:  Page 12 of 16
                                  APPENDIX I

                               ABC LABORATORIES

                           Date:  October 1, 1983
Sample Number:  23-1
Collected:  September 30, 1983
Received:  October 1, 1983

         Process Area
         Stream	          Parameter

         Electroplating        Total
         Wastewater            chromium
         Treatment
         Plant Sludge

                               Cadmium
Results

50,000 ppm
17,000 ppm
   Test
 Methods1

3050/7190
3050/7130
       Methods for Evaluating Solid Waste,"  SW-846, July 1982.
 (Atomic Absorption Methods)
Signature of Certification:
                                       0
                             I. Johnson, Office Branch Manager

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                                     Model  WAP - Impoundment:   Page 13 of 16
                                 APPENDIX II

                  QUALITY ASSURANCE/QUALITY CONTROL PROGRAM
Program Goal
     Our program's goal  is to acquire accurate and precise sludge information
that could- affect our impoundment performance and to maintain an up-to-date
documentation of that information.   The analytical data we obtain are
available

          to prevent any damage to  our impoundment structure by the sludge,

          to prevent our sludge from reacting with the impoundment structure
          or any unexpected contents,

          should a spill occur onsite, and

          so we can notify our offsite hazardous waste management facility
          contractor if a process or operation change is reflected in the
          sludge characteristics.

The amount of data we need to obtain our goal  is minimal.   We have no onsite
disposal, and our offsite hazardous waste management facility also analyzes the
sludge.  Therefore, we analyze the  sludge for just five parameters to assure
that it meets those characteristics stated in the RCRA permit.


Sampling Program

     Two people on our wastewater treatment plant staff serve as sludge
samplers.  They have been properly  trained to use the sampling  equipment  as
described in our Part B application's "Training Program."   Their sampling
skills are observed annually by our environmental manager  during the sampling
sessions; we feel this is a sufficient frequency since sampling routinely
occurs annually.

     The weighted bottles used to sample sludge are decontaminated before
reuse.  When samples are taken, the employee logs vital  data in a field book,
labels the containers (see Figure II-l), and prepares a request for analysis
for those samples sent to ABC Labs  (see Figure II-2).  The employee drives  the
samples back to the laboratory, properly stores the ABC Labs samples for  pickup
(within 48 hours), and then proceeds to our lab to analyze a sample for cyanide
within 24 hours.

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                                     Model  WAP  -  Impoundment:  Page 14 of 16
Collector     ( ,    r^-J\JCi. _ Sample  No.    IS -I
Place of Collection
                    CS.
Date Sampled    AZ&rrtjfa*) 33 ,  M X3     Time  Sampled   3 : f)Q
             ^    ,.__..  _^;
Field Information  Jf&rnJji    A
                         A          /             /
                                               t^C<
                                                 /
                     Figure  II-l.   Sample  container label.
     Source:   "Test  Methods  for  Evaluating  Solid Wastes" SW-846, July 1982.

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                                    Model  WAP - Impoundment:  Page 15 of 16
Collector
.* V./J7J.ZAAJ.
               TORY  SECTION2
Received
         by    k .   ^
                                         Title
Analysis Required
                                            Date
1 Indicate whether sample is  soil,  sludge, etc.
2 Use back of page for  additional  information relative to sample location.
                   Figure II-2.   Sampling analysis request.

    Source:  "Test Methods  for  Evaluating Solid Wastes" SW-846, July 1982.

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                                     Model WAP - Impoundment:  Page 16 of 16
Analysis Program
     Our sampling personnel are also trained as analysts.  Their training
program is described later in this application.  The analysts are monitored by
the environmental manager during sludge analysis.  The test for measuring
cyanide follows quality assurance/quality control procedures outlined in the
SW-846 method description.  The analytical data we generate are documented and
kept on file in our environmental manager's office.  The lab equipment used is
inspected and serviced semi annually and as needed on a nonroutine basis.  Any
leftover sample from our analysis is returned to the surface impoundment.

     All atomic absorption analysis procedures that our company requires have
been specified in our contract with ABC Labs.  ABC is a commercial  laboratory
with trained analysts who are retrained annually.  They maintain a rigorous
quality assurance/quality control program that is available for review by EPA
upon request.  All of their hazardous waste analyses are conducted for The
Jones Company within 72 hours and comply with SW-846 quality assurance/quality
control procedures for specific test methods.  Analytical data are documented
and returned to us for evaluation by our environmental  manager and then filed.

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                                     Model  WAP - Waste Pile:   Page 1  of  15


                          MODEL WASTE ANALYSIS PLAN

                                  WASTE PILE


                          1.   Facility Description


     The Color Company manufactures four inorganic chrome  pigments:   chrome
yellow and orange, molybdate  orange, and zinc yellow.   These  pigments are
produced in simultaneous processes, and the resulting  wastewaters  are routed
to the company's treatment plant.   The sludge from the treatment plant
contains hexavalent chromium  and lead that  cause it to be  classified as a RCRA
hazardous waste.

       A vacuum filtration unit removes approximately  30 percent of  the water
from the sludge.  The filter  cake from this device is  stored  onsite  in two
sheltered waste piles that are filled sequentially.  The filter cake dries for
several months in the piles until  enough is accumulated for transportation to
an offsite hazardous waste management facility to he economical.

     The waste piles are constructed with leachate collection systems and
polyvinyl chloride (PVC) membrane liners.  They were designed specifically to
hold the wet filter cake produced  by vacuum filtration of  the wastewater
treatment pigment sludges.  All materials of construction  were selected in
keeping with their compatibility with the filter cake.  Another chapter of
this Part B application provides a detailed description of the waste pile
design.

     The Color Company is requesting a RCRA permit to  store the pigment filter-
sludge cake in the waste piles.  The waste  piles would be  permitted  to hold
only the filter cake.

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                                     Model  WAP - Waste Pile:   Page 2  of 15


                      2.  Identification of Wastes Piled


     Listed in Table 1 are the filter cake characteristics that are important
in operating the waste piles in compliance with RCRA permit conditions.  This
characterization was performed by the analysts on our wastewater treatment
plant staff and by XYZ Labs.  (An example XYZ lab report is found in Appendix
I.)  The characteristics in Table 1 reflect the analysis results from eight
samples of the filter cake taken at 6 to 8 week intervals over a period of 1
year.  These results are supported by operating data collected over the past 10
years and by data presented in EPA's background information document (BID) on
these waste streams (K002, K003, and K004).  Quality assurance and quality
control procedures used to characterize the filter cake are described in
Appendix II of this waste analysis plan.

      The filter cake must meet the following boundary conditions:

        total chromium   < 350 ppm         pH                  9.2 to 11.5

        lead             < 100 ppm        krichloroethylene   < 0.25%

        water            <_ 70%            Vthyl benzene       < 0.25%

These boundary conditions have been established so as to identify significant
changes in waste characteristics and any anomalies in waste generation
processes.
 iTrichloroethylene and ethyl benzene are used as solvents onsite, but they are
 not normally released to the wastewater treatment system.
 [Note:  This model waste analysis plan will not address the management of
 these spent solvents.  A real waste analysis plan would be required to do so.
 A separate model plan in this manual (container storage) addresses this issue.]

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       TABLE 1.  CHARACTERISTICS OF MOIST FILTER CAKE FROM WASTEWATER TREATMENT PLANT1
RCRA2         Associated                Physical
Number          Hazard                   State                    Chemical Composition^


K002,     Hexavalent chromium,    Solid, single-layer      Total chromium:  50 to 200 ppm
K003,     lead (toxic)
K004                                                       Lead:  20 to 70 ppm

                                                           Water:  55 to 65% by weight

                                                           pH:  9.7 to 11.0

                                                           Trichloroethylene:  Not detectable

                                                           Ethyl benzene:  Not detectable
^Management of the filter cake falls under Process Code S03, storage in waste piles.                     .
2These streams are listed in 40 CFR 261.32.                                                              5L
^Refers to composition of filter cake as it leaves vacuum filtration unit.                               ^
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                                     Model  WAP  -  Waste  Pile:   Page  4  of  15


                       3.   Waste Pile Tolerance Limits
     The waste piles have the following limitations:

          The volume of filter cake in the waste  pile  must  not  exceed the
          design capacity in order to prevent  spills.

          The waste pile should not receive any filter cake that contains
          greater than 70 percent water,  so as to prevent the generation of
          liquids.

          The filter cake should not be waste  piled  if its  pH falls  outside
          the 9.0 to 12.0 range because this could potentially  damage the
          liner.

          The waste pile should not receive any wastes that are incompatible
          with the filter cake or waste pile materials of construction  (e.g.,
          the PVC membrane liner) such as the  trichloroethylene and  ethyl
          benzene solvents used onsite.  This  avoids reactions  that  may lead
          to contamination of the area.

These tolerance limits represent those qualitative and quantitative  waste
characteristics that the waste pile structures can manage within the RCRA
permit conditions.

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                                     Model  WAP - Waste Pile:   Page 5   of  15


                  4.  Filter Cake Parameters  to he Monitored


     To select the appropriate waste parameters to monitor,  The  Color  Company
1) reviewed existing information on the waste properties,  2)  noted what
properties best indicate any change in the  filter cake,  and  3) compared this
information to the waste pile design criteria so that  we can  prevent any
noncompliance with RCRA permit conditions.

     Our operating experience has shown that  the filter  cake  characteristics
are only expected to vary in lead and chromium concentrations, the percent
volume of water, and the pH.  (See Appendix C of this  Part  B  application  for
sample operating data.)  The waste pile limitations in Section 3 confirm  the
need for measuring percent moisture and pH.  It has been determined that  the
filter cake is neither ignitahle nor reactive; therefore,  it  is  unnecessary to
test for these characteristics.   (Test results are available  upon request.)

     The metal concentrations in the cake will vary depending on pigment
production rates.  Since the waste pile PVC liners are not  sensitive to the
concentrations of these metals,  any changes would not  influence  the waste pile
performance.  However, chromium  and lead are  measured  1) to  ensure compliance
with the RCRA permit waste description, 2)  to assure waste  composition
consistency, and 3) to be prepared should a spill  occur  onsite.

     The percent volume of water in the filter cake is a factor  that needs
monitoring.  Liquids should not  be allowed  to accumulate at  the  base of the
waste pile; therefore, the filter cake must be sufficiently  dewatered  to
minimize liquids.  A vacuum filter cake should be able to  retain 70 percent.
water.  Any volumes greater than this may create liquids that could
potentially leak and transport metals into  the environment  if the waste pile
liner were damaged.  The pH of the typical  alkaline filter  cake  is measured to
indicate a change in the filter  cake's characteristics.  Unusual  filter cake
pH values could damage the pile  liner and cause leakage.

     The Color Company has considered the potential  for  1iner-damaqing organic
constituents to he present in the filter cake.  Based  on our  knowledge that
the pigment producing processes  use no organics directly,  we  have no reason to
suspect that liner-damaging organics would  be present  in the  filter cake.
However, trichloroethylene and ethyl benzene  are used  as cleaning solvents but
are normally kept separate from  the wastewater streams.  We will  analyze  for
these solvents to assure they are not present in the sludge.

     We decided how often to characterize the filter cake  by  considering  --

          the potential for other materials onsite to  be mistakenly
          combined with the waste pile filter cake,

          the variability of the filter cake  composition,  and

          the likelihood of the  filter cake undergoing changes that would
          alter its permitted characteristics.

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                                     Model WAP - Waste Pile:  Page 6  of 15


     The hazardous constituents, chromium and lead, are consistently present
 in the filter cake; only their concentration, the volume of water, and perhaps
 the pH may vary.  The offsite hazardous waste management facility that accepts
 the waste pile material also analyzes it for their own purposes.  For these
 reasons and the low probability that unscheduled wastes will be inadvertently
 mixed with the filter cake, we have decided to perform routine
 recharacterization annually.  If there is any indication that an unusual
 quantity of leachate is being generated by the filter cake in the waste pile,
 an unscheduled sample will be taken and analyzed.

     When the waste piles are emptied for offsite management, their bases are
 not decontaminated because they will be covered again with the same type of
 filter cake; therefore, no incompatibilities would exist.  The transport
 vehicles are decontaminated by their owners before receiving the filter cake,
 and they are constructed of materials compatible with the sludge.

     The filter cake from wastewater treatment is the only waste stored in the
 piles.  However, if we ever suspect or are notified by one of our process area
 personnel that the pigment producing process or wastewater treatment process
 or their means of operation have changed, measures will be taken to determine
 if the filter cake has changed in character.  We will obtain as much
 information about the change as our personnel can provide and take an
 unscheduled sample of the filter cake from the wastewater treatment plant.
 The sample will  be split and one portion will be forwarded immediately to XYZ
 Labs, Inc.  for analyses for chromium, lead, trichloroethylene, and ethyl
 benzene, and we will  inform them of any suspected property changes in the
 sample.  We will  request results of the analyses within 72 hours.  Should
 their analyses indicate a significant change in lead or chromium concentration
 or the presence of trichloroethylene or ethyl benzene, every effort will  be
made to characterize the waste so that we can 1)  inform our offsite contractor
of the change, 2) take measures to protect the waste pile liner, and 3) be
 prepared should a spill occur onsite.

     Our personnel  will analyze the unscheduled sample for pH and percent
water.  If  the filter cake contains greater than 70 percent water, it will  be
 returned to the plant for additional vacuum filtration.  If the pH is outside
the boundary conditions (i.e., pH 9.2 to 11.5), an additional  characterization
will  be required  to determine if waste components are present that could
 influence waste pile performance.  Any analyses for nonroutine parameters that
 are required will  be performed either in-house or by XYZ Labs.

     The offsite  hazardous waste management facility contractor who normally
 receives the waste pile material  will be notified of any change in filter cake
characteristics  so that it can be determined if the waste is still  acceptable
at the facility.   If  it is not acceptable, The Color Company will  make every
effort to find another hazardous waste management facility to receive the
filter cake.   In  the interim, the filter cake will  remain stored onsite in  a
tanker truck.

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                                     Model  WAP  -  Waste  Pile:   Page  7   of  15


                       5.   Waste Sampling  and Analysis
Sampling
     Table 2 identifies the representative sampling  information  selected  for
the filter cake waste and for leachate that may  accumulate  in  the waste pile
sump.

     It is practically impossible to sample all  areas  within each waste pile
because access for sampling is limited to within a few feet of the  pile's
perimeter.  Furthermore, sampling filter cake only around the  perimeter would
not be completely representative of all  of the filter  cake  piled.   Also it  is
important to know the moisture content,  pH, and  the  potential  presence of
liner-damaging organic solvents in the filter cake before it enters the waste
pile in order to prevent piling unacceptable wastes"!   Therefore, to solve the
representative sampling problem and to monitor the moisture content of the
waste, we sample the filter cake in the  small  temporary  storage  container at
the vacuum filter area.  From this container,  a  grab sample of the  filter cake
is taken randomly.  We see no need to divide the temporary  storage  container
into a grid for random sampling.  The container  is small  (less than 5 cubic
yards), limiting the potential for unusual  variations  in sample  compositions.
A standard Gl-CM polyvinyl  chloride trier will be used in sampling.  This trie
is nonreactive to the filter cake.  Should any leachate  be  generated and
collected in the waste pile sump, we will  take a grab  sample with a Coliwasa
device or weighted bottle submerged near the bottom  of the  sump.
Representative sampling techniques such  as simple random sampling cannot  be
used in this case.  All samples are stored in containers of nonreactive linear
polyethylene (LPE) as described in SW-846, Section 1.2.2, until  analysis.

     We reviewed the scientific literature and our previous work history  to
identify any needs for special filter cake handling  procedures.  This helps us
to be certain that our employees are protected and that  the waste samples
remain representative during storage.

     The approach described above pertains to characterization and
recharacterization sampling as well as to unscheduled  sampling of the filter
cake.

     Quality assurance and quality control  procedures  for waste  sampling  are
described in Appendix II.


Analysis

     The wastewater treatment filter cake has been analytically  characterized
to assure its manageability onsite.  The approach to choosing  characterization
parameters is described in Section 4 of this plan.   Table 3 identifies the
test methods for each parameter along with the rationale for the selection  of
each parameter.  All of the analytical methods listed  are EPA-approved.
Quality assurance and quality control procedures for waste  analysis are
described in Appendix II.  Our in-house wastewater treatment plant  staff  and
XYZ Labs performed the initial characterization  of the filter  cake, and they
will recharacterize it annually.

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                                TABLE 2.   FILTER CAKE  SAMPLING INFORMATION
       Stream
(and Containment Device)
 Sampling Method
Rationale for Selection
 of Sampling Technique
    Comments
1.   Moist filter cake
    from wastewater
    treatment plant
    (Temporary sludge
    storage container at
    vacuum filter area)
One grab sample
with trier (SW-846,
Section 1.2.1.5)
   Grab sample
   preferred in order
   to avoid dilution
   by compositing.
1.  Wear rubber gloves,  apron,
   shoes, mask, and breathing
   apparatus.
2.  Use linear polyethylene
   sample container.
3.  Toxic.
2.  Waste pile leachate,
    homogeneous liquid
    (Sump)
One grab sample with
Coliwasa or weighted
bottle. Sample near
bottom of sump.
(SW-846, Section
1.2.1.1).
   Homogeneity of
   liquid requires
   only simple random
   sampling. If there
   is precipitation
   of any metal,
   highest concentration
   will occur near
   bottom.
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1. Do not collect sample
   during rainfall.
2. Put in linear
   polyethylene container.
3. Potentially toxic.
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                                 TABLE 3.   HASTE  ANALYSIS PARAMETERS  AND  METHODS
Stream
     Parameters      Analytical  Methods^
                         Detection Limit
                              (mg/L)
Rationale for Parameters
1. Moist filter cake
   from wastewater
   treatment plant^
2. Waste pile
   leachate^
      Total
     chromium

       Lead


     Moisture


        PH


Trichloroethylene


Ethyl benzene
       Total
      chromium
AA Methods 3050/7190          0.05
(SW-846)

AA Methods 3050/7420           0.1
(SW-846)

ASTM D95 - Distillation,
or D1796 - Centrifuge

pH Meter Method 9040
(SW-846)

GC Method 8010             1.2 X 1(H
(SW-346)

GC/MS Method 8240          7.2 X 10~3
(SW-846)

AA Methods 3010/7190          0.05
(SW-846)
Verification of waste.
                                                                                     Verification of waste.
No more than 70% water
allowed in waste.

Identification of
corrosion threats.

Identify the presence of
liner-damaging organics.

Identify the presence of
liner-damaging organics.

Toxic parameter; reflects
presence of filter cake
constituents.
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-------
                                            TABLE 3.   (continued)
Stream
Parameters      Analytical  Methods^
Detection Limit
     (mg/L)
Rationale for Parameters
                            Lead
                             PH
                     Trichloroethylene
                     Ethyl  benzene
                AA Methods 3010/7420
                (SW-846)
                pH Meter Method 9040
                (SW-846)

                GC Method 3010
                (SW-846)

                GC/MS Method 3240
                (SW-846)
      0.1
  1.2 X 10-4


  7.2 X 10-3
      - American Society for Testing and Materials.
SW-846, "Test Methods for Evaluating Solid Waste," July 1982.
^Annual waste recharacterization is planned.
      checked weekly for leachate collection.  Will analyze as necessary.
Toxic parameter; reflects
presence of filter cake
constituents.

Assure effective waste-
water treatment.

Identify the presence of
1iner-damaging organics.

Identify the presence of
liner-damaging organics.
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                                            TABLE 3.  (continued)
Stream
Parameters
Analytical Methods
                                                            1
Detection Limit
     (mg/L)
Rationale for Parameters
                            Lead
                             PH
                     Trichloroethylene
                     Ethyl benzene
                AA Methods 3010/7420
                (SW-846)
                pH Meter Method 9040
                (SW-846)

                GC Method 8010
                (SW-846)

                GC/MA Method 8240
                (SW-846)
                               0.1
                           1.2 X 10-4


                           7.2 X lO-3
      - American Society for Testing and Materials.
SW-846, "Test Methods for Evaluating Solid Waste," July 1982.
^Annual waste recharacterization is planned.
      checked weekly for leachate collection.  Will analyze as necessary.
                  Toxic parameter; reflects
                  presence of filter cake
                  constituents.

                  Assure effective waste-
                  water treatment.

                  Identify the presence of
                  liner-damaging organics.

                  Identify the presence of
                  liner-damaging organics.
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                                     Model WAP - Waste Pile:  Page 11 of 15
  SAMPLE
Sample Number:  1-1
                                   APPENDIX I

                               XYZ LABORATORIES

                          Date:  February 13, 1983

                                                 Client:  The Color Company
Collected:  February 12, 1983
Received:  February 12, 1983
Sample
Number

1-1
              Process Area
              Stream	

                   1.
Parameter

Total
chromium
Results
100 ppm
 Test
 Method1

3050/7190
                              Lead
                                                       50 ppm
                                      3050/7420
                              Trichloroethylene
                                                      Not
                                                      Detectable
                                        8010
                              Ethyl benzene
                                                      Not
                                                      Detectable
                                        8240
l"Test Methods for Evaluating Solid Waste,"  SW-846.  July, 1982,
 (Atomic Absorption Methods)
Signature of Certification:

                                       d) &-L,
                             Jane Doe, President

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                                     Model  WAP  -  Waste  Pile:   Page  12 of  15
                                 Appendix II

                  Quality Assurance/Quality  Control  Program
Program Goal
     The program's goal  is to obtain accurate  and  precise  waste  analysis  data
and maintain up-to-date  documentation of those data.   The  analytical data we
obtain are available 

          to prevent any damage to  the waste pile  structure  by the  filter
          cake,

          should a spill  occur onsite, and

          so we can notify our offsite hazardous waste management facility
          contractor if  a process  or operation change  is reflected  in  the
          filter cake characteristics.

The quantity of data we  need to attain our  goals is  not major.   We  have  no
onsite disposal, and our offsite hazardous  waste management  facility analyzes
the sludge also for their purposes.


Sampli ng Program

     We sample and analyze the waste except that the analyses for chromium,
lead,  trichloroethylene, and ethyl  benzene  are performed by  XYZ  Labs.  Two
people on the wastewater treatment  plant staff serve as both samplers  and
analysts, and they have  been properly trained  to use the sampling and
analytical equipment described in  Section 5.   A description  of their training
is found in the "Training Program"  chapter  of  this  Part B  application.   Their
sampling skills are observed annually by our environmental manager  during the
sampling sessions.  We believe this  is a sufficient  frequency since
characterization sampling routinely  occurs  annually.

     Once a sample is taken, the trier is decontaminated.  When  samples  are
taken, the employee logs vital  data  in a field book, labels  the  containers
(see Figure II-l), and hand carries  them to a  designated storage area  until
XYZ Labs picks up the samples (within 24 hours).   Our  sampling employee
prepares a request for analysis for  those samples  sent offsite for  analysis
(see Figure II-2) and then proceeds  to analyze the  filter  cake (within 24
hours) for all remaining parameters  at the  wastewater  treatment  plant
1aboratory.


Analysis Program

     The Color Company's two trained analysts  are  monitored  by the
environmental manager during filter  cake analyses.   The test methods used

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                                      Model WAP  -  Waste Pile:   Page 13 of 15
Collector   /S   jQCUi4iAJ	 Sample  No.    /-/



Place of Collection  !b//lAToMJiL/[fAJ -Jj
\r LJttAiOuCutfyU (JAJ/JU I jCLrrLfLtt^Lfi/u^  Af&LfLCJi;
.-...    ,^  ^,    _        ....
Date Sampled  (fyjMrtQ  6,  tf &1 _ Time  Sampled  / ; 3 -f p , m .
Field Information  JyHSj(jL \J&LfctM)  \
                   -.-,,.     .^^

                      Figure II-l.   Sample container  label.



    Source:  "Test Methods  for Evaluating Solid Wastes"  SW-846, July 1982.

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                                     Model  WAP  - Waste Pile:  Page 14 of 15
Collector /]
                          Date  Sampled /p/k I S3      Tiie  /: 3? Q./yi. Hours
Affiliation of Sampler
                                                               yyid
                                                             r\nc>(30
           number      street         '    city       state        zip

Telephone fCCg) 5S5- /3 1 3. _ Company  Contact  J.
LABORATORY
SAMPLE
NUMBER

TCC -I
                COLLECTOR'S
                SAMPLE  NO.
                                   TYPE  OF
                                   SAMPLE1
                                                    FIELD  INFORMATION2

Analysis Requested
              OrftfL
              ,,...
Special Handling and/or Storage

                             a
                                                    jCi~Trta
                                                    ~"-
                                           . To KJTd .
PART II:  LABORATORY SECTION2
Received by
                                 Title
                                                  .Xfe LoAo Date
                                                                  /T
Analysis Requi red J&faJ?
  Indicate whether sample is soil,  sludge,  etc.
2 Use back of page for additional  information relative  to  sample  location.
                  Figure II-2.   Sampling analysis  request.

   Source:  "Test Methods for Evaluating Solid  Wastes"  SW-846,  July  1982.

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                                     Model  WAP - Waste Pile:   Page 15  of 15


follow quality assurance/quality control  procedures outlined  in each
EPA-approved method.  The analysts register the receipt of each sample in the
lab log before analysis begins.

     The analytical  data we generate are documented and kept  on-file in the
environmental manager's office.  The lab equipment used is inspected and
serviced semiannually and as required on a  nonroutine basis.   Any leftover
sample from the analysis is returned to the waste pile.

     All atomic absorption analysis procedures have been specified in  the
Color Company's contract with XYZ Labs.  XYZ is a commercial  laboratory with
trained analysts who are retrained annually.  They maintain a rigorous quality
assurance/quality control program that is available for review by EPA  upon
request.  All of the hazardous waste analyses are performed within 72  hours of
receiving the sample.  The analyses comply  with SW-846 quality assurance/
quality control procedures for specific test methods.  XYZ Labs document their
analytical  data and  return them to us for evaluation and filing in the
environmental manager's office.

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                                    Model WAP  -  Land  Treatment:   Page  1  of 16


                          MODEL WASTE ANALYSIS PLAN

                               LAND TREATMENT!

                          1.  Facility Description


     The Refining Company is a refiner of petroleum products.   The  treatment
of wastewater from the refining process generates two  hazardous  wastes,
dissolved air flotation (DAF) float and American Petroleum  Institute (API)
Separator sludge.  These wastes are listed as  hazardous  in  40  CFR Part 261
primarily because of their toxic levels of lead  and hexavalent  chromium;
however, toxic organics may also be present in the wastes.

     The Refining Company desires to obtain a  RCRA permit to land treat the
DAF float and API Separator sludge on its site.  The  land treatment  process
involves spreading the wastes over a designated  plot  of  land followed  by
continued management.  The soil and applied wastes are tilled  to promote  waste
degradation, transformation, and immobilization  within a given  depth of soil
(treatment zone) as defined in the permit. Only  the DAF  float  and the  API
Separator sludge generated by us onsite will be  treated  at  the  facility.   No
nonhazardous waste streams will be land treated  at this  facility.

     As required under RCRA, a land treatment  demonstration will  be  performed
for EPA.  The results of this demonstration will indicate successful
degradation, transformation, or immobilization of hazardous constituents  in
the waste.  Another chapter of this Part 8 application provides  a detailed
description of the proposed treatment demonstration plan.
      waste analysis plan will not address the storage  of  hazardous  waste
before land treatment.  A real waste analysis plan would be  required to do so,
but it is excluded here because a separate model  plan has  been  prepared for a
storage facility.

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                                    Model WAP - Land Treatment:  Page 2  of 16


                     2.  Identification of Wastes Treated
     Table 1 identifies general physical and chemical characteristics of the
two types of wastes to be land treated.  The API Separator sludge is high in
solids, having a heavy sludge character.  It is not flowable as a liquid.  The
DAF float is flowable and is handled more like a liquid because of its low
solids content.

     The waste characteristics in Table 1 are based on analyses performed over
the past year by our in-house staff using EPA-recommended methods.  The
Appendix VIII analyses were done according to the methods described by EPA in
guidance memoranda issued on April 3, 1984, and May 25, 1984.  Quality
assurance and quality control procedures used to characterize the wastes are
described in the appendix to this waste analysis plan.

     After completion of the treatment demonstration, the Refining Company
will propose principal hazardous constituents (PHCs) for use as indicator
parameters for unsaturated zone monitoring at the full-scale land treatment
unit.  PHCs will be selected on the basis of their ability to indicate the
fate (degradation, transformation, and immobilization) of all hazardous
constituents in the waste.  A more detailed discussion of PHCs is provided in
the unsaturated zone monitoring plan.

     The Refining Company has established boundary conditions for the API
Separator sludge and the DAF float based on the results of recent and past
analyses of these wastes at our plant.  The Refining Company will use the
waste stream boundary conditions shown in Table 2 to determine if a given
batch of waste has characteristics that are typical of the API Separator
sludge or DAF float that the Refining Company land treatment facility is
permitted to manage.  These conditions were selected based on waste analysis
data from our years of operation.  If the characteristics of a given batch of
waste fall  outside these boundary conditions, the Refinery Company will
conduct a more detailed investigation of the waste batch and notify EPA of our
findings.  Section 4 describes in detail the Refinery Company's approach to
boundary condition analyses.  Based on our years of operating experience, we
would not expect the waste to fall outside these limits.  (Operating records
are available upon request.)

-------
                                       TABLE 1.  HASTE CHARACTERISTICS
                            Basis for
                             Hazard
                            Physical
                           Properties
                                        Chemical
                                       Composition
1.  API Separator
    Sludge (RCRA
    No.3 K051)
Chromium, Lead
(Toxic)
Density: 1.35 to 1.65 g/ml
2.  DAF Float
    (RCRA No.3 K048)
Chromium, Lead
(Toxic)
Density: 1.15 to 1.45 g/ml
Hater: 48 to 58% by weight
Electrical conductivity:
  1 to 3 mmhos/cm
pH:  2.5 to 4
Oil:  20 to 26% by volume
Solids:  21 to 27% by weight
Total organic carbon:
  8,250 to 9,450
Total chromium:  2,000 to
  4,000 mg/kg
Lead:  300 to 600 mg/kg
Additional 40 CFR 261
Appendix VIII constituents:4

Water:  77 to 87% by weight
Electrical conductivity:
  2 to 4 mmhos/cm
pH:  2.5 to 4
Oil:  11 to 14% by volume
Solids:  2 to 8% by weight
Total organic carbon:
  4,600 to 5,400
Total chromium:  25 to 100 mg/kg
Lead:  250 to 500 mg/kg
Additional 40 CFR 261
Appendix VIII constituents:4
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Iprocess code for both streams is D81.
^Both streams are single layer wastes.
3Refer to 40 CFR 261.32.
^Information on specific Appendix VIII  constituents was not available for this model.
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                                TABLE 2.  WASTE  STREAM BOUNDARY CONDITIONS
Parameter
Total Chromium (mg/kg)
Lead (mg/kg)
Water (% by weight)
API Separator Sludge
1,500 to 4,500
250 to 825
30 to 70
DAF Float
0 to 150
200 to 750
70 to 95
Electrical

  conductivity (mmhos/cm)                            0  to 5                                  0 to 6


pH                                                  2.5 to 6                              2.5 to 5.5


Total organic carbon (TOC) (mg/L)                8,000  to 9,750                         4,300 to 5,700

                                                                                                              2
Total phenols (ug/g)                                0 to 150                                0 to 75           .
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                                      Model  WAP - Land Treatment Page 5  of  16


                  3.  Land Treatment Process Tolerance Limits
      Tolerance limits represent those characteristics of a waste or waste
 mixture that a management process, e.g., land treatment, can handle within the
 facility's permit conditions.  For this land treatment facility, the process
 is limited in that we will  be permitted to treat only those wastes with
 characteristics designated in the permit, i.e., DAF float and API sludge.  We
 plan to apply these wastes separately to different land treatment plots.

      A treatment demonstration will  be conducted to prove that each waste can
 be land treated at the proposed facility without pretreatment. The design and
 management parameters for the proposed land treatment facility will be
 established in the permit based on this demonstration.  Because the
 demonstration will be made using waste typical for the Refinery Company, the
 waste stream boundary conditions, as defined in Table 2, can also serve as the
 tolerance limits.  The design and management conditions employed to
 successfully manage these wastes at the land treatment facility are defined  in
 the facility Operating Plan of this Part B application. Any deviation from
 these typical waste characteristics would require a modification to the
 Operating Plan.

      The primary boundary condition parameters that can also serve as
 tolerance limits are--

           pH values (Note:  The pH of the waste (2.5-4) is not favorable
           regarding mobility; the permit conditions will require liming to
           raise the pH),
>
           electrical  conductivity to estimate the soluble salts that may limit
           treatment efficiency, and

           water content and metals and organics concentrations to assure that
           the appropriate application rate is selected based on constituent
           concentrations that do not hinder treatment performance.

      Numerical values for these parameters are found in Section 2.

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                                     Model WAP - Land Treatment Page 6  of 16


                    4.  Waste Parameters to be Monitored


     This section identifies the waste parameters that will be monitored to
generate the information that the Refinery Company needs to properly manage
the API Separator sludge and DAF float at the proposed land treatment unit.
We have selected waste parameters that allow us to 1) demonstrate that the
waste characteristics are within the established boundary conditions, 2)
address process tolerance limits, and 3) successfully manage the waste at the
land treatment unit in accordance with 40 CFR Part 264, Subpart M.

     To select the appropriate waste parameters, we 1) reviewed existing
information on the waste properties, 2) noted what properties best indicate
any change in waste characteristics that affect treatability, and 3) compared
this information to our treatment process design criteria so that we can
prevent any noncompliance with RCRA permit conditions.  Since the RCRA permit
will be based on the type of waste treated, waste analysis parameters were
chosen based on those waste characteristics that affect treatability.

     The following parameters have been selected to monitor boundary
conditions/tolerance limits:  water content, electrical conductivity, pH,
total organic carbon, and Appendix VIII hazardous constituents including total
chromium and lead.  Of the Appendix VIII constituents, principal  hazardous
constituents (PHCs) will be monitored frequently.  A complete scan for the 89
Appendix VIII constituents specified by EPA will be performed with periodic
waste recharacterizations. [Refer to EPA's April 3, 1984, memorandum on land
teatment and Appendix VIII constituents.]  Because our wastes may contain low
concentrations of various phenolic compounds that are not biodegraded easily,
EPA has required that total phenols be measured.  Exceeding the boundary
conditions/tolerance limits for the waste characteristics could result in
untypical wastes that could contaminate the environment beyond the designated
treatment zone.  Parameters to be monitored for RCRA waste characteristics
include ignitability (flash point), reactivity, and EP toxic metals in
addition to total chromium and lead.  These characteristics will  be monitored
with periodic waste recharacterizations.  Specific gravity will be measured to
help verify waste characteristics.

     In selecting waste characteristics to monitor, we also considered the
potential for halogenated organic constituents to be present in the sludges.
Based on our waste analyses of the sludge over the years and records of
sludges from similar refining facilities within our company, there is no
evidence that halogenated organics would be present in the sludge.  (These
data are available upon request.)

     Although a very low probability exists that wastes not permitted for
treatment could be mistakenly combined with the permitted wastes, such a
mistake could reduce land treatment performance.  We must be sure that the
wastes we handle are the DAF float and API Separator sludge and that the
wastes do not contain nonpermitted components (i.e., boundary conditions are
met).  This assurance is provided by sufficiently analyzing the wastes as
described in this plan.  We decided how often we felt it necessary to
characterize the waste with these tests by considering

-------
                                     Model WAP - Land Treatment  Page  7   of 16
          the potential for other materials onsite to be combined  with  the
          wastes by mistake,

          the variability of waste composition, and

          the likelihood of the sludge undergoing changes that  alter  its
          permitted characteristics.

     Experience has shown that the concentrations of chromium and  lead  in  the
wastes are relatively consistent over time.  However, we plan to analyze  the
wastes quarterly for these and other key parameters because  the potential
exists for environmental contamination if untypical wastes cause the  treatment
process to perform poorly.  Complete waste characterizations will  be  performed
annually to provide an accurate profile of the wastes.  All  analyses  will  be
performed in-house, and results will be recorded on the characterization  form
shown in Figure 1.  Should the quarterly analyses or annual
recharacterizations indicate that one or more of the waste parameters are
outside the permit conditions, we will handle the waste as described  below.

     If we are ever notified by one of the process area personnel  that  the
refining or wastewater treatment process or the means of operation have
changed, we will check the wastes for changes in character.  After obtaining
as much information about the change as our personnel can provide, we will
take an unscheduled sample from the tanks and completely characterize it  in
the onsite labs.  The characterization results will be evaluated to decide if
the waste characteristics are within the permitted ranges. If the  waste
characteristics do not comply, we will make every effort to  find an offsite
commercial hazardous waste management facility to receive the waste.   In  the
interim, the waste will remain stored onsite in mobile tanks or open  bed
trucks.

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                                      Model  WAP  -  Land  Treatment Page 8  of 16
                       The  Refining  Company  (Generator)
                                 P.O.  Box  00
                              Anytown,  USA 00000

                         EPA  ID  Number  USA 000000000


                                                   Date
1.   Waste Identification
     a.  Facility Waste Number	   Sample  Number 	
     b.  RCRA Waste Number 	
     c.  DOT Waste Number 	
     d.  Name of Waste
     e.  General Description of Waste  Generation  Process


2.   Sampling

     a.  Date Sampled                        b.  Sampling Method
     c.  Name and Affiliation of Sampler
     d.  Was sample taken during normal process operation?  	 Yes 	 No


3.   Physical State  at 21 C (70 F) 	  Solid 	 Sludge	 Liquid
4.   Specific Gravity



5.   Percent Water (Free Liquids)  Test Method




6.   Electrical  Conductivity  Test Method




7.   Corrosive   	 Yes 	 No   pH (regardless of corrosivity)





                      Figure 1.  Characterization form.

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                                     Model  WAP  -  Land  Treatment Page 9  of 16
8.   Ignitable 	 Yes 	  No        Flash  Point
         Test Method

9.   Reactive 	 Yes 	 No   Test  Method
          Description of Results
10.  EP Toxic Metals  	Yes 	 No
         Contaminant           Concentration            Method of Analysis
11.  Total Organic Carbon  (mg/L)  Test Method
12.  Organic Components  (Including PHCs  and Total  Phenols)  (percent by wt.
     or mg/L)
     Test Method
                     Authorized Signature
                     Title and Date
                 Figure 1.  Characterization  form  (continued).

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                                     Model UAP - Land Treatment Page  10 of 16


                        5.   Waste  Sampling  and Analysis
 Sampl ing
      The  approaches described below  pertain to characterization and
 recharacterization as well  as to unscheduled  sampling of the DAF float and API
 Separator sludge.

      The  DAF float is stored temporarily  in an enclosed mobile tank before it
 is  spread over the land treatment area.   This tank serves as a sampling point
 to  determine if the waste  is treatable.   We sample the float at three vertical
 points  from the access port in the tank.  We  choose not to composite the three
 ports'  samples because the  concentration  of heavy metals may not be evenly
 distributed throughout the  tank.  Compositing samples with different
 concentrations may mask the true metals concentrations in the sludge as it is
 pumped  from the tank to the land.  For example, if the bottom of the tank
 contained a high lead concentration, too  much lead would be applied to an area
 of  land.   This could hinder the treatment zone's performance and contaminate
 soils outside the zone.  A  Coliwasa  constructed of Type 316 stainless steel is
 used  to sample the float (SW-846, 1.2.1.1).   The collected sample is then
 placed  in  a container made  from nonreactive linear polyethylene (LPE) (SW-846,
 1.2.2).

      The  API sludge is sampled at each API Separator.  Random grab samples are
 taken at  three points within an imaginary, 3-dirnensional grid of the sludge in
 the separators.  [See Appendix C of  this manual.]  In order to obtain a
 reliable  profile of key parameters in the sludge, the samples are not
 composited because the potential exists for uneven distribution of metals that
 have  settled in the separators.  The sludge is sampled with a trier
 constructed of Type 316 Stainless Steel (SW-846, 1.2.1.5), and the sample is
 stored  in  LPE containers (SW-846, 1.2.2).

     We reviewed the scientific literature and our previous work history to
 identify  any needs for special  waste handling procedures that are necessary to
 ensure the safety of our employees who sample or handle the waste and to
 assure that the waste samples remain representative during storage.

     Table 3 contains information pertaining to all  the sampling procedures
 described, including safety precautions. Quality assurance and quality control
 procedures for sampling waste are described in the appendix.


 Analysis

     Table 4 identifies test methods for each waste parameter to be measured.
 Detection limits are provided for some methods where applicable.  The table
 also includes the rationale for choosing each parameter as discussed in
 Section 4. The test methods were selected from EPA's "Test Methods for
 Evaluating Solid Waste"  (SW-846), the American Society for Testing and
 Materials  (ASTM)  compendium of test  methods, and the American Public Health
Association's Standard Methods  for the Examination of Water and Wastewater.
Quality assurance and quality control procedures for waste analysis are
discussed in the appendix.

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                                 TABLE 3.  WASTE  SAMPLING  INFORMATION
       Stream
Containment Device    Sampling Method
                                    Comments
DAF Float
 Temporary storage
        tank
Grab sample with
Coliwasa  (SW-846,1
Sections  1.4.2
and 1.2.1.1)
1.  Wear goggles and  rubber
    gloves.
2.  Store sample in LPE
    containers.
3.  Grab one sample at each
    of three depth levels.
4.  Toxic waste.
API Separator Sludge
 API Separator
Random grab sample
with trier  (SW-846,
Section 1.2.1.5)'
1.  Wear goggles,  rubber
    gloves, and apron.
2.  Store sample in LPE
    containers.
3.  Grab one sample at each
    of three grid  areas
    randomly selected in  the
    separator.
4.  Toxic waste.
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isW-846, "Test Methods for Evaluating Solid Waste," July  1982.
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             TABLE 4.  WASTE ANALYSIS INFORMATION FOR API SEPARATOR SLUDGE AND DAF FLOAT1
  Parameters
Analytical  Methods
Detection
  Limit
  (wg/L)
 Rationale for Parameters
  Specific gravity


"^Percent water


 *Electrical
  conductivity

 *PH


  Flash Point


  Reactivity


  Arsenic


  Barium


  Cadmium


 *Total  chromium


 *Lead
 ASTM D1429, Method C
 (Erlenmeyer Flask)

 ASTM D95 - Distillation, or
 D1796 - Centrifuge

 Method 9045
 (SW-846)3

 pH Meter Method 9040
 (SW-846)

 Method 1010-Closed cup
 (SW-846)

 U.S. Gap Test or U.S.
 Internal Ignition Test^

 AA Method 7061
 (SW-846)

 AA Methods 3030/7080
 (SW-846)

 AA Methods 3030/7130
 (SW-846)

 AA Methods 3030/7190
 (SW-846)

 AA Methods 3030/7420
 (SW-846)
    2


   100


    5


    50


   100
                 Verification  of  waste.
Treatment performance affected
by percent water in waste.

Treatment performance affected
by conductivity of waste.

Treatment performance affected
by pH of waste.

Check for ignitability to assure
safe handling.

Check for explosivity to assure
safe handling

Identify unexpected constituents.
Identify unexpected constituents.
Identify unexpected constituents.
Verification of waste and
reference to assess treatment
performance.
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                                         TABLE 4.   (continued)
 Parameters
                      Analytical  Methods
                                                   Detection
                                                     Limit
                                                    (wg/L)
                                               Rationale  for Parameters
 Mercury


 Selenium


 Si 1ver


""Total  organic
 carbon

''Total  phenols
AA Method 7471
(SW-846)

AA Method 7741
(SW-846)

AA Methods 3030/7760
(SW-846)

APHA5 505
                       Method 8040-Gas chromatograph
                       (SW-846)
                                                       0.2
                                                       10
Appendix VI11 Constituents:
 Volatile
 organics


 Semi volatile
 organics
                        Method 8240-Gas  chromatograph/  ljjg/g
                        mass  spectrometer  (SW-846)
                       Method 8270-Gas chromatograph/
                       mass  spectrometer  (capillary
                       column technique)  (SW-846)
                                                                     Identify unexpected constituents,
                                                                     Identify unexpected constituents,
                                                                     Identify unexpected constituents,
                                                                     Treatment performance affected
                                                                     by organic content of waste.

                                                                     Required by EPA because of  slow
                                                                     biodegradation and effect on
                                                                     treatment.
                                                                     Identify  Appendix VIII constituents
                                                                     and  assess  treatment performance.
                                                                     Identify  Appendix VIII constituents
                                                                     and  assess  treatment performance.
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^Quarterly key analyses and annual  recharacterizations  are  performed.
^An asterisk indicates parameters are monitored  quarterly.
3SW-846, "Test Methods for Evaluating Solid Waste,"  July  1982.
^[Author's note:  These explosivity tests are  currently under  development by the Bureau of Mines  for  EPA.]
5APHA American Public Health Association  Standard Methods  for  the Examination of
 Water and Wastewater 15tn edition, 1980.
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                                    Model  WAP  -  Land  Treatment:   Page 14 of 16
                                  APPENDIX

                  Quality  Assurance/Quality  Control  Program
Program Goal
     The program's goal  is  to  collect  accurate  and  precise  waste
characteristic information  so  that  we  can  assure  that  the wastes  treated at
our faciity  reflect those waste  characteristics that the  process  is permitted
to treat.  This can be accomplished by  making sure  that the waste maintains
the permitted characteristics  of DAF float and  API  sludge.   We  generate a
great deal of data at our facility, and the success of the  treatment process
is especially dependent  on  the quality  of  these analytical  data.   Thus, this
quality assurance/quality control program  is carried out  to the fullest to
assure that  accurate and precise data  are  obtained.


Sampling Program

     Two of  our personnel will be trained  to sample wastes  as described in
this application's training  program section.  Their sampling skills are
observed quarterly during sampling  events  by our  operations manager.  Sampling
equipment is inspected for  decontamination and  operability  before each
shipment is  sampled, and each  inspection is documented.   We make  note of any
problems encountered and the corrective actions taken.

     All sample containers  are labeled  (see Figure  A-l),  and vital  sampling
information  is logged in the field  before  the sampler  drives the  samples to
the laboratory (see Figure  A-2).


Analysis Program

     Our lab personnel have  been  trained to perform the analytical  procedures
discussed in Section 5 of this waste analysis plan, and their training program
is described in this Part B  application.   Analytical skills are checked with
the blanks or standards that are  included  with  each analysis.   Lab  personnel
document receipt of each sample  and assign sample identification  numbers to
replicates.  The quality assurance/quality control  procedures for analysis
follow those outlined in each EPA-approved test method.  Upon receipt of the
sample, a lab employee logs  it into the daily lab record.   Tests  are completed
at least 24  hours before land application  to identify  any anomalies in time.
All test results are documented  on  the  characterization form shown  in Figure
1.

     Analytical  equipment is inspected  and serviced semiannually  in addition
to routine checks before each analysis.  Leftover samples are returned to the
containment  devices from which they were sampled.

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                                   Model  WAP - Land  Treatment:   Page  15  of  16
Collector   T ,   /'y.J	 Sample  No.
Place of Collection ID A-P
Date Sampled UUAJAJI  /J. /f #3	 Time  Sampled   /p:QQ & .
Field Information
                   p/J
                    Figure A-l.   Sample container label.
   Source:   "Test  Methods for  Evaluating Solid Waste" SW-846, July, 1982.

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                                   Model  WAP - Land Treatment:   Page 16 of 16
Sample Identification Number

1.  Waste Identification
2.  Purpose of Sampling
        7          fr
    a.   Sampling Point Location
    b.   Description
4.  a.  Number of Samples Taken

              Q-yU-

5.  Any Field Measurements Taken

        Parameter
                                                      Date
                                                      Time / o -.
                                            b.   Volume  per Sample
                                                Measurement
6.  Observations During Sampling

   jH^a^\ nevm.ajL-  JO^UA
                                /T
7.  a.  Sample Destination

      JlrtL-  JltoAAX.
                                                                          u
                                            b.   Means  of  Transport
                                 /P

                            Signature  of  Sampling  Person:
                           Figure  A-2.   Field  log.
   Source:   "Test  Methods  for  Evaluating  Solid  Wastes",  SW-846, July  1982.

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                                     Model  WAP - Incineration:   Page 1  of 20


                          MODEL WASTE ANALYSIS PLAN

                                 INCINERATION1


                           1.  Facility Description


     The Controlled Combustion Company operates a commercial  hazardous waste
incinerator, receiving wastes  transported in tankers  from offsite generators.

     We are requesting a RCRA  permit to incinerate halogenated  and
nonhalogenated solvent distillation recovery bottoms, in particular, from the
spent solvents methylene chloride, trichloroethylene, and acetone.  These
wastes  are designated RCRA hazardous because the first two contain toxic
compounds and the third contains an ignitable compound.   These  wastes do not
exhibit any reactive or corrosive characteristics.  It is anticipated that we
will accept additional wastes  for incineration in the future.

     The wastes described above require no treatment  before incineration.
They are documented as mutually compatible by "A Method  for Determining the
Compatibility of Hazardous Wastes" (EPA-600/2-80-076) and can be stored in a
common  area before incineration.

     The incinerator is designed to destroy and remove 99.99 percent of the
wastes' principal organic hazardous constituents (POHCs) so that little or no
emissions to the environment will occur.   Trial burns have been conducted for
EPA using methylene chloride as the indicator POHC. The  trial  burns destroyed
and removed more than 99.99% of the methylene chloride and maintained
performance standards (40 CFR  264.343) in which the trial burn  material
contained 5 percent chloride,  5 percent water, and 30 percent ash.
'This model waste analysis plan will not address the container and tank
storage of the wastes onsite since storage is addressed in other model  plans.
A real waste analysis plan would be required to detail  the storage aspects of
the facility.

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                                     Model WAP - Incineration:  Page 2  of 20


               2.  Identification of Wastes to be Incinerated


     The Controlled Combustion Company plans to incinerate distillation
recovery bottoms from spent methylene chloride, trichloroethylene, and acetone
in accordance with the RCRA permit.  Other wastes may be incinerated in the
future as long as the heats of combustion of each organic constituent in each
waste feed are greater than that of methylene chloride (POHC), i.e., they can
be burned more efficiently.  Heats of combustion must be greater in order to
assure that 99.99% of the constituents are destroyed and removed as was
demonstrated in the trial burns with methylene chloride.  The ash content,
chloride content, viscosity, and water content of each waste feed must be less
than that of the trial burn feed. Any waste feeds that do not meet these
conditions are restricted from incineration.

     Table 1 contains the pertinent characteristics of each hazardous waste to
be incinerated.  Our staff sampled and analyzed each of the wastes to provide
the initial  characterization.  They visited each generator's site and
collected samples three times at 2-week intervals.  Table 1 reflects the
analytical results of those sample analyses.  (Quality assurance and quality
control programs for sampling and analysis are described in Appendix I.)  Each
generator allowed us to review their waste analysis data over past years which
also agreed with our test results.  This initial characterization served to
establish that each of the wastes fell  into one of the waste categories
intended for incineration.  Figure 1 is the waste characterization form
completed for each waste.

     Based on our waste analyses and discussions with generators about the
consistency of their wastes, we have selected waste stream boundary conditions
of + 15 percent of the limits provided in Table 1.  These boundary conditions
wilT alert us to any untypical  wastes arriving at the facility that may affect
incinerator performance.  We do not anticipate that the waste characteristics
will  fall outside this range.  If they do, we will follow the contingency
procedures described in Section 4, "Parameters to be Monitored."

-------
                                      TABLE 1.  WASTE CHARACTERISTICS1
                          RCRA
                         Number^
           Basis for
           Hazard
           Li sting
                         Physical
                        Properties
                               Chemical
                             Composition
A-l Recovery Still
    Bottoms of Spent
    Halogenated Solvent
F001
Methylene
chloride
(Toxic)
A-2 Recovery Still
    Bottoms of Spent
    Halogenated Solvent
F001
Trichloroethylene
(Toxic)
Specific gravity:
0.95 to l'. 15
Heat of combustion:
7.49 to 9.16 kcal/g
(13,500 to 16,500 Btu/lb)
Ash:  5 to 7% by weight
Viscosity:  19 to 22
Centipoise

Specific gravity:
1.02 to 1.24
Heat of combustion:
5.99 to 7.33 kcal/g
(10,800 to 13,200 Btu/lb)
Flash point:  >32 C
(pure TCE, closed cup)
Ash:  3 to 6% by weight
Viscosity:  16 to 19
Centi poise
Methylene chloride:
18 to 22% by volume
Oil:  76 to 80% by volume
Water:  1 to 3% by weight
Trichloroethylene:
28 to 32% by volume
Oil:  66 to 70% by volume
Water:  1 to 3% by weight
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Model WAP - Incineration:  Page 4  of 20

































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-------
                                     Model WAP - Incineration:  Page 5  of 20
                                                       Date
1.  Generator
     a.   Name

     b.   Address



     c.   EPA ID Number
2.    Waste Identification

     a.  Facility Waste Number 	   Sample Number 	

     b.  RCRA Waste Number 	

     c.  DOT Waste Number 	

     d.  Name of Waste

     e.  General Description of Waste Generation Process


3.    Sampli ng

     a.  Date Sampled                       b.  Sampling Method

     c.  Name and Affiliation of Sampler

     d.  Was sample taken during normal process operation?  	 Yes 	 No
         If no explain:


4.    Physical State at 21 C (70 F) 	 Solid 	 Sludge 	 Liquid


5.    Specific Gravity



6.    Viscosity  (Centipoise)  Test Method



7.    Water Content (percent)  Test Method




                   Figure  1.  Waste characterization form.

-------
                                     Model WAP -  Incineration:   Page 6   of  20
8.   Total  Organic Carbon (ppui)  Test Method
9.   Heating Value (kcal/g.)  Test Method
10.  Ash Content (percent)  Test Method
11.  Corrosive   	 Yes 	  No      Test  Method









12.  Ignitable 	 Yes 	  No        Flash Point



         Test Method









13.  Reactive 	 Yes 	 No         Test  Method



         Description of Results
             Figure 1.  Waste characterization  form  (continued).

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                                     Model  WAP - Incineration:  Page 7  of 20
14.  Other Inorganic Components (Indicate percent by weight or mg/L)  Test Methc
15.  Organic Chloride  Test Method
16.  Organic Components  (Indicate percent by weight or mg/L and if a
     designated Appendix VIII POHC)  Test Method
     I certify the accuracy of this data and the representativeness of the

waste sample.

               Signature and Title	


               Date
               Figure 1.  Waste characterization form (continued).

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                                     Model  WAP - Incineration:   Page 8  of 20


                       3.  Incinerator Tolerance Limits


     The waste feed to the incinerator must be semisolid  or liquid  and have a
heating value that meets the temperature requirements of  the incinerator.   The
total feed rate to the incinerator must range from 7.56  X 10^ kcal/hr (30  X 10^
Btu/hr) to 1.26 X 107 kcal/hr (50 X 106 Btu/hr).  The heating value of each
organic constituent in the waste feed must  be greater than the  heating value for
the pure indicator POHC designated at trial burn - methylene chloride (1.7
kcal/g (3,067 Btu/lb)).  Methylene chloride attained  a 99.99 percent destruction
and removal efficiency during the trial hum. The chloride content  of the  waste
feed must not exceed 5 percent.   This limit, leads to  optimum scrubber removal of
chloride emissions. This value is the maximum concentration for which compliance
with incinerator performance standards was  demonstrated during  the  trial burn.
The waste feed must not have a water content greater  than 5 percent, because
water reduces heating value and, in turn,  burning efficiency.   Also, two types
of problems can arise if sufficient water  is present  to cause phase separation:
1) the potential for equipment damage if freezing occurred, and 2)  perturbation
of the combustion process if a slug of water were introduced into the feed.
Complying with these limits helps ensure that 99.99 percent of  the  POHCs will be
destroyed and removed.  Ash content of the  waste feed must be less  than 30
percent in order to comply with  particulate emissions standards.

-------
                                     Model  WAP - Incineration:  Page 9  of 20


                       4.  Parameters to be Monitored


     The distillation recovery bottoms must meet the chemical  and physical
requirements specified in the incinerator permit.  To select the analysis
parameters to represent the waste characteristics,  we 1)  reviewed existing
information on the waste properties such as generator data and EPA's
Background Information Document for the specific waste, 2) noted what
properties best indicate any change in the  waste, and 3)  compared this
information to the incinerator design criteria and  trial  burn  test results.

     The three categories of wastes are analyzed for specific  gravity,
viscosity, elemental  analysis (including metals), and total  organic carbon to
verify waste composition; corrosivity, reactivity,  and flash point to assure
safe handling.  Percent water, ash content, and heat of combustion are
monitored to assess various aspects of incinerator  performance. Wastes are
scanned by GC/MS for the presence of hazardous constituents.  Also,
waste-specific parameters to be determined  are methylene chloride,
trichloroethylene, organic chloride (total  organic  halogens),  flash point, and
acetone.  POHCs are monitored to estimate destruction and removal efficiency.
All the wastes we intend to manage are mutually compatible;  therefore, we see
no need to test routinely for compatibility.

     We plan to recharacterize the wastes periodically to identify changes
that cannot be verified by waste shipment screenings.  The frequency for
recharacterizing the wastes was selected by considering --

          the potential for restricted waste being combined  in a shipment,

          the variability of the waste composition  between shipments,

          the likelihood of a waste undergoing changes that  alter its
          permitted characteristics, and

          the prior history of the waste generator.

Section 5, "Wastes Sampling and Analysis,"  contains a description of the
analysis procedures to be followed and identifies the frequencies of waste
recharacterization.

     We screen shipments, because the potential may exist for generators  to
include, by mistake, wastes other than those permitted for incineration at our
facility.  This could affect the incinerator's destruction and removal
efficiency by reducing the heating value of the waste, for example.  Figure  2
displays the sequence of events that are to be followed when waste shipments
*  >-'ive at our facility. We developed the screening procedures based on our
v-.owledge of the generators and the wastes they ship.

     When a waste shipment arrives at the facility, we first check the
manifest for completeness and correctness.   At a minimum, we will look for the
following information on each manifest:

          a manifest document number;

-------
                          Model WAP -  Incineration:   Page 10  of 20
  Waste Shipment Arrives
Compare Shipment
   Externally to
   Its Manifest
 Visually Inspect
    Shipment
  Sample Waste
Analyze Waste for
 Key Parameters
 Evaluate Analytical Data
  Accept Waste
   Shipment
Discrepancy
                                        Contact
                                       Generator
                                       Discrepancy
                                          
                                        Contact
                                       Generator
                                       Recharacterize
                                           Waste
                           Reject
                           Waste
                          Shipment
                                      Evaluate Analytical Data
 Figure  2   Shipment  screening  procedures.

-------
                                     Model  WAP -  Incineration:   Page  11  of  20


          the generator's name, address,  and  EPA  identification  number;

          each transporter's name and EPA identification  number;

          the destination of the waste shipment,  i.e.,  hazardous waste
          management facility,  address, and  EPA identification number;

          an alternative hazardous waste  management  facility, address, and
          EPA identification number;

          a Department of Transportation  shipping name  and  number;

          the quantity or volume of waste in  the  shipment;  and

          a signed certification of the shipment's content.

The shipment will  be inspected  visually,  noting --

          if the shipment labels/placards match the  manifest;

          any irregularities in the shipment  (e.g.,  leaks);

          if any restricted wastes are visibly present; and

          if the waste appearance matches any previously  noted descriptions.

     It is standard procedure to check manifests  and inspect shipments
visually regardless of the waste.  Additional  sampling  and  analysis of wastes
are more dependent on the specific generator  and  the waste.  All of the  waste
shipments will be sampled as described in Section 5, "Waste Sampling  and
Analysis," but the analysis of  waste  shipments does  not always include
measuring all the parameters used in  the  initial  waste  characterization.  A
subset of these, known as "key  parameters,"  is selected,  so we can obtain the
best indication of waste identity and incinerability, within reasonable  given
time and labor constraints.  Four criteria are considered when selecting key
parameters.  These are 

          the need to identify  restricted wastes,

          waste characteristics that  affect  the incinerator's performance,

          the potential  ignitabi1ity, reactivity, or incompatibility  of  the
          wastes,  and

          parameters that best  indicate changes in waste  characteristics.

We feel assured that we can adequately screen incoming  shipments by basing  our
key parameters on these criteria.

     In the event  that a waste  shipment does  not  pass the screening tests, we
contact the generator and, if requested,  we  perform  a complete

-------
                                     Model  WAP - Incineration:   Page 12 of  20


recharacterization, analyzing for all  the parameters  previously  selected and
any additional  parameters that may be necessary.  Based  on these results, we
will accept or  reject the waste shipment.

     If we are  notified hy one of our generators or we suspect that  a waste
generating process or its operation has changed, we will  analyze the waste  to
see if its character has changed.  We will  obtain as  much information about
the change as the generator can provide, receive the  generator's approval to
take an unscheduled sample, and then completely characterize it.  We will
evaluate the characterization results to decide if the waste meets the permit
envelope of parameter limits when blended for waste feed. If it  does not, we
will reject the waste.

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                                     Model  WAP - Incineration:   Page 13 of 20


                       5.   Waste Sampling and Analysis
Samp!i ng
     The sampling procedures are based on the wastes'  physical/chemical.
properties and means of containment.   We selected  the  appropriate
representative sampling techniques, devices,  and containers  from "Test  Methods
for Evaluating Solid Wastes" (SW-846).  The equipment  selected  is listed  for
handling material of the same physical form as our waste.  Scientific
literature and work history volunteered by the generators  were  also reviewed
to identify any needs for special  waste handling procedures  necessary to
protect our personnel and keep our samples representative.   Based on this
review, we will be certain that the sampling  personnel  wear  goggles, rubber
gloves, and aprons; that the area  is  well-ventilated when  sampling; and that
personnel are fully aware that certain wastes are  toxic.

     Since the still bottoms will  be delivered in  tanker trucks, we will
screen each shipment by taking grab samples through the tank access ports.   A
vertical sample will be taken at each port so as to obtain as representative a
sample as possible across the depth of the tank, considering the limited
access.  Long glass tubing (SW-846, 1.4.1)(decontaminated  between samples)
will be used to obtain full vertical  samples. Sampling with  this tube will  be
based on the same principle as sampling shallow depths with  Coliwasas.  The
ASTM Method 0140-70 describes the tube sampling method. Waste  samples  will he
stored in glass bottles with teflon caps (SW-846,  1.2.2).

     The same sampling approach is used for routine waste  characterization  and
recharacterization and for unscheduled sampling of the wastes.

     Quality assurance and quality control procedures  for  waste sampling  are
described in Appendix I.


Analysis

     Table 2 identifies the test methods chosen to characterize and
periodically recharacterize the wastes and our rationale  for selecting  each
parameter.  Key parameters selected to screen the  wastes  in each shipment are
also identified.  All analyses will be performed in-house, and  all the
analytical methods are EPA-approved.   Quality assurance and  quality control
procedures for waste analysis are discussed in Appendix I.

     The frequencies of recharacterization are as  follows:  1)  streams  A-l  and
A-2 -semiannual, 2) stream B-l -annual, and 3) stream  C-l  -quarterly. They
were selected based on a ranking exercise that considers  the issues addressed
in Section 4.  [See Appendix E of this manual for  an explanation of this
ranking exercise.]

-------
                                     TABLE 2.  WASTE ANALYSIS INFORMATION
Stream*
    Parameters^
Analytical Methods3
Rationale for Parameters
All Streams



All Streams



All Streams


All Streams



All Streams



All Streams
All streams
Specific gravity



 Viscosity



*Water content


 Total organic carbon



*Heat of combustion



 Ash content
    Corrosivity
ASTM D891, Method C
(Specific Gravity
Balance)

ASTM D2170 (Kinematic
Viscometer)
ASTM D95 (Distillation)
APHA 505 (Combustion-
Infrared - Detection
Limit = 1 mg/L)

ASTM D240 (Bomb Calor-
imeter)(or 2015 (Adia-
batic Calorimeter))

APHA 209E (Total Volatile
and Fixed Residue at 550C)
SW-846, Method 1110
(Corrosivity Toward
Steel)
Waste verification.
Waste verification and assessment
of waste delivery system's
adequacy.

Assess burning efficiency and,
in turn, air requirements.

Burning efficiency.  Waste
verfication.
Assess burning efficiency.
Maintain compliance with
particulate emissions standards;
evaluate slag formation, and
assess if system's ash handling
capacity is sufficient.

Identification of corrosives  for
safe handling.
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-------
                                               TABLE 2.   (continued)
Stream^
                        Parameters2
Analytical Methods3
Rationale for Parameters
All streams


All streams


All streams



All streams
A-l, C-l


  A-2



  B-l
                        Flashpoint
                        Reactivity
                        Organochloride  content
                        (shipment  analysis of
                        B-l  is  not  performed.)

                        Volatile and  semivolatile
                        organic constituents.
                        Methylene chloride
                        Trichloroethylene
                       Acetone
SW-846 1010  (Pensky-
Martens Closed Cup)

U.S. Gap Test or U.S.
Internal Ignition Test^

SW-846, Method 9020
(Microcoulometric
Titration).

SW-846, Methods 8240
and 8250, respectively
(GC/MS; detection limits
vary based on constituent)

SW-846, Method 8010
(GC)

SW-846, Method 8010
(GC Detection Limit =
0.02 ug/L)

SW-846, Method 8015
(GC Detection Limit =
1  wg/L)
Waste verification.  Identification
of ignitables for  safe  handling.

Identification of  explosives  for
safe handling.

Maintain compliance  with  chloride
emissions standards  via hydrogen
chloride removal system.

Identify any hazardous  organic
constituents that  are present to
determine if Btu values exceed
methylene chloride's.

Verify toxic constituent. Monitor
destruction and removal.

Verify toxic constituent. Monitor
destruction and removal.
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Verify ignitable constituent.
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^Recharacterization Frequency:  A-l and A-2 - semiannual; B-l  - annual;  C-l  quarterly.
^Asterisk denotes key parameters measured with each shipment.
3APHA - American Public Health Association's  Standard Methods for the Examination  of  Water and Wastewater 1980.
 ASTM - American Society for Testing and Materials.
 SW-846  "Test Methods for Evaluating Solid Waste"  July 1982.
^[Author's note:  These explosivity tests are currently under  development  by  the  Bureau  of  Mines for EPA.]
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                                     Model  WAP  -  Incineration:   Page 16 of 20


     A waste will be rejected  if  recharacterization  analyses  indicate it does
not fall within our permit specifications.

     We have chosen to analyze discrete waste streams  for  the  parameters in
Table 2 rather than analyze the waste  feed.  Since our waste
recharacterizations and shipment  screenings  involve  the analysis  of discrete
waste streams, we plan to use  these test  results  to  characterize  the waste
feed rather than repeat those  tests again.   Waste feed properties will  be
estimated based on the volumes of waste streams blended together.  The  waste
feed will  be sampled and measured for  heating value  once a week  to ensure that
it remains under the heating value maximum  and, in turn, prevents damage to
the refractory materials.

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                                     Model WAP - Incineration:  Page 17 of 20
                                  APPENDIX I

                   Quality Assurance/Quality Control  Program
Program Goal
     Our program's goal is to obtain accurate and precise waste data so that we
can assure that the wastes we incinerate possess the chemical/physical  properti
specified in our permit.  We accomplish this by making sure that 

          the wastes meet the predetermined characteristics, and

          no restricted wastes are accepted.

We generate a great deal of data at the facility.  Therefore,  we carry  out the
quality assurance/quality control  program to the fullest  to assure that accural
and precise data are obtained.


Sampling Program

     Designated personnel  have been trained to sample waste shipments.   This P<
B application contains a chapter on their training program.  Our operations
manager evaluates the employees'  sampling skills quarterly. Sampling equipment
inspected for decontamination and  operability before each shipment is sampled.
Each inspection is documented, noting any problems and corrective actions  takei

     Since our facility handles more than one waste and one generator,  all  sam|
containers are labeled (see Figure 1-1), and vital  sampling information is logc
in the field (see Figure 1-2) before another employee drives the samples and ai
accompanying list of those samples to the laboratory for  analysis.


Analysis Program

     Our laboratory personnel have been trained to perform the analytical
procedures outlined in Table 2.   This Part B application  contains a descriptioi
of their training program.   The employees'  analytical  skills are checked with
blanks or standards that are included in each analysis.

     Lab personnel  document the receipt of each sample. Waste  samples are  ston
according to their expected content until  analysis.  Screening samples  are
analyzed as soon as possible to avoid delays in shipment  processing.
Characterization/recharacterization samples are analyzed  depending on their
storage life.  Sample identification numbers are assigned to the replicates th.
are analyzed.  The quality assurance/quality control  procedures for analysis
follow those outlined in each test method of SW-846, "Test Methods for  Evaluat
Solid Waste," or other EPA-approved methods.

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                                     Model  WAP - Incineration:   Page 18  of  20
Collector  tf.  tfu#t.t _ Sample  No.   fl- 2 ~ FT- I

Place of Collection
Date Sampled   jj^^^>jf-  <3^, /^?^? _ Time  Sampled   3-QO *,
                 I  ~      '                                      '
Field Information  JfrryuaJL*   ^LL/^j> e^aL
                                /
                      Figure  1-1.   Sample container label.

     Source:   "Test  Methods for  Evaluating  Solid Wastes"  SW-846, July 1982.

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                                     Model  WAP -  Incineration:   Page  19  of  20
                                                      Date  21*1 1 83
Sample Identification Number /? ^ - ff- I              Time  3-. QQ a-


1.  Waste Identification
                                                         j
2.  Purpose of Sampling
                                0
3.  a.  Sampling Point Location
    b.  Description
4.  a.  Number of Samples Taken             b.   Volume  per  Sample
5.  Any Field Measurements Taken
        Parameter                               Measurement




6.   Observations During  Sampling




7.   a.  Sample Destination                  b.   Means  of  Transport
                              (T

                            Signature of  Sampling  Person:
                            Figure 1-2.   Field  log.


     Source:   "Test Methods  for Evaluating  Solid  Wastes"  SW-846,  July  1982.

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                                     Model  WAP - Incineration:   Page 20 of 20


     All  test results are documented on the characterization form shown in Figure
1 and are kept on file in our facility's office.

     Analytical  equipment is inspected and  serviced  semiannually in  addition to
routine checks before each analysis.  Leftover samples  are returned  to  storage
for incineration.

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                                Model  WAP - Chemical  Treatment:  Page 1  of 20


                          MODEL WASTE ANALYSIS PLAN

                              CHEMICAL TREATMENT

                           1.  Facility Description


     The Chemical Treatment Company is requesting a RCRA permit to operate a
commercial treatment facility that chemically stabilizes hazardous wastes
received from offsite generators.  This permit would  allow us to treat
hazardous wastes consisting of solid organics, oxidizers, and metals.  We
specifically plan to treat

           segregated cadmium wastewater treatment sludge,

           pigment wastewater treatment sludge,

           emission control dust/sludge from secondary lead smelting,

           emission control dust/sludge from the primary production of steel
           in electric furnaces, and

           cumene distillation bottom tars.

All of the wastes we treat must have the characteristics of one of these
wastes.

     The treatment process entails chemically fixing  the wastes in cement.
This will produce a stable, solidified waste that is  sent offsite for
disposal.  The process is designed specfically to treat solid organics,
oxidizers, and metal-based wastes safely and effectively.  Another portion of
this Part B application contains a detailed description of our facility's
design and the results of the trial  treatment test.
IA facility such as this may have onsite hazardous waste storage.   This model
will  not address storage since it is addressed in another model.   A real  waste
analysis plan would be required to describe the facility's storage practices.

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                                Model  WAP - Chemical  Treatment:   Page 2  of  20


                 2.   Identification of Wastes to be Treated


     Table 1 contains all  the pertinent characteristics  of each  waste stream
to be treated onsite.  Any other waste types will  be restricted  from the
facility.

     Our staff sampled and analyzed each waste for its initial
characterization.  This entailed collecting four sets of samples at  3-week
intervals.  The results of the sample analyses are summarized in Table 1.
Specific data sheets are available upon request.  (Quality assurance and
quality control programs for sampling and analysis are described in  the
appendix.)  This characterization was intended to determine  that the wastes
fell  within the categories planned for treatment.   Figure 1  is  an example of
the waste characterization form completed for each waste.  Four  generators
provided their waste analysis data from past years to support our results.
The fifth facility is relatively new, so they obtained data  from a similar
facility with 14 years of operating experience to support their  waste data.

     The waste stream boundary conditions are the maximum and minimum values
of waste characteristics that the facility can treat properly.   We have
selected boundary conditions of plus or minus the following  percentages of the
1imits found in Table 1:

          segregated cadmium wastewater treatment sludge +_ 10%,

          pigment filter cake +_ 5%,

          emission control dust/sludge from secondary lead smelting  +_ 15%,

          emission control dust/sludge from the primary production of steel
          in electric furnaces _+ 10%, and

          cumene distillation bottom tars _+ 20%.

For example, pigment filter cake boundary conditions for pH  would be 5 percent
less than 7.0 (i.e., 6.65) and 5 percent more than 9.5 (i.e., 9.98). These
conditions were set  following our waste analyses and talks with  generators
about the consistency of their wastes.  The wastes are not expected  to fall
outside these limits; however, if they do, we will follow the contingency
procedures described in Section 4, "Parameters to be Monitored."

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                                        TABLE 1.  WASTE CHARACTERISTICS1
       Stream
                               Basis  for
                             Hazard  Listing
                                       Physical
                                      Properties
                     Chemical
                     Composition
                  (or %  by  volume)
1.
2.
3.
Segregated  Cadmium
Wastewater  Treat-
ment Sludge  (RCRA
No.2 F006)
Cadmium,
Hexavalent Chromium,
and Complexed
Cyanide
(Toxic [T])
Pigment Filter     K002-  Hexavalent  Chromium  and  Lead  (T)
Cake (RCRA Nos.3)  K003-  Hexavalent  Chromium  and  Lead  (T)
                   K004-  Hexavalent  Chromium  (T)
                   K005-  Hexavalent  Chromium  and  Lead  (T)
Emission Control
Dust/Sludge from
Secondary Lead
Smelting (RCRA No.3
K069)

Emission Control
Dust/Sludge from
the Primary
Production of Steel
in Electric Furnaces
(RCRA No.3 K061)
Hexavalent Chromium,
Cadmium, and Lead (T)
                             Hexavalent  Chromium,
                             Cadmium,  and  Lead  (T)
                                                                 Specific
                                                                 gravity:4
                                    Specific
                                    gravity:4
Specific
gravity:4
                                    Specific
                                    gravity:4
                 pH:   7.0  to  9.5
                 Complexed cyanide:
                   negligible
                 Cadmium:   17,000 to 22,000 ppm
                 Total  Chromium:   50,000 to
                   62,000  ppm

                 pH:   9.0  to  12.0
                 Total  Chromium:   50 to 100 ppm
                 Lead:  20 to 70  ppm
PH:4
Cadmium:  300 to 520  ppm
Lead:  45,000 to 60,000 ppm
Total Chromium:  25 to 40  ppm
                 pH:4
                 Cadmium:  600 to  700  ppm
                 Lead:  1,250 to 1,400  ppm
                 Total Chromium:   10,300 to
                   17,600
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                                                                                                                       CD
                                                                                                                       to
    Cumene Di still a-
    tation Bottom Tars
    (RCRA No.3 K022)
                        Phenol and Tars  (polycyclic
                        aromatic hydrocarbons [PAH])  (T)
                                    Flash Points;
                                    90 to 100 C
                                    Specific
                                    gravity:4
                 Phenol:  0.7 to  1.5% by weight
                 PAH:  0.8 to 1.7% by weight
iprocess code for all  streams  is  T01,  chemical treatment.
2Refer to 40 CFR 261.31.
3Refer to 40 CFR 261.32.
4fAuthor's note:  Insufficient  information available  for  these  specific wastes for this model."!
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                                Model WAP - Chemical Treatment:  Page 4  of 20
                                                     Date
1.   Generator
     a.  Name

     b.  Address


     c.  EPA ID Number
2.   Waste Identification

     a.  Facility Waste Number 	   Sample Number 	

     b.  RCRA Waste Number 	

     c.  DOT Waste Number 	

     d.  Name of Waste

     e.  General Description of Waste Generation Process


3.   Sampli ng

     a.  Date Sampled                       b.  Sampling Method

     c.  Name and Affiliation of Sampler

     d.  Was sample taken during normal  process operation?  	 Yes 	 No


4.   Physical State (21 C (70 F)) 	 Solid 	 Sludge 	 Liquid


5.   Specific Gravity


6.   Corrosive   	 Yes 	 No   pH (regardless of corrosivity) 	
7.    Ignitahle 	 Yes 	 No       Flash Point

         Test Method
                   Figure 1.   Waste characterization form.

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                                Model WAP - Chemical Treatment:  Page 5  of 20
8.   Reactive	 Yes 	 No        Test Method

         Description of Results
9.   EP Toxic Metals  	Yes 	 No

         Contaminant           Concentration           Method of Analysis
10.  Organic Components  (Indicate percent by weight or mg/L)     Test Method
11.  Inorganic Components (Indicate percent by weight or mg/L)     Test Method
     I hereby certify the accuracy of these data and the representativeness of
the waste sample.
                 Signature and Title

                                Date
             Figure 1.  Waste characterization form (continued).

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                                Model  WAP - Chemical  Treatment:   Page 6  of  20
                   3.  Chemical  Treatment Tolerance Limits
     The treatment process is limited in that it cannot stabilize as
effectively wastes that may contain 1)  soluble salts  of zinc,  copper,  or  lead;
2) sodium salts or other salts of arsenate, borate,  phosphate, iodate, or
sulfide; or 3) large quantities of sulfates because  these constituents retard
cement setting time.

     The process requires that the influent waste or  waste mixture have a pH
between 8 and 12.  If necessary, additives will  be blended in  to  achieve  this
pH.

     We do plan to accept wastes that may be incompatible with other wastes we
manage.  Since the process cannot treat incompatible  wastes together,  they are
treated in separate batches and the structure is decontaminated between
batches.

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                                Model WAP - Chemical Treatment:  Page 7  of 20


                     4.  Waste Parameters to be Monitored


      Waste analysis parameters were selected after 1) reviewing existing
 information on the waste properties, for example, 40 CFR 261 Appendix VII
 (including a search for ignitability and reactivity), 2) noting what
 properties best indicate any change in a waste, and 3)  comparing this
 information to our treatment facility's design criteria and trial  treatment
 test  results so that we can prevent any noncompliance with RCRA permit
 conditions.

      The treatment structure's materials of construction were chosen for their
 compatibility to the specific waste categories listed in Section 2; therefore,
 this  aspect of compatibility is not a factor.   Design information  about the
 treatment structure can be found in another chapter of  this Part B
 application.

      Since the permit will  be based on the type of waste the process can
 treat, we chose waste analysis parameters based primarily on waste
 characteristics and those properties that are  indicative of treatment
 performance.  These include pH, specific gravity, EP toxic metals, total  and
 amenable cyanide, flash point, reactivity, phenol, and  PAH.  For those
 nonhazardous constituents listed in Section 3  that retard the setting of
 cement, we have chosen to conduct cement setting tests  on small  samples of
 waste.  Conducting tests to measure the specific constituents would be quite
 lengthy and may not be accurate.   Waste-to-waste compatibility tests will  be
 conducted also.  Waste compatibility to treatment reagents and treatment
 structures has already been demonstrated.

     We plan to completely  recharacterize the  wastes periodically.  This will
 verify that the shipment screenings are correct and identify any waste changes
 that cannot be verified by  simple screening.

     We selected the recharacterization frequencies by  considering 

           the potential for restricted wastes to be combined in a shipment,

           the variability  of the waste composition between shipments,

           the likelihood that a  waste will  undergo changes that would
           alter its permitted characteristics, and

           the performance  history and reliability of the waste  generator.

 Section 5, "Waste Sampling  and Analysis,"  lists the analysis procedures,
 provides a rationale for each analysis parameter selected,  and identifies  the
 frequencies of waste recharacterization.

     All  incoming waste shipments will  be  screened following those steps
displayed in Figure 2.   The screening  procedures are based  on our  generators,
the wastes they plan to ship, and applicable RCRA regulations.

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                          Model WAP -  Chemical Treatment:   Page 8   of  20
  Waste Shipment Arrives
Compare Shipment
   Externally to
   Its Manifest
 Visually Inspect
    Shipment
  Sample Waste
Analyze Waste for
 Key Parameters
 Evaluate Analytical Data
  Accept Waste
   Shipment
Discrepancy
                                        Contact
                                       Generator
                           Reject
                           Waste
                          Shipment
                                      Discrepancy
                                        Contact
                                       Generator
                                       Recharacterize
                                           Waste
                                     Evaluate Analytical Data
  Figure 2.   Shipment screening procedures.

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                                Model WAP - Chemical  Treatment:  Page 9  of 20
     When a waste shipment arrives at our facility, we check its manifest for
completeness and correctness.  At a minimum, we will  look for the following
information on each manifest:
           a manifest document number;
           the generator's name, address, and EPA identification number;
           each transporter's name and EPA identification number;
           the destination of the waste shipment, i.e., hazardous waste
           management facility, address, and EPA identification number;
           an alternative hazardous waste management  facility,  address, and
           EPA identification number;
           a Department of Transportation shipping name and number;
           the quantity or volume of waste in the shipment;
           the number and type of containers in the shipment (if applicable);
           and
           a signed, dated certification of the shipment's content.

We will then visually inspect the shipment, noting 

           if the number and type of containers match the manifest;
           if the shipment labels/placards match the  manifest;
           the presence of free liquids and the consistency with the manifest;
           any irregularities with the shipment, e.g.,  leaks;
           if any restricted wastes are visibly present;  and
           if the waste appearance matches any previously noted description.
     Each waste shipment that passes initial  inspection will be sampled and
analyzed.  We sample all waste shipments as described in  Section 5, "Waste
Sampling and Analysis," but the analysis of waste shipments does not always
include measuring all  the parameters used in our initial  waste
characterization.  Rather, we select a subset of these  to measure known as
"key parameters," so we can 1) obtain the best indication of waste
treatability within given time and labor constraints, and 2) identify any
ignitable, reactive, or incompatible wastes that may  be present.  The key
parameters are selected based on 
           the need to identify any restricted wastes,

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                                Model  WAP - Chemical  Treatment:   Page 10 of  20


           waste characteristics that  affect treatment process  performance,

           the ignitability, reactivity, or incompatibility
           of the wastes, and

           those parameters that best  indicate waste  characteristic  changes.

     Figure 2 also shows the analytical  procedures followed when a  shipment
screening indicates that a waste does  not agree with  the characteristics of
our permitted wastes.  In such an event, we contact the generator and,  if
agreed, we perform a complete recharacterization (with the generator's
approval), analyzing for all the parameters previously selected  and  any
additional parameters that may be necessary.  Based on these results, we will
accept or reject the waste shipment.

     If we are ever notified by one of our generators or suspect that the
waste generating process or its means  of operation has changed,  we  will  check
to see if the waste has changed in character.   We will obtain as much
information about the change as the generator  can provide and receive the
generator's approval to take an unscheduled sample and completely characterize
it.  The characterization results will be evaluated to decide if the waste
complies with those waste characteristics that the treatment process is
permitted to nandle.  If it does not,  we will  reject  the waste.

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                                Model WAP - Chemical Treatment:  Page 11 of 20


                       5.  Waste Sampling and Analysis
Sampling
     Table 2 lists representative sampling techniques selected for each waste
we plan to manage.  Specific waste streams are listed because their means of
containment varies from one generator to another.

     The sampling procedures were developed by first identifying the wastes'
physical/chemical properties and means of containment, e.g., tanker truck.  We
selected the appropriate representative sampling techniques, sampling devices,
and sample containers following a review of "Test Methods for Evaluating Solid
Waste"  (SW-846).  Since the equipment selected is listed for handling
materials of the same physical forms as our wastes, we believe that the
equipment is suitable.

     We reviewed the scientific literature and work history volunteered by the
generators to identify any needs for special  waste handling during sampling.
Such information helps protect our personnel  and keeps our samples
representative.

     We will use simple random sampling for wastes arriving in 55-gallon
drums.  These wastes are homogeneous and can be grab sampled at mid-level in
the drum through the bung opening.  Simple random sampling entails using a
random numbers table to select drums to sample [see Appendix C of this
manual].  The number of drums sampled is based on the American Society for
Testing and Materials (ASTM) cube root equation for barrels [see Appendix D of
this manual].

     Tanker trucks will  be sampled through access ports in the tanks.  Since
our access is limited to ports, which may limit the representativeness of the
sample, we will take samples at three discrete vertical depths to provide the
best representation of waste possible.

     We sample closed-bed trucks through access ports in the trailer.  A
vertical sample that covers the depth of the bed is taken.  Thus, our access
is limited and the representativeness of the waste sample may also be limited.

     The sampling approaches described above pertain to characterization and
recharacterization sampling as well  as unscheduled sampling of the wastes.

     Quality assurance and quality control procedures for sampling wastes are
described in the appendix.


Analysis

     Table 3 identifies the parameters and their analytical methods chosen to
characterize wastes periodically as well as a subset of key parameters chosen
to screen the v/astes in each shipment.  Table 3 also provides our rationale

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                                         TABLE 2.  WASTE SAMPLING INFORMATION
Stream
Numbers
Contai nment
Device
Sampli ng
Technique
Number of Samples
Taken Comments
References
i. , J. ,
and 4.
(single
layered
sludges)
Tanker truck
          Access limited
          to tank ports.
          Grab sample
          with weighted
          bottle.
                   Grab samples at
                   top, middle, and
                   bottom of tank.
                    1.

                    2.
2.
Closed
truck
bed
Access limited
to ports.  Grab
sample with
trier.
One vertical core
sample through
bung across
depth of drum.
1.

2.


3.


4.
    Do not  composite
    sample.
    Wear goggles,
    rubber  gloves,
    protective
    clothing, respira-
    tor, and face
    shield.
    Store sample away
    from acids and
    standing water.
    TOXIC WASTE.
Do not composite
samples.
Wear rubber gloves,
apron, mask, and
breathing appartus.
Place sample in
linear polyethylene
container.
TOXIC WASTE.
                     Technique: SW-846,*
                       Section 1.4.1
                     Device: SW-846,
                       Section 1.2.1.5
Technique:  SW-846,
  Section 1.4.1
Device:  SW-846,
  Section 1.2.1.5
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                                               TABLE 2.  (continued)
Stream
Numbers
b.
Contai nment
Device
55-gallon
drums
Sampl i ng
Technique
Simple random
sampl ing.
Grab sample
with trier.
Number of Samples
Taken

 > 3 /No. of drums
\ / in shipment2
Comments
1. Store i n a cool ,
well -ventilated
area.
2. Wear goggles,
References
Technique: SW-846,
Section 1.1.3.1
Device: SW-846,
Section 1.2.1.5
    breathi ng mask,
    gloves, apron, and
    boots.
3.  Place sample in
    linear polyethylene
    container.
4.  Use Teflon cap.
5.  Get sample through bung
    across depth of drum.
6.  TOXIC WASTE.
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iSW-846 "Test Methods for Evaluating Solid Waste" July 1982.
^Source of cube root equation:  American Society for Testing and Materials, Method D  140-70.
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TABLE 3.  WASTE ANALYSIS INFORMATION
Stream
Number^
1., 2., 3.,
4.
1.
4! 	
1., 2., 3.,
4.
1., 2., 3.,
4.

1., 2., 3.,
4.
1., 2., 3.,
4.
4!'
4!'

Parameters2
*Reactivity
*Total and amenable
cyanide
* ii
pH
*Specific gravity
Arsenic

Barium
Cadmium
Total chromium
Lead

Analytical
Methods3
U.S. Gap Test or U.S.
Internal Ignition Test 4
SW-846, Method 9010
(Titration)
SW-846, Method 9040
(pH Meter)
ASTM D1429, Method C
(Erlenmeyer Flask)
SW-846, Method
7061 (AA)

SW-846, Methods
3050/7080 (AA)
SW-846, Methods
3050/7130(AA)
SW-846, Methods
3050/7190(AA)
SW-846, Methods
3050/7420(AA)

Rationale for Detection
Parameters Limit
(pg/L)
Identify reactive wastes
for safe handling.
Verify no cyanide
reactivity.
Assure within pH
treatability range.
Waste verification.
Identify unexpected 2
metals.

Identify unexpected 400
metals.
Measure treatment 5
performance.
Measure treatment 50
performance.
Measure treatment 100
performance.




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CL
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                                                 TABLE  3.   (continued)
Stream
Number^
i  j   y O  j
4.
l,  , j,
4.
1 ? ^
L  y ^-'9 ^ * J
4.
5.
5.
Parameters
Mercury
Selenium
Silver
*Flash point
Phenol
Analytical
Methods
SW-846, Method 7471
(cold vapor technique)
SW-846, Method 7741 (AA)
SW-846, Methods 3050/
7760 (AA)
SW-846, Method 1010
SW-846, Method 8040
Rationale for
Parameters
Identify unexpected
metals.
Identify unexpected
metals.
Identify unexpected
metal s.
Verify waste.
Verify waste and measure
Detection
Limit
(M9/L)
0.2
2
10
-
1.4
5.
1    9   ~\
!  ) *-  > **  1
4., 5.
1    ?   3
i, <-) ->
4., 5.
               PAH
               Cement  setting
               retardants
Waste compatibility
                       (Gas Chromatograph)

                       SW-846, Method 8100
                       (Gas Chromatograph)

                       Needle penetration
                       test (COE)
                                      Mix wastes  proportional  to
                                      treatment mixture^
treatment performance.

Verify waste and measure
treatment performance.

Identify the presence of
constituents that retard
setting.

Identify incompatible wastes.
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^Recharacterization Frequency:   Stream  1.- semiannual;  2.-  annual;  3.- quarterly; 4.- annual.
^Asterisk denotes key parameters measured with  each  shipment.
3SW-846 "Test Methods for  Evaluating  Solid Waste"  July  1982.
 ASTM American Society  for  Testing  and  Materials.
 COE Corps of Engineers
^[Author's note:  These explosivity test methods are  currently  under development by the Bureau of Mines for EPA.]
5[Author's note:  An actual waste analysis plan would provide  a description of the test method.]
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                                Model WAP - Chemical Treatment:  Page 16 of 20


for selecting each parameter.  All analyses will  be performed in-house.
Quality assurance and quality control procedures  for waste analysis are
described in the appendix.

     The frequencies of recharacterization selected are also found in Table 3.
They were based on a ranking exercise that considers the issues addressed in
Section 4.  [See Appendix E of this manual for an explanation of this
ranking exercise.]  The details of the ranking exercise are not included since
they take the waste generators' performance history into consideration.
However, the details are available upon request.

     Should recharacterization analysis prove that the waste is not manageable
by our treatment process within the specified permit conditions, we will
reject it.

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                                Model  WAP - Chemical  Treatment:   Page 17 of  20


                                  APPENDIX

                  Quality Assurance/Quality Control  Program
Program Goal
     Our program's goal  is to assure that  we acquire accurate  and  precise
information in order to  assure that the wastes  we treat  exhibit  those
chemical/physical  characteristics for which our process  is  permitted.  We
accomplish this by making sure that --

          the wastes are the permitted organic  solids, oxidizers,  or
          metal-based wastes;

          waste incompatibilities are identified so that they  are  treated
          in separate batches; and

          no restricted  wastes are accepted.

We generate a great deal of data at our facility.  Thus, we carry  out our
quality assurance/quality control program  to the fullest to assure that
accurate and precise data are obtained.


Sampling Program

     Two of our employees have been trained to  sample waste shipments.   This
Part B application contains a chapter on their  training  program.   The
employees' sampling skills are observed quarterly by our operations manager.
Sampling equipment is inspected for decontamination and  operability before
each shipment is sampled, and each inspection is documented, noting any
problems and corrective  actions taken.

     Since we plan to handle more than one waste and one generator at the
facility, all sample containers will be labeled (see Figure A-l),  and vital
sampling information will be logged in the field (see Figure A-2)  before a
designated driver carries the samples (with an  accompanying list of those
samples) to the laboratory.


Analysis Program

     Our laboratory personnel have been trained to perform the analytical
methods outlined in Table 3.  This Part B application contains a description
of their training program.  The employees' analytical skills are checked with
blanks or standards that are included in each set of analyses.

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                                Model  WAP - Chemical  Treatment:   Page  18 of  20
Collector     C&ATjj,j	Sample No.
Place of Collection  JfoyU&jJ  
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                                Model  WAP - Chemical  Treatment:   Page 19 of 20
Sample Identification Number
1.   Waste Identification
    a.  Waste Type
    b.  Facility Waste Number 3
    c.  Suspected Composition
2.   a.   Waste
        Address
                        , USA
3.   Purpose of Sampling
                  
    a.   Sampling Point Location
    b.   Description
5.  a.  Number of Samples Taken
                                                      Date
                                                      Time  // . p & g . m 
                                                         , JUa^L,
                                                Generation  Process
                                            b.   Volume per Sample
6.  Any Field Measurements Taken 77 tf-'

        Parameter
                                                Measurement
7.  Observations During Sampling
8.  a.  Sample Destination
                                                               l
                                            b.   Means of Transport
                                 C

                            Signature of Sampling Person:
                           Figure A-2.  Field log.

         Source:  "Test Methods for Evaluating Solid Wastes," SW-846.

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                                Model  WAP - Chemical  Treatment:  Page 20 of 20


     Lab personnel  document the receipt of each sample.  Waste samples are
stored until  analysis according to their expected content.  Screening samples
are analyzed  as soon as possible (less than 24 hours) to avoid delays in
shipment processing.  Characterization/recharacterization samples are analyzed
depending on  their storage life. Sample identification numbers are assigned to
the replicates analyzed.  The quality assurance/quality control procedures for
analysis follow those outlined in each test method of SW-846, "Test Methods
for Evaluating Solid Waste," or other EPA-approved methods.

     All test results are documented on the characterization form shown in
Figure 1 and  kept on file in the facility office.

     Analytical equipment is inspected and serviced semiannually in addition
to routine checks before each analysis.  Leftover waste samples will  be
returned to the appropriate storage container for later treatment.

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                                          Model  WAP - Landfill:   Page 1  of 21


                          MODEL WASTE ANALYSIS PLAN

                                   LANDFILL

                           1.   Facility Description


     The Land Disposal  Company owns and operates a commercial  hazardous waste
landfill facility, receiving wastes that are generated offsite.   The facility
is operating under a RCRA interim status permit.  Today,  we are  requesting  a
permit to operate under current RCRA landfill  standards (40 CFR  264 Subpart
N).

     The landfill receives organic and inorganic solid and  sludge wastes (no
liquid wastes);  however, some of these wastes  are restricted from disposal
(see Section 2). No wastes containing free liquids and no wastes containing
greater than 70  percent water are accepted.   The acceptable wastes require  no
treatment before disposal and are not stored onsite for greater  than 90 days.

     The landfill trenches are designed to contain these  wastes  safely, so  no
exposure to the  surrounding environment occurs.   (Another portion of this Part
B permit application contains a detailed description of our facility's
design.)  The trenches  contain synthetic liners  and leachate collection
systems whose materials were selected for their  compatibility with the  waste
types we handle.  The natural  clay formation underlying our site also has a
very low permeability to the wastes we receive (see the Facility Design and
Hydrogeology chapters).

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                                          Model  WAP - Landfill:   Page 2  of 21


                2.  Identification of Wastes to be Landfilled
     Table 1 lists the pertinent characteristics of each hazardous waste for
which we are requesting a RCRA permit, i.e., the wastes we currently manage at
the landfill  facility.  The analytical data on off-spec lead acetate were
provided by the generator.  Our staff sampled and analyzed the two pigment
filter cake waste streams five times (once every 2 weeks), resulting in the
analytical data found in Table 1.   The initial characterization data in Table
1 for the dust/sludge from secondary lead smelting were provided by the waste
generator.  The Land Disposal  Company has confidence in these data because of
the generator's work history and the knowledge that their process goal  is to
recover as much of the metals  as possible.  Our staff sampled and analyzed the
bottom tar waste three times during a 6-week period to obtain the initial
characterization data given in Table 1.   A detailed display of all the  data
collected is  presented in Appendix III.   [This model does not include Appendix
III due to the lack of representative data.  However, an actual  plan could
include such  data.]  Quality assurance and quality control programs for
sampling and  analysis are described in the appendix.

     The Land Disposal Company conducted the initial characterization of each
waste to ensure that no restricted wastes were present and to verify the waste
composition.   Compatibility among  wastes was also considered.

     Figure 1 is an example of the waste characterization form we complete for
each waste.  All of the wastes currently managed are mutually compatible.
Therefore, we see no need to test  routinely for compatibility.

     Waste stream boundary conditions of _+ 10 percent of the waste
characteristic limits shown in Table 1 have been designated.  These boundary
conditions have been set to identify anomalies in waste characteristics.  This
helps alert us to any unusual  properties that may require our attention. We
selected 10 percent after reviewing our  waste analyses and analytical data
from each generator.  The contingency procedures discussed in Section 4,
"Waste Parameters to be Monitored," will be followed if boundary conditions
are exceeded.

     The Land Disposal Company restricts the following wastes from the  site:

               free liquids           ignitable wastes
               gaseous wastes          reactive wastes
               oxidizers              corrosive wastes
               cyanides               radioactive wastes
               sulfides               polychlorinated biphenyls

The landfill  trenches are not  designed to retain these wastes chemically or
physically.  We do have the capability of accepting certain incompatible
wastes.   We would safely dispose of these incompatible wastes by isolating
them in clay  cells within the  trenches.

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                                     TABLE  1.   WASTE  CHARACTERISTICS
       Stream-'-*^
 Basis for Hazard
  Classification
    Physical
     State
  Chemical Composition
A-l   Off-spec  lead  acetate
      (RCRA  No.  U144)3

A-2   Pigment filter  cake
      (RCRA  No.  K003)4
B-l   Pigment filter cake
      (RCRA No. K004)4
C-l   Dust/sludge from
      secondary lead
      smelting
      (RCRA No. K069)4
D-l   Bottom tars from
      phenol production
      (RCRA No. K022)4
Lead acetate (Toxic)
Lead, hexavalent
chromium (Toxic)
Hexavalent chromium
(Toxic)
Hexavalent chromium,
lead, cadmium (Toxic)
Phenol,  Tars
(polycyclic aromatic
hydrocarbons [PAH])
Solid, single layer
Density = 3.25 g/ml

Sludge, single layer
Sludge, single layer
Sludge, single layer
Tarry solid, single
layer
Lead acetate:  up to 95%
  by weight

Lead:  50 to 200 ppm
Total chromium:  20 to 80 ppm
Water:  40 to 70% by weight
pH:  8.5 to 11.0

Total chromium:  50 to
  100 ppm
Water:  50 to 70% by weight
pH:  9.5 to 11.0

Cadmium:  200 to 300 ppm
Lead:  35,000 to 50,000 ppm
pH:  5.0 to 7.0
Water:  30% by weight
Total chromium:  10 to 30 ppm

Phenol:   0.7 to 1.5% by
  weight
PAH:  0.8 to 1.7% by weight
Flash point:  90 to 100 C
Water:  0.5 to 2.0% by
  weight
Stream numbers indicate generator (A, B, C, and D) as well as separate streams from each
waste generator.
^Process code for all btreams is D80, Landfill.
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                                          Model WAP - Landfill:  Page 4  of 21
                                                          Date
1.   Generator
     a.  Name

     b.  Address


     c.  EPA ID Number
2.   Waste Identification

     a.  Facility Waste Number 	   Sample Number	

     b.  RCRA Waste Number 	

     c.  DOT Waste Number 	

     d.  Name of Waste

     e.  General Description of Waste Generation Process


3.   Sampli ng

     a.  Date Sampled                       b.  Sampling Method

     c.  Name and Affiliation of Sampler

     d.  Was sample taken during normal process operation?  	 Yes 	 No


4.   Physical State at 21 C (70 F) 	 Solid 	 Sludge 	 Liquid


5.   Water Content (percent) Test Method



6.   Corrosive   	 Yes 	 No   pH (regardless of corrosivity) 	
7.    Ignitable  	 Yes 	 No       Flash Point

         Test Method
                   Figure 1.  Waste characterization form.

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                                          Model  WAP - Landfill:  Page 5  of 21
3.   Reactive
                     Yes
   No
                                         Test Method
         Description of Results
9.   EP Toxic Metals
         Contaminant
Yes
                                      No
   Concentration
                                                       Method of Analysis
10.  Other Restricted Wastes  Test Methods
11,
Free Liquids
Gaseous Wastes
Oxidizers
Cyanides
Sulfides
Radioactives
Polychlorinated
biphenyls
Organic Components
Yes No
Yes No
Yes No
Yes No
Yes No
	 Yes 	 No
Yes No
(Indicate percent by weight
and polycyclic aromatic hydrobarbons (PAH) for <
or mg/L including phenol
Drganic waste streams
     Test Methods
     I certify the accuracy of these data and the representativeness of the
waste sanple.
                   Signature and Title _
                   Date
             Figure 1.  Waste characterization form (continued).

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                                          Model  WAP - Landfill:   Page 6   of  21


                        3.   Landfill  Tolerance Limits


     Sludges to he landfilled must not contain more than 70 percent  water.
[Note:  This is an arbitrary value selected for this model.]  The remainder  of
the sludge must be solids to assure minimal leachate generation.   Also,  the
wastes must not contain any free liquids.

     Tolerance limits are established to assure optimum landfill  performance.
They reflect those waste properties beyond which the landfill  cannot safely
contain each waste.  In this case, water content and the presence of free
liquids are the central factors in establishing tolerance limits.

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                                          Model  WAP  -  Landfill:   Page  7   of  21


                     4.   Waste Parameters  to  be  Monitored
     The wastes managed at the facility must  have  characteristics  that  fall
within the chemical  or physical  retention capabilities  of  the  landfill, i.e.,
those characteristics to be specified in the  RCRA  permit.   To  select  our
analytical parameters, we 1)  reviewed existing  information on  the  waste
properties including the EPA  background information  document  (BID's)  on each
waste (including a search for ignitability, reactivity,  and incompatibility),
2) noted what properties best indicate any change  in a  waste,  and  3)  compared
this information to  our landfill  facility's design criteria.

     Except for the  off-spec  lead acetate, waste streams are tested for a
variety of parameters depending  on their potential effects on  the  landfill  and
basis for hazard designation.  These include  free  liquids, pH,  cyanide,
sulfide, oxidizing agents, reactivity, radioactivity,  PCBs, and flash point,
which are measured to detect  restricted wastes.  Analysis  for  water content,
EP toxic metals, phenol, PAH, and a GC/MS scan  for volatile and semivolatile
organic constituents are conducted to verify  waste characteristics and
identify any potential liner-damaging organics  that  are  present.

     We decided how  often to  recharacterize the waste  with these tests  by
considering 

           the potential for  restricted wastes  being combined  in a shipment,

           the landfill's limitations,

           the variability of a  waste's composition  from one  shipment to
           another,

           the likelihood of  a waste undergoing changes  that  adversely  affect
           its manageability, and

           the prior history  of  the waste generator  performance and
           reli ability.

     Section 5, "Waste Sampling  and Analysis,"  contains  a  description of
these analysis procedures and identifies the  frequencies of waste
recharacterization for each stream.

     We screen all incoming shipments to assure that the wastes we receive
meet the permitted boundary conditions.  The  procedures  followed during a
shipment screening are presented in Figure 2.

     We check each waste shipment manifest for  completeness and correctness,
looking for the following information on each manifest:

-------
                        Model  WAP  - Landfill:   Page  8  of 21
  Waste Shipment Arrives
Compare Shipment
   Externally to
   Its Manifest
 Visually Inspect
    Shipment
  Sample Waste
Analyze Waste for
  Key Parameters
 Evaluate Analytical Data
  Accept Waste
    Shipment
Discrepancy
                                        Contact
                                       Generator
                                       Discrepancy
                                          JL
                                         Contact
                                        Generator
                           Reject
                           Waste
                          Shipment
                                        Recharacterize
                                           Waste
                                      Evaluate Analytical Data
   Figure  2.   Waste shipment screening procedures,

-------
                                         Model WAP - Landfill:   Page 9  of 21

           a manifest  document  number;

           the  generator's  name,  address, and  EPA identification  number;

           each transporter's name  and  EPA  identification number;

           the  destination  of the waste shipment, i.e., hazardous waste
           management  facility, address, and EPA identification number;

           an alternative hazardous waste management facility, address, and
           EPA  identification number;

           a Department  of  Transportation shipping name and  number;

           the  quantity/volume  of waste in  the shipment;

           the  number  and type  of containers in the shipment  (if  applicable);
           and

           a signed, dated  certification of the shipment's content.


     We then visually  inspect the shipment, noting


           if the number and type of  containers match the manifest;

           if the shipment  labels/placards  match the manifest;

           if the waste's appearance  matches any previously  noted
           descriptions;

           any  irregularities with  the  shipment, e.g., leaks;

           if any restricted wastes are visibly present; and

           if each container is 90  percent  full.


If any complications arise  as a result  of this inspection, we  contact the
generator to resolve the problem.

     We sample  and analyze  each waste shipment (excluding off-spec  commercial
products*) that passes our  initial  inspection. The sampling  procedures for
each shipment depend on its means of  containment, e.g., drums, when it arrives
at our facility.  Our  analysis  of waste shipments does not always include
    do not sample and analyze off-spec products  as  part  of  our  screening
procedures.  The wastes are only off-spec  and have  never been contaminated  by
generator use.   We rely on visual  examination of off-spec products  to  identify
them.

-------
                                          Model WAP - Landfill:  Page 10 of 21


testing for all the parameters included in the initial  waste characterization.
Rather, we select a subset of these, designated "key parameters,"  so we can
obtain the best indication of waste manageability within the given time and
labor constraints.  We consider four criteria when selecting key parameters.
These are--

           the need to identify restricted wastes;

           waste characteristics that might affect the landfill's  performance;

           the ignitability, reactivity, and/or incompatibility of the wastes;
           and

           those parameters that best indicate any changes in important waste
           characteristics.

A more detailed description of these procedures is found in Section 5, "Waste
Sampling and Analysis."

     If a shipment screening indicates that a waste has characteristics that
are inconsistent with our acceptance criteria, we contact the generator and,
if requested,  perform a complete recharacterization, analyzing for all  of the
parameters previously selected and any additional  parameters that  may be
necessary.  Based on these results, we accept or reject the waste  shipment.

     If we are ever notified by one of the generators  or suspect that the
waste generating process  or its means of operation has  changed, we check to
see if the waste has changed in character.  We obtain  as much information
about the change as the generator can provide, and with the generator's
approval, take an unscheduled sample and completely characterize it.   We then
evaluate the characterization results and decide if the landfill facility can
continue to manage the waste safely within permit  conditions.  If  not,  we will
reject it.

-------
                                          Model  WAP - Landfill:   Page 11 of 21


                       5.  Waste Sampling and Analysis
Sampli ng
     Sampling procedures were developed by first  identifying  the wastes'
physical/chemical properties and means of containment.   We selected  the
appropriate representative sampling techniques  and  sampling devices  from  "Test
Methods for Evaluating Solid Wastes" (SW-846).   Since the equipment  selected
is listed to handle material of the same physical  form as our waste,  we assume
the equipment is suitable.  Scientific literature and work histories
volunteered by the generators were reviewed to  identify any needs for special
waste handling procedures to protect our personnel  and  keep the  samples
representative.   Quality assurance/quality control  procedures are addressed in
the appendix.

     Table 2 summarizes the representative sampling procedures selected for
each waste stream.  Specific waste streams are  listed because their means  of
containment varies from one generator to another.

     We use simple random sampling for wastes arriving  in 55-gallon drums.
The drummed wastes listed in Table 2 are homogeneous  and  can  be  grab  sampled
at mid-level  in  the drum.  Simple random sampling  entails using  the  random
numbers table to select drums to sample.  [See  Appendix C of  this manual.]
The number of drums sampled is based on the American  Society  for Testing  and
Materials (ASTM) cube root equation for barrels.   [See  Appendix  D of  this
manual.]

     We sample closed-bed trucks through the access ports in  the trailers.  We
take a vertical  sample that covers the depth of the bed.   Since  access  is
limited, the representativeness of the waste sample is  also limited.

     We use random sampling for open-bed trucks where the sample areas  are
based on a three-dimensional grid.  The volume  of  the load is divided into
levels of imaginary cells based on the load length, width, and depth, and  cell
numbers are assigned in sequence.  We then use  the  random numbers table to
select the numbered cell  to sample.  [See Appendix  C  of this  manual.]  We  next
take one sample  from the randomly chosen cell.  Only  one  sample  per truck  is
taken since the  purpose of the sample is to verify  that the waste is
consistent with  the manifest and does not contain  more  than 70 percent  water.

     Table 2 also lists "leachate" as a waste stream.  Should any leachate be
generated and collected in our trench sump, we  obtain a grab  sample  near  the
bottom of the leachate1s depth.  Since we are limited to  vertical  sampling in
the sump manhole, representative techniques are difficult to  use.

     We will  take any unscheduled samples as described  above, or we will
develop any special  procedures that are necessary  to  obtain representative
samples on the generator's site.

-------
                               TABLE 2.   REPRESENTATIVE SAMPLING TECHNIQUES
   Stream
             Containment Device
                            Sampling Technique
                                              Comments
A-l
Off-spec
lead
acetate*
55-gal Ion drum
Simple random grab sample
with thief (SW-846,
Section 1.2.1.4).  Sample
cube root of total number
of containers per shipment
1. Wear rubber gloves, safety
   goggles, and a self-
   contained respirator.
2. Clean hands carefully.
3. Toxic.
4. Use glass container with
   teflon cap.
A-2
R-l
Pigment
filter
cake
Pigment
filter
cake
Closed-bed truck
Open-bed truck
Vertical core sample through
two ports with trier
(SW-846, Section 1.2.1.5).
Simple random grab sample with
trier (SW-846, Section 1.2.1.5)
One sample per depth level.
1. Wear rubber gloves, apron,
   shoes, mask, and breathing
   apparatus.
2. Use linear polyethylene
   sample container.
3. Toxic.
o
a.
                                                                                                               -o
                                                                                                               I
                                                                                                               CL
                                                                                                               -h
                                                                                                               cu
                                                                                                               ro
                                                                                                               o
                                                                                                               ro

-------
                                              TABLE 2.   (continued)
     Stream
                Containment Device
                         Sampling Technique
                                            Comments
C-l  Dust/sludge      Open-bed truck
     secondary lead
     smelting
                                      Simple random grab sample
                                      with trier (SW-846,
                                      Section 1.2.1.5).  One
                                      sample per depth level.
                                                                             3.
                                                          Wear rubber gloves, apron,
                                                          shoes,  mask, and breathing
                                                          apparatus.
                                                          Use linear  polyethylene
                                                          sample  container.
                                                          Toxic.
D-l
L-l
Bottom tars
from phenol
production
55-gallon drum
Leachate,
homogeneous
1iquid
Sump
Simple random grab
sample with Coliwasa
(SW-846, Section 1.2.1.1).
Sample cube root of total
number of containers
per shipment.
Simple random grab sample with
Coliwasa (SW-846, Section
1.2.1.1).  Sampling dependent
on volume of leachate
collected in sump.
                                                                             3.
                                                                             4.
1
   Wear goggles, mask, rubber
   gloves, apron, and boots.
   Place sample in glass
   container with teflon cap.
   Get one mid-level  sample.
   Toxic.
   Do not collect during
   rainfall.
2.  Put in linear polyethylene
   contai ner.
3.  Potentially toxic.
                                                                                                                  o
                                                                                                                  CL
                                                                                                                  rt>
                                                                                                                  -a
                                                                                                                  cu
                                                                                                                  CL
                                                                                                                  -h
                                                                                                                  -a
                                                                                                                  to
                                                                                                                  ca
                                                                                                                  n>
                                                                                                                  CO

                                                                                                                  o
^Typically, off-spec materials are not analyzed.
2Source of cube root equation:  ASTM D140-70.
                                                                                                                  IX)

-------
                                          Model HAP - Landfill:  Page 14 of 21
Analysis
     Table 3 identifies the analytical methods chosen for periodic waste
characterizations and waste shipment screening.  The table also provides a
rationale for selecting each parameter and the frequency at which each stream
is recharacterized.  The recharacterization frequencies selected are based on
a ranking exercise that considers the criteria discussed in Section 4.  [See
Appendix E of this manual for an explanation of this ranking exercise.] The
details of the ranking exercise are not included since they take the waste
generator's history of performance into consideration.  The details are
available upon request.  Should recharacterization analyses prove that the
waste is not safely manageable onsite, we will reject it.

     All analyses are performed in-house.  QA/QC procedures for sample
analysis are discussed in the appendix.

-------
                                      TABLE 3.  WASTE ANALYSIS  INFORMATION
      Stream^
 Parameter^
  Test Method3
Detection
  Limit
  (U9/L)
   Rationale for
Parameter Selection
A-2, B-l, C-l, L-l    *pH
A-2, B-l, C-l, D-l    *Free liquids
                      SW-846,  pH  Method
                      9040  (Electrode)

                      SW-846,  Method  9095
                      (Paint  Filter  Test)4
                                     Identify  restricted  corrosive
                                     wastes.   Waste  verification.
                                                                                 Identify  restricted  free
                                                                                 liquids.
A-2, B-l, C-l, D-l,    Water content
L-l
                      ASTM  D95  (Distillation)
                      or  D176  (Centrifuge)
                                    No more  than  30%  water  is
                                    allowed  in waste  to  maintain
                                    integrity of  landfill
                                    structure and minimize
                                    leachate generation.
                                                                                                                    o
                                                                                                                    fa-
                                                                                                                    ro
D-l
"flash  point
SW-846, Method 1010
(Pensky-Martens Closed
Cup)
             Identify restricted ignitable
             wastes.
                                                                                                                    cu
                                                                                                                    3
                                                                                                                    a.
                                                                                                                    -h
A-2, B-l, C-l, D-l     Reactivity
                      U.S.  Gap  Test  or  U.S.
                      Internal  Ignition  Test^
                                    Identify  restricted  reactive
                                    wastes.
                                                                                                                    -o
                                                                                                                    (U
                                                                                                                    (O
                                                                                                                    n>
                                                                                                                    en
                                                                                                                    o
                                                                                                                    ro

-------
                                        TABLE  3.   (continued)
Stream Parameter
A-2, B-l, C-l, D-l EP toxic metals
L-l Arsenic

Barium

Cadmium

Total Chromium

Lead

Mercury

Selenium

Silver

Detection Rationale for
Test Method Limit Parameter Selection
(P9/L)

SW-846, Methods 3050/
7060 (AA, Furnace)
SW-846, Methods 3050/
7081 (AA, Furnace)
SW-846, Methods 3050/
7131 (AA, Furnace)
SW-846, Methods 3050/
7191 (AA, Furnace)
SW-846, Methods 3050/
7421 (AA, Furnace)
SW-846, Method
7471 (AA, Furnace)
SW-846, Methods 3050/
7740 (AA, Furnace)
SW-846, Methods 3050/
7761 (AA, Furnace)
Waste verification.
1

2

0.1

1

1

0.2

2

0.2

A-2, B-l, C-l, D-l    *0xidizing agents
                      Iodide, Starch Paper
                      Test6
                                     Identify  restricted
                                     oxidizing wastes.
                                                                                                                o
                                                                                                                Q-
                                                                                                                n>
                                                                                                                 01
                                                                                                                 3
                                                                                                                 Q.
A-2, B-l, C-l
*Cyanide
SW-846, Method 9010
(Titration)
Identify restricted
cyanide wastes in
aqueous-based media,
id
n>
                                                                                                                 o
                                                                                                                 -h
                                                                                                                 ro

-------
                                      TABLE 3.   (continued)
      Stream
 Parameter
  Test Method
Detection
  Limit
  (wg/L)
      Rationale for
   Parameter Selection
A-2, B-l, C-l,
D-l, L-l
D-l, L-l
'Sulflde
A-2, B-l, C-l, D-l     Radioactivity
 Phenol
 PAH
SW-846, Method 9010
(Titration)
                      Radiation Detector
SW-846, Method 8040
(GC/FID)
SW-846, Method 8100
(GC/FID)
   1,000       Identify  restricted
               sulfide wastes  in
               aqueous-based media.

               Identify  restricted
               radioactive wastes.

               Verification of waste.
               Verification of waste.
                                                                                                                 o
                                                                                                                 o.
D-l
A-2, B-l, C-l,
D-l, L-l
*PCB
 Volatile and
 semivolatile
 organic
 constituents.
SW-846, Method 8080
(GC/ECD)
SW-846, Methods 8240
and 8250, respectively
(GC/MS)
   0.065
   (for one
   isomer)

  Based
   on
 constituent
Identify restricted PCBs
in an organic media.
Identify any hazardous
organic constituents
that are present.
                                                                                                                 Cu
                                                                                                                 3
                                                                                                                 O.
                                                                                                                 -h
                                                                                                                 O)
^Recharacterization Frequency:  A-l-none; B-1-quarterly;  A-2  and  D-l-semiannual;  C-1-annual.
^Asterisk denotes key parameter measured with each  shipment.
3SW-846 "Test Methods for  Evaluating Solid Waste" July  1982.
  ASTM - American Society  for Testing and Materials.
^[Author's note:  This test method will be included  in  the  next edition  of  SW-846.]
^[Author's note:  These explosivity tests are currently under development by  the  Bureau of Mines for EPA.]
                                                                                           ~j
                                                                                           o

                                                                                           ro

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                                          Model  UAP - Landfill:   Page  18 of  21
                                   APPENDIX

                  QUALITY ASSURANCE/QUALITY CONTROL PROGRAM
Goal of Program
     Our program's goal  is to collect representative waste information  in
order to assure that the wastes we handle can be safely retained  by  our
landfill.  We accomplish this by making sure that --

          no restricted  wastes are accepted,

          significant waste characteristics are verified,  and

          waste incompatibilities are identified so those  wastes
          are disposed in isolated cells.

We generate a great deal of data at our facility, and we carry  out our  quality
assurance/quality control program to the fullest to assure that accurate and
precise data are obtained.


Sampling Program

     Two of our personnel have been trained to sample waste shipments.  This
Part 6 application contains a chapter on our training program.  The  employees'
sampling skills are observed quarterly by our operations manager.  Sampling
equipment is inspected for decontamination and operability before each
shipment is sampled.  Each inspection is documented, noting any problems and
corrective actions taken.

     Since many wastes and generators are dealt with at our facility, we label
all sample containers (see Figure A-l) and maintain a field log of vital
sampling information (see Figure A-2) before a designated  driver  carries the
samples (with an accompanying list of those samples) to the laboratory.


Analysis Program

     Our lab personnel have been trained to perform the analytical methods
outlined in Table 3.  (See the Part B Training Program section.)  Their
analytical  skills are checked with blanks or standards that are included with
each analysis.

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                                          Model  WAP  -  Landfill:   Page  19 of 21
Collector
Place of Collection  v
                                              Sample  No.
Date Sampled  /.
             ~7/
Field Information
                              / 3
                                             Time Sampled  JO'/<3.
                     Figure  A-l.   Sample container label.

    Source:   "Test  Methods for  Evaluating  Solid Wastes"  SW-846, July  1982.

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                                          Model  WAP - Landfill:  Page 20 of 21
                                   FIELD LOG

                               A                      Date
Sample Identification Number    -2 " /                 Time

1.  Waste Identification
    a.  Waste Type P/jo_W-t 
-------
                                          Model  WAP - Landfill:   Page 21 of 21


     Lab personnel  document receipt of each sample.  Waste samples are stored
until analysis based on their expected content.   Screening samples are analyzed
as soon as possible to avoid delays in shipment  processing.   Characterization/
recharacterization samples are analyzed depending on their storage life.
Sample identification numbers are assigned to replicates  analyzed.  The quality
assurance/quality control  procedures for analysis follow  those outlined in each
test method of SW-846, "Test Methods for Evaluating Solid Waste,"  and other
EPA-approved methods.  All test results are documented on the characterization
form shown in Figure 1 and are kept on file.

     Analytical  equipment  is inspected and serviced semiannually in addition to
routine checks before each analysis.  Leftover samples are returned to their
original containers.

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                                  APPENDIX B
                                  REFERENCES
1.   Identification and Listing of Hazardous Waste Under RCRA,  Subtitle C,
Section 3001.  Listing of Hazardous Waste (40 CFR 261.31 and 261.32).  NTIS
PB81-190035, U.S. Environmental Protection Agency, Washington,  D.C.  1980.  853
pp.

2.   Test Methods for Evaluating Solid Waste.  Physical/Chemical  Methods.
SW-846, 2nd Edition, U.S. Environmental Protection Agency, Washington, D.C.
1982.

3.   Standard Methods for the Examination of Water and Wastewater, 15th
edition.  American Public Health Association, Washington, D.C.   1980.

4.   A Method for Determining the Compatibility of Hazardous Wastes,
EPA-600/2-80-076, U.S. Environmental Protection Agency, Cincinnati, Ohio,
1980.  149 pp.  Available from Superintendent of Documents, U.S.  Government
Printing Office, Washington, D.C.
5.   Toxic and Hazardous Industrial  Chemicals Safety Manual for Handling and
Disposal with Toxicity and Hazard Data.  The International  Technical
Information Institute, Tokyo, Japan, 1976.  591 pp.

6.   Hazardous Waste Land Treatment.  SW-874, U.S. Environmental  Protection
Agency, Washington, D.C.  1983.  671 pp.

7.   EPA Memorandum.  "Guidance on Petroleum Refinery Waste Analyses for Land
Treatment Permit Application."  April 3, 1984.

8.   Permit Applicants'  Guidance Manual for Hazardous Waste Land Treatment,
Storage, and Disposal Facilities.  SW-84-004, U.S. Environmental  Protection
Agency, Washington, D.C.  1983.  Available from Superintendent of
Documents, U.S. Government Printing Office, Washington, D.C.

9.   Guidance Manual for Hazardous Waste Incinerator Permits.  SW-966, U.S.
Environmental Protection Agency, Washington, D.C.  1983.  Available from
Superintendent of Documents, U.S. Government Printing Office, Washington, D.C.

10.  Design and Development of a Hazardous Waste Reactivity Testing Protocol.
EPA-600/52-84-057, U.S. Environmental Protection Agency, Municipal
Environmental Research Laboratory, Cincinati, Ohio.  Available from the
National Technical Information Service  (NTIS No. PB84-158807).

-------
                                 APPENDIX C

             HOW TO USE A RANDOM NUMBERS TABLE FOR WASTE SAMPLING


     This appendix has been developed to demonstrate how hazardous waste can
be sampled without any bias by the sampler.  It is important that the sample
you obtain is representative of the actual  waste's chemical  and physical
characteristics.  To avoid taking many samples that are expensive and tedious,
you can, with the aid of a random numbers table, select areas in a waste
collection that should be just as representative of the waste.

     The following example explains how to  use a random numbers table.

     Let us assume that we have 30 drums stored.  We assign  a two digit number
to each drum ranging from "01" to "30".  Now refer to Table  1,  "Random
Numbers".  We will use these numbers to decide which of our  30 drums to
sample.  We select the point at which to begin in the table  by using our date
of sampling.  For example, if we sample on  October 14, 1983, we move to the
10th horizontal  set of numbers.  (October is the 10th month  of the year.)  We
then move to the 14th set of vertical numbers (the 14th day  of the month).
Next we use the years, "83".  We start with the first number on the first row
of this set of 10 digits and count 8 digits to the right.  At the eigth digit,
we then count down 3 digits.  This is our starting point.  We read the numbers
from left to right in sets of two digits since the maximum number of barrels
(30) has two digits.  Any number greater than 30 is ignored.  If any number is
repeated, each repeat is ignored.  If we come to the end of  a row on the page,
we return to the far left on that same page and begin reading numbers left  to
right in the next row below it.  We continue selecting two digit numbers
between "01" and "30", inclusive, until the number of drum samples required
has been fulfilled.

     If we wanted six samples, we would begin with --


JJ7S|03


[Oil 84 1
24J3 83533 2544^

05J10
[Six was chosen as a sample number only for the purpose of this demonstration.
It does not mean that everyone should sample six out of every  thirty drums.]
Therefore, drums numbered 24, 25, 01, 03,  18 and 05 will  be sampled.  Figure  1
displays the barrel  numbers selected.

     This random numbers method can also be used for other waste sampling
scenarios, e.g., surface impoundments.   These other scenarios  may entail
dividing your waste collection into a three-dimensional  grid.   Figure 2
displays how such an area could be numbered for three levels of depths.  The
number of levels required depends on the waste and on the facility design.
"Test Methods for Evaluating Solid Wastes"  (SW-846) should be  reviewed for
EPA's latest guidance on determining the total  number of points to sample.
                                     C-l

-------
                                                       TABLE 1. RANDOM NUMBERS
         Day

  Month      1


                2


                3


                4
                6


                7


                8


                9

October   10



               11


              12
1(21)    2(22)   3(23)   4(24)    5(25)
5)172 34774
04328 (2404
Ilt 44190
4)117 1027*
22159 1(442
309SI 21721
19452 24241
1349) 0052*
((7 33919
i)o ini
40)1* 76212
19244 54664
99(76 17075
06437 10072
142*7 07(17
51661 57130
K4S~ 1171)
4(01 illll
I9K AIMZ
1900177727
72)4( J56I7
19094 (4)59
(2247 77127
759 1MM
19(1 1(093
64121 15117
4M7 (1)7)
5474( 52137
22241 4IIOI
II9M 20041
7(()7 07(09
9)I9( 47120
15292 inn
9)792 29121
(5731 91049
720(4 (2102
01227 )5(21
447(1 3(504
(9M 9I2K
01100 }9)ll
II 756 45441
3905* ltd*
I80JS 9)172
12641 27941
16254 17(61
(9J2 19109
(())( KM)
(5727 ((411
51)05 14411
93402 3I74
19221 94510
4(10) 5(7(0
70(9 27(77
(99)1 202)7
172M 22741
(Oli'l 92)17
46210 47(74
55)99 4)142
21(77 (4950
41947 700(4
19017 11775
71577 009(4
75524 (20)1
14011 ((4)4
(1(79 474)(
(1525 1(0)1
96(17 91200
(96)1 29SJ4
(04)9 205)4
10(11 44124
J750S (0(61
O424 97(99
40914 01912
110(0 7102)
0551? 101(2
97442 29590
1(117 09(9(
(2*19 27619
9(950 4I5)(
1)091 5(71)
14714 219)0
(9129 10942
01(52 50774
31)74 52249
999(0 91107
(0921 55226
441(0 0(2(6
(412( 19012
0299) 99)40
I04IS 44411
95)71 9J5SO
9192( 30SK
MHO 1245)
10577 41114
94127 47551
1915) 794(2
10(07 (17)4
1)99) 59701
(57)6 72247
577)0 (4410
5994) 57973
5)4) (2909
(Mil 39164
7(750 19915
Mill (((09
74119 94(2(
1)010 40412
12)04 70011
99410 )2()5
911)4 11(10
57711 (4)(C
125(4 33649
99(21 63065
75246 59124
41946 74109
(5150 27721
51747 95)54
12214 9529)
97041 43081
90)11 171))
71440 12012
5(056 12404
2142) 4(211
1(1(1 06-:OI
19(11 12232
775(1 (5)7)
107(9 521(6
(02(4 17121
9(1(5 72)45
11)45 (49(9
21245 (7)37
44151 (9231
9(196 5)501
(4)49 409(4
1)7(1 (2216
216)4 79772
24409 05079
4)744 1102)
19974 ((2(7
29179 45421
14(31 1(209
5)101 )775(
04970 0)00
2101) 20365
99(34 74279
51)9) 93)62
1511) 5255)
5911) 19151
91044 (72(1
11712 34(11
16909 50(09
21136 4945)
13656 (37)6
294)1 9127)
99X0 79667
12973 02631
02(00 45564
(12)( 9241)
(4099 (CMS
47(17 (11(9
92412 700)7
27199 04434
42012 10447
(((15 34015
5((2( 58421
09299 10649
501)9 30769
91)24 51764
429)4 40911
97590 OOOM
19040 4)27)
35176 1227)
7)194 704(2
124)4 22012
017(0 24094
(4)11 476(7
(77)7 T3477
5O99 (1)5)
1014) 34294
11(74 00126
75092 M60S
17(41 51)92
922)1 96306
903M 10292
39560 951)1
(4794 511(7
19559 73921
72411 (0950
96391 52(25
M761 41(19
95419 101(4
017(1 11604
(1(11 744(6
39417 77712
617(4 45542
7)101 70122
7(60) 37363
II 114 17(79
13346 (91(7
71416 20411
52202 0)979
2951) 2(792
117(0 22172
57475 12756
(0145 51101
13757 47430
5(4)6 9(155
10136 7(1(7
51081 12751
15591 (22)7
9900) 99042
14145 79205
7042) (6917
2254) 7(155
((254 72797
00)02 79474
72)44 710)4
09497 66031
49(77 7(215
31130 4333(
30210 30345
33719 1(4(1
459)) 21144
4)011 27150
75051 2753)
3340l'5457l
1)041 (1407
(7274 4)10)
91750 274)1
(2770 42)21
(9072 2200)
51)57 05419
19)16 77945
797)1 124)5
40210 76(17
66071 03621
2096 09592
17541 12991
914(1 01 OW
757(0 )75((
75441 1)141
92561 )])!(
72606 10601
54555 47)71
34751 34141
125)5 13834
49)75 22147
(6)11 1401 (
30866 45132
22)11 41215
(7M) 09152
02)12 2I(5(
91092 45(72
32107 3)770
(1119 03162
4(467 47152
114(1 4(791
222K 701)9
45539 7(2(1
1(53) 7(700
05970 7441)
42140 45172
67516 (21)5
51261 757)9
11170 304)3
I4S33 95(22
1029) (7506
4147) 99025
7400) 3)77)
11797 14312
30)64 36664
79517 934J6
(4412 11502
12107 22066
(7117 44(99
71656 14001
41)70 9(126
36631 17927
(6910 1022)
5(9)7 91901
55912 31638
((60) 41011
36844 57614
942(4 (95K
4946) 66646
571)5 34921
41036 (0310
96002 0(914
05142 77950
2177) 13371
(94(5 (I4J)
47462 539)1
45004 19195
56301 99752
52)17 50(41
95240 03(0)
9(2)9 50JS4
79639 ()6)1
90)50 71191
33621 14199
6(26)    7(27)    8(28)   9(29)   10(30)
                                                                 1(972 421(1
                                                                 749)8 79042
                                                                 71073 33(71
                                                                 7(744 2(190
                                                                 (227) (929)

                                                                 102)9 230JI
                                                                 41177 771(1
                                                                 01715 )1(00
                                                                 1(1)5 47434
                                                                 1.-9I5 (1979

                                                                 77411 914)1
                                                                 19451 1(7)1
                                                                 0)311 35119
                                                                 11(39 27)15
                                                                 130)2 142(1
         (7945 94104
         3147) 19(72
         11047 92759
         21(49 7975)
         2)31) 591(5

         09376 2(055
         11212 10)49
         (97)0 71912
         9I()( 15119
         02979 91092

         42)02 (((02
         010)9 1(9)1
         10)55 01217*
         09204 2(211
         20641 15111
95701 00741  754l sft)0
45752 15715  193)7 71133
94319 3947)  91(79 W))6
21117 17691  19490 M511
IU5( 34510  47274 (9M4
(7099 41)72
49111 17540
19642 39764
11)45 (0509
41114, 7MU

2(596 44173
92I(( 137(7
00441 12(00
57125 51470
KU( 12079
3)342 J2754
617(1 117(9
47I4( 19472
11)91 301(6
379)9 91037

(4)59 97)70
36141 362(1
24(04040)4
5(10) 11141
67394 00017
34169 9)991
09(51 24911
41676 152)0
14111 0(114
550)1 2(711

17117 9461)
31661 55(04
(4012 01117
17629 2120)
04160 (6647

44417 55591
79910 7(514
70J72 710(1
1(111 5191)
317(9 907)7
110(1 51150
(1(55 16181
4(422 09247
KIM 5(193
90(17 1704*
4010] 7(719
09606 (94(3
(2479 29(10
402)1 11140
10690 55550
7)951 1(949
3(554 57926
13676 20)))
01)1) 13677
2944) 1J417
S4I6J 9*7)7
202(9 14456
0(790 9910)
71(90 79726
7(22220006
1)414 2119)
104(1 751)1
27105 77095
47736 36)31
6091) 11970
02741 59912
74102 59)54
0(9)) 71(51
40)45 10092
70055 91(13
39(13 0(554
1400 15077
4)40( 1609)
11409 18241
301(5 (9119
57644 5(746
1(5)6 94055
0)1)5 51050
02312 99231
(1273 71369
995C1 7271)
41529 00(19
77(22 93711
9(572 1(401
03(14 (1401
68661 4)49)
41601 11787
1(4)9 942)5
0(491 774)1
91660 (((90
10471 19499
4171) 14179
72016 J36S)
07546 1(014
90211 79457
92106 (215)
9121) 2(29)
436)6 77309
50517 1(5)5
10244 11760
((716 40M3
47234 01529
01161 2(52)
514)6 701(1
97419 (3007
4)00) 01104
16321 565))
15(55 66121
09)27 5507)
1)631 47000
12665 01244
51971 09441
5715) 097(0
11)79 18)19
411)1 1)701
11)76 (1(39
((056 ((290
4(5(0 (2912
49(64 (9775
01190 05311
(0411 5164)
5(045 79079
Ol})( 40)11
7)126 11)(4
30141 92034
19715 41550
Kill 91111
2(610 14)07
19001 (1179
21951 719(5
(1379 1)714
341)7 24161
3I4CX 49)(0
98500 74701
11477 11901
470)1 (592)
16(70 57295
01115 1(166
((0)0 299)1
(9425 60371
17199 (1950
60291 (10(6
26791 MOM
41125 33931
(9754 37493
07421 3(4)5
1746) M2I
(2)02 4)19)
46430 2I22
76(31 O44I
270)) 4(45)
20212 915(0
74(7) 11)11
7(7)0 47212
12541 9)216
JIOSI 31860
0147) 1079)
(1045 13107
12572 775(9
M90) (69)4
62015 )!)))
93(21 3140
9924) (5090
99146 7<3?0
97472 74441
61045 5(619
1(149 1(324
11(54 74206
00321 (7139
til IT 23474
(((20 0)704
2(1(1 411(5
319)9 43(91
36342 0)327
57455 7(644
14(55 13511
0)0)1 (0771
970(7 97104
090(1 91746
119(7 (0754
7(15) SUM
(0541 93121
36623 62931
7(795 95719
3(624 37)91
33712 7(()2
-1(129 11641
(29)5 14149
1)459 151)0
42442 0760*
                                                                 14552 7(17)
                                                                 4515) 16947
                                                                 7I35S 21(92
                                                                 93474 76461
                                                                 14(19 91(9)
         409219)696  9771II5IU  310040)26)  05(2(074(0
         42417 28771  149)6 94099  90775 42001  16673 62770
         14077 17114  )))I6 49494  31817 90127  19415 92)02
         12019 04274  01191 2)9)0  ((711 11142  (3(59 21941
         1(499 00179  15151 (7716  (1909 4)7)6  I92M 93M(
                                                                 44546 75524  (1515 774)4  1(541 11479  5)150 71(01  106)4 (2713
                                                                 12917 96024  04714 03809  32711 1)577  02269 (1O1  11110 462(1
                                                                 1)04) 314))  471)1 752)4  745)9 1(529  5719) 45997  71749 1(666
                                                                 99)57 5459)  IKK (42K  839)1 31741  12891 097)7  6 504 1(946
                                                                 01072)1(79  (09(1)4029  544(109594  11939 31777  44794 4M

                                                                 90831 50179  420(4 (29(7  1)072 (4227  240(0 594M  05(95 1(1)4
                                                                 13914 19441  93149 (7937  1(935 199(0  26142 43600  754(6 74 01
                                                                 (7047 77214  12751 45644  47141 557(1  04(72 5754)   '
                                                                 91727 4661)  41043 49(1)  29)15 17200  9(47) 56M)
                                                                 174)9 301(1  44171 1(491  57170 77(91  21004 Mill
                                                                                                                                     (4706 254)1
                                                                                                                                     1(774 07)0)
                                                                                                                                     19711 1319
       Source: Statistics with Applications to the Biological and Health Sciences.  R. D. Remington and Wl. A. Schork, 1970.
                                                                       C-2

-------
TABLE 1. RANDOM NUMBERS (con.)
Day
Month







October


1
2
3
4
5
6
7
8
9
10
11
12
11(31)
91192 51631
933S1 inn
] 245
JI301 7020*
01457 10015
30691 IOIII
17141 4llld
36775 63621
023*0 3167*
16744 466*7
66412 04J02
76371 4111*
9)772 72925
59011 11612
52352 04440
08017 07(2*
27214 3941*
20)11 31511
36076 17121
60679 41162
49416 58370
57S7 19149
17179 777JI
00757 1112*
6(2/6 79013
64716 9I69S
13695 11496
51275 66797
51005 84170
99991 10051
51692 51 $07
297 5>i:0
05041 40582
75711 3S76I
210J1 1517)
9092 60W1
C7204 91171
15159 97214
J0497 91407
09711 IM75
95330 01915
0*7(0 31381
0153* 11967
11214 59150
HUH 41761
34?OS 05174
47)12 6211
S5M5 91302
PaOJ JM!4
JKM> IH
01921 11647
07202 76476
6S813 61242
63323 06496
IOSI9 11SIJ
44200 58929
30154 29121
0--17 14292
31764 Il:i2
11727 35572
12
11909 11674
21912 24171
HIM 11117
42174 10757
15741 7V4I6
90071 71120
3J17J IIM7
7i1<5( 41164
79600 21297
01111 50201
29770 420t
65940 37120
19454 63712
1)000 19110
43621 34976
04119 77570
57313 03503
82309 69931
61723 37934
43675 03631
61738 87313
II 730 92494
65111 44979
09641 07644
71273 (3412
4544S 92211
37066 41151
15110 41155
29999 21611
OHIO OH 14
19056 74472
04152 52595
46051 60261
70475 00601
10741 45(14
12571 7175)
15112 29SIO
0/771 21391
129UO 15(199
45U2 54961
24121 60514
05601 49921
15117 95(11
41361 57195
(0221 59611
<3304 43178
83158 92445
43CI9 45(61
10110,27159
64717 59010
9(441 59293
71888 34845
95750 11033
17446 41171
97371 41064
26044 49211
75(74 42199
(9098 66717
26675 641(4
95469 36823
13
91956 14511
26172 12044
17512 11216
91511 15725
72457 59502
11673 71161
671M 16791
(1426 31415
16414 17174
56101 09171
04511 42575 '
292(1 94564
21401 96665
WJJ 7323J
93012 16596
47155 77121
71441 4:511
12658 ann
63818 MI57
21060 (1096
19290 17656
41113 35113
9093* 29114
1 1619 68088
9712H (1001
71114 67432
74734 361(1
443(9 94860
91012 41392
42067 76669
91214 20261
95514 56541
04996 12256
1(171 12077
92222 16704
65214 11115
10371 64136
64657 42011
51651 31041
41741 12030
42519 91907
66126 14146
14641 40792
16217 03046
27504 21 121
97247 24(75
1 60650 76219
95491 16106
13001 20544
7(4(9 12626
Mill 31425
17461 41964
58634 71411
12161 12019
16221 99697
56145 67200
41 121 90C41
14731 73336
64451 29021
11112 95011
*14*
60422 55574
41214 01301
29661 26014
6(201 61219
4671609051
49929 70495
91342 11120
17114 24170
00109 07711
55991 60212
99111 14406
96591 00619
77750 21211
46514 59011
21596 (5491
24491 67455
71335 61670
11290 60114
54390 91261
71112 2(930
16130 21490
69112 36411
76614 58007
34112 04971
65911 35 10
32145 41312
09251 65456
42074 31 171
15S( 7(399
1-96(6 640C4
16019 94191
06616 61791
47175 (7507
16521 10141
00197 51267
12919 50721
11459 OC215
12751 01021
25972 41691
71412 79416
25694 17097
67211-52234
47562 95494
17136 36037
94711 11807
26259 67622
02772 41651
1271] 177111
41665 99419
60661 31711
76412 17062
68694 59662
01321 19111
66101 56711
17951 07947
21125 15056
19515 06164
47711 14165
011(1 11674
61121 14965
15
11(70 (103*
(671$ 01095
02919 17619
26701 41?! 6
70961 l73
92247 04111
41761 24164
55661 03111
05109 38159
31303 30689
11405 21 IK
6046 97375
02390 50796
60241 274
10/34 41760
06320 12C04
17359 77927
10741 89647
70109 06735
449)7 03354
30961 57150
OSWI 01981
14(71 11816
27565 663/7
71167 29316
11549 12414
12411 9615 /
27967 12666
59902 21561
67141 10120
11767 73915
67504 57205
05112 18439
07057 7(126
11224 40276
88987 69761
67650 72930
24224 24911
llvll 4(040
S3032 109(4
19566 24041
48311 19442
62017 18064
93913 70910
(0312 41339
14657 10154
66449 19211
11 7JO
70606 26074
70062 14219
01295 11011
55905 26891
29127 47526
41101 12641
12935 49391
51345 06309
47103 19679
12842 00121
01131 13129
14166 12151
                     16   17
18
19
20
10807 5)351
73IC4 23M2
06110 62724
22091 34134
11171 64711
11271 36101
HI4* 6S7S6
91108 43361
1184} 01542
02044 21164
38608 11174
41164 21909
10911 52950
67690 96766
I37 17014
46351 19711
10019 09512
19200 92772
511 II 57942
17210 13027
16026 97391
71756 72721
36115 10281
66117 16252
2C>!4 11929
5526) 15651
44454 0-1601
11(1] 16969
17811 12954
15466 62947
74012 62183
1IU4 14992
45646 1661$
69250 19144
25162 151 14
44677 50111
52211 09164
42195 91614
14807 61214
70166 41212
21721 16160
15940 57190
25075 12609
12717 305(1
1(149 26211
(2270 9!I6
14292 74431
49399 71(71
94911 195(1
92571 19377
0(740 05279
(5359 101*1
0.-085 28051
47(55 41419
10712 2)210
26621 1197*
20910 (1230
19272 46462
76093 47414
91102 70715
32117 07/71
71107 78715
11112 2I34S
4363* 7999*
77175 49561
27(01 600(1
57777 15934
67101 12054
9496? 6114*
15004 854
10455 lion
12491 1476*
27196 54171
7M7 6241)
29052 7IJIS
10651 04261
41401 61230
76111 27/53
24461 91764
3021 1. 13386
61(16 41214
01426 02110
17/10 35457
07414 14001
16747 (7007
06056 97177
05160 2615*
16491 13981
15907 72184
20461 16?I2
71512 16476
61C94 92S40
68476 65S21
54079 400C9
I1J6J 46776
14017 67005
(3325 91553
01151 73692
52907 166/5
11909 79431
             C-3

-------
Figure 1. Display of drums selected for sampling based on a random numbers table.
                                  C-4

-------
                                                           Top Level
                                                           Middle Level
                                                           Bottom Level
Figure 2. Three dimensional grid for selecting sampling cells.
                         C-5

-------
                                     APPENDIX  D
                   DRUMMED  WASTES -  ESTIMATING SAMPLING  SIZE
      <1
        Designation: 0 140-70


           AMERICAN SOCIETY  FOR TESTING AND  MATERIALS

                           19U Re St. Philadelphia, P*.. W03
                 fttrnmtd from the AfuraaJ Book ui ASTM Sundatdi Opyr.tht ASTM

        Standard Methods of

        SAMPLING  BITUMINOUS  MATERIALS1

Thi bumbrd K r>MMd under (he fixed de.naiwn U I JO: the numtier .mmeduuHv rmhwin* (he deunuuun indiaiai
ite .car of oriental adoption or. in ibe ca> .if rvi,4,i. the jear of lax ftviMon.  ,\ number m (urcmhew indiuin (h<
>ear of last rctppco\at.
12. Sampling Semisolid or Uncrasfad  Solid
    Materials
  12.1  Drums, Barrels. Cartons, and Bags
Where the lot of material to be sampled  is
obviously  from  a single run  or batch of the
producer,  one  package  shall be  selected at
random, and  sampled  as described below.
Where the lot of material to be sampled  is
not obviously from  a single  run or  batch of
the producer,  or where  the  single  samples
selected as described above  fails on test to
conform to the  requirements of  the specifi-
cations, a  number of packages shall be se-
lected at random equivalent to the cube ruot
of the total number of packages in  the lot.
The following  table is given, showing the
number of samples to  be selected for  ship*
ments of various sizes.
JT-ii V rjmfm if* QlifflflMttff
f jcujp % ill ^mprnwifc
2M*
9 u>:?
;x ui M
65 to 125
126 to 216
:!7w34J
344u 512
Jl 3 to 719.
730 to lOTO
1001 to 1331
Paefcam
2
3
4
5
6
7
8
9
to
11
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                                          from the  soft. When more than one package
                                          in a lot  is .sampled, each individual sample
                                          hall be not less than . Ib (O.I  kg) in weight.
                                          When the lot of material i> obviously from a
                                          single run or batch  of the producer,  ail sam-
                                          ples from the  lot .shall  be  melted and thor-
                                          oughly mixed, and  an  average 1-gal  (4-drrT)
                                          sample taken from the combined material for
                                          examination. In ca>e mure  than a single run
                                          or batch of the producer is present and the
                                          hatches can  be clearly  differentiated., a com-
                                          posite  1-gal sample  shall be prepared for ex-
                                          amination from each batch. Where  it is not
                                          possible to differentiate between  the various
                                          batches,  each  sample  shall  be examined
                                          separately.
Samples shall be ukea from at least 3 in.
(76 mm) below the  surface and at least 3 in.
                                           D-l

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                                 APPENDIX E
       A RANKING METHOD TO SELECT FREQUENCY OF WASTE RECHARACTERIZATION
     This ranking method has been developed to aid in selecting the
appropriate frequency of waste recharacterization.  It is  intended  primarily
for facilities that receive wastes from an offsite generator;  however,  it  may
also be modified for use by onsite facilities. The method  allows several
criteria to be taken into consideration in determining the frequency  of
recharacterization.  It should always be kept in mind that the objective of
recharacterization is to minimize the potential  for any environmental
contamination at a facility by an unmanageable waste.

     Figure lisa worksheet designed to rate wastes (especially those
generated offsite) on the basis of the likelihood that the character  of the
waste will  be drastically altered between shipments.  A worksheet should be
prepared for each generator and their waste that is served by  the facility.
The sheet lists five criteria to be evaluated

          The potential for restricted wastes to be combined in a waste
          shipment that is normally permitted.

          The design limitations of the hazardous waste management  process.

          The variability of a waste's composition among shipments.

          The likelihood of the waste undergoing changes that  will  affect
          its manageability.

          The prior history of the waste generator performance and
          reliability.

     Weighting factors  ranging from one to five can be assigned to  each of
these criteria to assess its relative importance (5 is the most important).
That is, how significant of an impact would an episode that falls under one of
these criteria have on  the facility's operation; for example,  a generator
mistakenly sends a shipment of wastes containing oxidizing agents rather than
the contracted spent solvent.  These weighting factors will vary depending
upon the hazardous waste process under consideration and the limitations of
the facility's permit.   It is often helpful to prepare a list  of reasons why
criterion has been assigned a given weight.

     After assigning weights, probabilities ranging from 0 to  4 should  be
chosen for each criterion indicating the likelihood of a given generator and
waste meeting that criterion.  For example, what is the likelihood  of a
contracted waste having a restricted waste mixed in its shipment. It  is again
helpful to prepare a list of reasons why a given probability is selected.
                                     E-l

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                                      FIGURE 1.   RECHARACTERIZATION DECISION CHART
                                 Weight                    Probability
                                                                               Product
Restricted Waste Combined
in Shipment
Process Design Limitations
Variability of Waste
Composition
Chemical/Physical Instability
of Waste
i
Generator's Performance
Hi story





0





1





2





3





4





Actual (Max.)




TOTAL ACTUAL (MAXIMUM)
Weight = 1 to 5 with 5 being the most important
Probability = 0 to 4 with 4 being the most probable
     TOTAL ACTUAL
     TOTAL MAXIMUM
x  100 = X

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     The products of each criterion weight and probability should be totaled
in the far right column of the worksheet along with the maximum total
possible.  Incorporating these totals into the worksheet equation yields a
value of "X" that can be used in the following chart to determine the percent
of a generator's shipments that should be recharacterized each year.


                                         % of number of shipments
                X                        recharacterized over one year*
              100                                  100%

            75 - 100                                75%

            50 - 75                                 50%

            25 - 50                                 25%

             0-25                                 10%
This chart assumes that a facility receives at least one shipment of a given
waste each year from each generator.  It is recommended that at least the
first shipment be recharacterized, so one can document waste characteristics
in case future shipments are not received.

     Figure 2 is an example of how the worksheet would be completed.
^Distribute sampling and analysis of shipments should be well-distributed
over the year.
                                     E-3

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                             FIGURE 2.  EXAMPLE RECHARACTERIZATION DECISION CHART


                            Weight                    Probability
                                                                                                 Product
Restricted Waste Combined
in Shipment
Process Design Limitations
Variability of Waste
Composition
Chemical/Physical Instability
of Waste
Generator's Performance
History
5
5
3
2
2
0



X

1

X



2
X




3


X


4




X
Actual (Max.)
10 (20)
5 (20)
9 (12)
0 ( 8)
8 ( 8)
TOTAL ACTUAL (MAXIMUM)



Weight = 1 to 5 with 5 being the most important


Probability = 0 to 4 with 4 being the most probable


     TOTAL ACTUAL


     TOTAL MAXIMUM
                x  100 = X
                                                                                             32  (68)
32
--  x  100 = 47 = X
                                   [As seen in the table on page E-2, the value of "47" falls within  the
                                   "25 to 50" range; therefore, 25% of the number of shipments would  be
                                   	1 ^^^4.^^.4^^^ >-li i ri i^n 1- h a waar "1

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