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.
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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 facility—the 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 facility—the 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
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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
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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.
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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—
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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
-------
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
-------
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
-------
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
-------
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
-------
(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
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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
o.
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.
3
•a
o
c
3
n>
3
(a
OJ
o
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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.
-------
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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during rainfall.
2. Put in linear
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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 • jQCUi4i£AJ 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 Ti«ie /: 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.
-------
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—
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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.
-------
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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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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^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- J£O^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).
-------
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).
-------
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 550°C)
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.
-------
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."
-------
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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to
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,
-------
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
-------
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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^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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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.
-------
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
-------
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.
-------
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.
-------
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.
-------
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
Il««t 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
(9«M 9I2K
01100 }9)ll
II 756 45441
3905* ltd*
I80JS 9)172
12641 27941
16254 17(61
(9«J2 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
»2»97 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 4«20t
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
15«S( 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 l»73»
92247 04111
41761 24164
55661 03111
05109 38159
31303 30689
11405 21 IK
6046« 97375
02390 50796
60241 27«4
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 7«JO
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 8«54
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 R«e« 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 r«vi,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
Sflrrtnt
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
-------
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
-------
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
-------
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
-------
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 r»i i^n 1- h a waar "1
------- |