oEPA
United States Enforcement and
Environmental Protection Compliance Assurance
Agency (2224 A)
EPA-305-B-98-006
December 1998
Protocol for Conducting
Environmental Compliance
Audits of Treatment,
Storage and Disposal
Facilities under the
Resource Conservation
and Recovery Act
EPA Office of Compliance
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Notice
This document has been developed to assist in conducting environmental audits. The use of this document should
be restricted to environmental audits only. For example, areas such as safety, transportation, occupational health,
and fire protection are mentioned solely for clarification purposes. It is a summary of environmental regulations
under RCRA but it is not a substitute for a comprehensive knowledge of the regulations themselves. Any
variation between applicable regulations and the summaries contained in this guidance document are
unintentional, and, in the case of such variations, the requirements of the regulations govern.
This document is intended solely as guidance to explain performance objectives for environmental auditors.
Following the steps set forth in this guidance generally should result in compliance with those aspects of the
regulations that it covers. The U.S. Environmental Protection Agency (EPA) does not make any guarantee or
assume any liability with respect to the use of any information or recommendations contained in this document.
Regulated entities requiring additional information or advice should consult a qualified professional.
This guidance does not constitute rulemaking by the EPA and may not be relied on to create a substantive or
procedural right or benefit enforceable, at law or in equity, by any person. EPA may take action at variance with
this guidance and its internal procedures.
Acknowledgements
EPA would like to gratefully acknowledge the support of the U.S. Army Corps of Engineers Construction
Engineering Research Laboratories (CERL) for their assistance in developing checklist items pertaining to the
RCRA Subpart CC and for providing suggestions for the overall format of this document.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Table of Contents
Notice inside cover
Acknowledgements inside cover
Section I: Introduction
Background ii
EPA's Policy on Environmental Audits ii
Purpose of the Protocols for Conducting Environmental Compliance Audits iv
How to Use This Protocol iv
List of Acronyms and Abbreviations vi
Section II: Audit Protocol
Applicability 1
Review of Federal Legislation 1
State and Local Regulations 2
Key Compliance Requirements 2
Key Terms and Definitions 3
Typical Records to Review 15
Typical Physical Features to Inspect 16
Index for Checklist Users 17
Checklist 19
Appendices
Appendix A: Identification and Listing of Hazardous Waste Al
Appendix B: Identification of Hazardous Waste Hazardous Constituents Bl
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates
Identified as Acute Hazardous Wastes Cl
Appendix D: Potentially Incompatible Hazardous Wastes Dl
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates El
Appendix F: Constituent Concentration in Waste Extract Fl
Appendix G: Treatment Methods Expressed as Specific Technologies Gl
Appendix H: Constituent Concentrations in Wastes HI
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Section I
Introduction
Background
The Environmental Protection Agency (EPA) is responsible for ensuring that businesses and organizations
comply with federal laws that protect the public health and the environment. Recently, EPA has begun
combining traditional enforcement activities with more innovative compliance approaches. In its Strategic Plan,
the Agency recognizes the need to assist the regulated community by providing compliance assistance and
guidance that will promote improved compliance and overall environmental performance (see Exhibit 1). EPA
encourages regulated entities to recognize compliance as the floor, rather than the ceiling, of environmental
performance by internalizing and implementing sound environmental practices. As part of that effort, EPA is
encouraging the development of self-assessment programs at individual facilities. Voluntary audit programs play
an important role in helping companies meet their obligation to comply with environmental requirements. Such
assessments can be a critical link, not only to improved compliance, but also to improvements in other aspects of
an organization's performance. For example, environmental audits may identify pollution prevention
opportunities that can substantially reduce an organization's operating costs.
Over the years, EPA has encouraged regulated entities to initiate environmental audit programs that support and
document compliance with environmental regulations. EPA has developed this audit protocol to provide
regulated entities with specific guidance in periodically evaluating their compliance with federal environmental
requirements.
Exhibit 1 - EPA's Credible Deterrent Goal
Within its Strategic Plan, EPA has established a goal to ensure full compliance with the laws intended to protect
human health and the environment. Within the framework of this goal, EPA's objectives are as follows:
Identify and reduce significant non-compliance in high priority program areas, while maintaining a strong
enforcement presence in all regulatory program areas,
Promote the regulated communities' voluntary compliance with environmental requirements through
compliance incentives and assistance programs.
EPA's Policy on Environmental Audits
In 1986, in an effort to encourage the use of environmental auditing, EPA published its "Environmental Auditing
Policy Statement" (see 51 FR 25004). The 1986 audit policy states that "it is EPA policy to encourage the use of
environmental auditing by regulated industries to help achieve and maintain compliance with environmental laws
and regulation, as well as to help identify and correct unregulated environmental hazards." In addition, EPA
defined environmental auditing as a systematic, documented, periodic, and objective review of facility operations
and practices related to meeting environmental requirements. The policy also identified several objectives for
environmental audits:
* verifying compliance with environmental requirements,
> evaluating the effectiveness of in-place environmental management systems, and
> assessing risks from regulated and unregulated materials and practices.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Exhibit 2 - EPA's 1995 Audit Policy
Under the final Audit/Self Policing Policy, EPA will not seek gravity-based penalties and will not recommend
criminal prosecutions for companies that meet the requirements of the policy. Gravity-based penalties represent
the "seriousness" or punitive portion of penalties over and above the portion representing the economic gain from
non-compliance. The policy requires companies:
« to promptly disclose and correct violations,
« to prevent recurrence of the violation, and
» to remedy environmental harm.
The policy excludes:
« repeated violations,
» violations that result in serious actual harm, and
« violations that may present an imminent and substantial endangerment.
Corporations remain criminally liable for violations resulting from conscious disregard of their legal duties, and
individuals remain liable for criminal wrongdoing. EPA retains discretion to recover the economic benefit gained
as a result of noncompliance, so that companies will not be able to obtain an economic advantage over their
competitors by delaying investment in compliance. Where violations are discovered by means other than
environmental audits or due diligence efforts, but are promptly disclosed and expeditiously corrected, EPA will
reduce gravity-based penalties by 75% provided that all of the other conditions of the policy are met.
As a result of EPA's new audit policy, through March 1998, 247 companies have disclosed environmental
violations at more than 760 facilities and EPA has reduced or waived penalties for 89 companies and 433
facilities.
The final Audit/Self-Policing Policy was published in the Federal Register on December 22, 1995 (60 FR 66706).
It took effect on January 22, 1996, For further information, contact the Audit Policy Docket at (202) 260-7548 or
call (202) 564-4187,
In 1995, EPA published "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of
Violations" which both reaffirmed and expanded its 1986 audit policy. The 1995 audit policy offers major
incentives for entities to discover, disclose and correct environmental violations. Under the 1995 policy, EPA
will not seek gravity-based penalties or recommend criminal charges be brought for violations that are discovered
through an "environmental audit" (as defined in the 1986 audit policy) or a management system reflecting "due
diligence" and that are promptly disclosed and corrected, provided that other important safeguards are met (see
Exhibit 2). These safeguards protect health and the environment by precluding policy relief for violations that
cause serious environmental harm or may have presented imminent and substantial endangerment, for example.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Purpose of the Protocols for Conducting Environmental Compliance Audits
This protocol, which is part of a set containing other area or statutory specific audit protocols, is a tool to assist
you in conducting environmental audits, which should inform you whether your facility is in compliance with
federal regulations. EPA has developed these audit protocols to assist and encourage businesses and
organizations to perform environmental audits and disclose violations in accordance with EPA's audit policy. The
audit protocols are intended to promote consistency among regulated entities when conducting environmental
audits and to ensure that audits are conducted in a thorough and comprehensive manner.
Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the
federal laws affecting a particular environmental management area. It also includes a checklist containing
detailed procedures for conducting a review of facility conditions. In order to use these documents effectively,
you should be familiar with basic environmental auditing practices and the relevant environmental regulations
under Title 40 of the Code of Federal Regulations (CFR). The audit protocols are not intended to be exclusive or
limiting with respect to procedures that may be followed. EPA recognizes that other audit approaches and
techniques may be effective in identifying and evaluating a facility's environmental status and in formulating
recommendations to correct observed deficiencies.
These protocols can be used as a basis to implement, upgrade, or benchmark environmental management
activities. The protocols are a management tool for measuring and improving environmental performance by
correcting deficiencies uncovered by the audit (see Exhibit 3). This process is perhaps the key element to a high
quality environmental management program and will function best when an organization identifies the "root
causes" of each audit finding. Root causes are those breakdowns in management oversight, information
exchange, and evaluation that allow environmental problems to recur. Thus, while an organization may have
developed an excellent record of dealing with a symptom, such as spill response, the underlying problem or "root
cause" has not been addressed. Furthermore, identifying the root cause of an audit finding can mean identifying
not only the failures that require correction but also the successes. In each case a root cause analysis should
uncover the failures while promoting the successes so that an organization can make continual progress toward
environmental excellence.
Exhibit 3 - Corrective Action Model
Audit
i
N
Improve
Environmental
Mgmt. System
Effectiveness
^
\|
—
Identify
Problems
I
Fix
Problems
Develop Actions
to Correct
Underlying
Causes
—
Analyze
Exceptions
for
Cause/Effect
*
Group Findings
for Common
Causes
1
Examine each
Group for
Underlying
Causes
How to Use This Protocol
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
IV
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
To conduct effective compliance audits, the auditor or audit team needs to possess sound working knowledge of
the operations and processes to be reviewed, the relevant regulations that apply to a given facility, and of
acceptable auditing practices. The audit protocol should be used as a planning tool to assist the auditor in
understanding the requirements for conducting a comprehensive audit. This document will provide the user with
a generic audit approach to regulatory issues that may require closer examination. Once the general issues are
identified through the use of this protocol, the auditor should perform a more detailed investigation to determine
the specific area of noncompliance to be corrected. The auditor should review federal, state and local
environmental requirements and annotate the protocol, as required, to include other applicable requirements not
included in the protocol.
The auditor also should determine which regulatory agency has authority for implementing an environmental
program so that the proper set of regulations is consulted. State programs that implement federally mandated
programs may contain more stringent requirements. This protocol should not be used as a substitute for the
applicable regulations.
The collective set of the audit protocols developed by EPA is designed to support a wide range of environmental
auditing needs; therefore several of the protocols in this set or sections of an individual protocol may not be
applicable to a particular facility. Each protocol is not intended to be an exhaustive set of procedures; rather it is
meant to inform the auditor, about the degree and quality of evaluation essential to a thorough environmental
audit. EPA is aware that other audit approaches may provide an effective means of identifying and assessing
facility environmental status and in developing corrective actions.
Each protocol contains the following information:
• List of acronyms and abbreviations used in the document,
• Applicability - provides guidance on the major activities and operations included in the protocol and a brief
description of how the protocol is applied,
• Review of federal legislation - identifies key issues associated with the subject protocol area,
• State and local regulations - identifies typical issues normally addressed in state and local regulations but
does not present individual state/local requirements,
• Key compliance requirements - summarizes the overall thrust of the regulations for that particular protocol,
• Key compliance definitions - defines important terms,
• Typical records to review - highlights documents, permits and other pertinent paperwork that should be
reviewed by an auditor and reconciled against regulatory requirements,
• Typical physical features to inspect - highlights pollution control equipment, manufacturing and process
equipment and other areas that should be visited and evaluated during an audit,
• Index for checklist users - outlines different areas of the checklist that may pertain to the facility being
audited,
• Checklist - matches the regulatory requirements with the tasks that should be accomplished by the auditor,
and
• Appendices - supporting information for the checklist (e.g., regulatory deadlines, lists of contaminants,
wastes, and required testing procedures). Note: information contained in the appendices is dated and should
be verified with a current version of the applicable federal regulations.
The checklist delineates what should be evaluated during an audit. The left column states either a requirement
mandated by regulation or a good management practice that exceeds the requirements of the federal regulations.
Good management practices are distinguished from regulatory requirements in the checklist by the acronym (MP)
and are printed in italics. The regulatory citation is given in parentheses after the requirement. The right column
gives instructions to help conduct the evaluation. These instructions are performance objectives that should be
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. v
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
accomplished by the auditor. Some of the performance objectives may be simple documentation checks that take
only a few minutes; others may require a time-intensive physical inspection of a facility.
EPA is presently is the process of developing a series of audit protocol application guides to serve as companion
documents to the set of protocols. The application guides will provide the auditor with a matrix that identifies
and cross-references certain site-specific activities or unit operations with particular environmental aspects of
that activity. For example, managing hazardous waste containers is a site-specific activity with environmental
concerns, such as possible releases to air, and water, that may require additional review through auditing. By
using the application guide the user can identify facility specific practices that require more in-depth review. In
addition, the application guides will also direct the user to specific protocols and sections (e.g., checklist items)
of the protocol to determine areas that are regulated and require auditing.
List of Acronyms and Abbreviations
Btu British thermal unit
CAA Clean Air Act
CAMU Corrective action management unit
CCW Constituent concentrations in wastes
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act (or Superfund)
CESQG Conditionally exempt small quantity generator
CFR Code of Federal Regulations
cm Centimeter
CO Carbon monoxide
CQA Construction quality assurance
CWA Clean Water Act
DOT Department of Transportation
DRE Destruction and removal efficiency
dscm Dry standard cubic meter
EPA Environmental Protection Agency
FR Federal Register
ft. Feet/Foot
g Gram
gal. Gallon
h Hour
ha Hectare
HC1 Hydrogen chloride
HOC Halogenated organic compound
hr. Hour
HSWA Hazardous and Solid Waste Amendments
in. Inch
kg Kilogram
km Kilometer
L Liter
Ib. Pound
LQG Large quantity generator
m Meter
meq Milliequivalent
mg Milligram
Mg Megagram
mi. Mile
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
VI
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
MJ Megajoule
mm Millimeter
MP Management practice
NOV Notice of violation
NRC National Response Center
OB/OD Open burning/open detonation
PCB Polychlorinated biphenyls
PL Public Law
POHC Principal organic hazardous constituent
POTW Publicly owned treatment works
ppm Parts per million
ppmv Parts per million by volume
ppmw Parts per million by weight
RCRA Resource Conservation and Recovery Act
scf Standard cubic foot
scm Standard cubic meter
SDWA Safe Drinking Water Act
SPCC Spill prevention, control, and countermeasure
SQG Small quantity generator
TOC Total organic carbon
TSD Treatment, storage, and disposal
TSDF Treatment, storage, and disposal facility
TSS Total suspended solids
TU Temporary unit
UIC Underground injection control
U.S. United States
USC United States Code
UST Underground storage tank
VO Volatile organic
VOC Volatile organic compound
yr. Year
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
VII
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
THIS PAGE INTENTIONALLY LEFT BLANK
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. viii
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Section II
Audit Protocol
Applicability
This protocol applies to facilities that store, treat, or dispose of hazardous waste. Not all checklist items will be
applicable to a particular facility. Guidance is provided on the checklists to direct the auditor to the regulations
concerning the type of hazardous waste activities/facilities on the site.
There are numerous environmental regulatory requirements administered by federal, state and local governments.
Each level of government may have a major impact on areas at the facility that are subject to the audit.
Therefore, auditors are advised to review federal, state and local regulations in order to perform a comprehensive
audit.
Review of Federal Legislation
Resource Conservation and Recovery Act, Subtitle C (1976)
The Resource, Conservation and Recovery Act (RCRA) of 1976, which amended the Solid Waste Disposal Act
of 1965, addresses hazardous (Subtitle C) and solid (Subtitle D) waste management activities. Subtitle C of
RCRA, 42 U.S. Code (USC) sections 6921-6939b, establishes standards and procedures forthe handling, storage,
treatment, and disposal of hazardous waste. For example, RCRA prohibits the placement of bulk or
noncontainerized liquid hazardous waste or free liquids containing hazardous waste into a landfill. It also
prohibits the "land disposal" of specified wastes and disposal of hazardous waste through underground injection
within 1/4 mile (0.40 km) of an underground source of drinking water. Pursuant to Subtitle C of RCRA, the
Environmental Protection Agency (EPA) promulgated regulations at 40 CFR Parts 260-299, establishing a
"cradle-to-grave" system that governs hazardous waste from the point of generation to its treatment or disposal.
RCRA also governs the management of used oil. Regulations promulgated under RCRA (40 CFR 279) establish
management standards for used oil generators, collection center aggregation points, transporters, transporter
facilities, used oil processors, rerefmeries, used oil burners who burn off-specification used oil for energy
recovery, used oil fuel marketers, and for use and disposal of oil used as a dust suppressant.
The 1984 Hazardous and Solid Wastes Amendments (HSWA) greatly expanded the requirements and coverage
of RCRA. A significant provision of HSWA is the prohibition on the land disposal of hazardous waste. The land
disposal restrictions (LDRs) promulgated by EPA essentially ban the disposal of untreated liquid hazardous
waste or hazardous waste containing free liquids in landfills and establish treatment standards for these wastes. In
addition to the new statutory and regulatory requirements imposed by HSWA, a new subtitle to the act was
created to govern underground storage tanks (USTs). This document does not provide audit guidance for
underground or above ground storage tanks regulated under RCRA. Audit guidance and technical
information on above and underground storage tanks is provided by EPA in a separate protocol titled Protocol for
Conducting Environmental Compliance Audits of Underground and Above Ground Storage Tanks and is
expected to be available in 1999.
After assessing air emissions at TSDFs, the EPA ascertained that volatile organic chemicals (VOCs) adversely
affect human health and the environment. In response, EPA promulgated three subparts of RCRA rules designed
to control VOCs. In 1990, EPA issued Subparts AA and BB, which amended 40 CFR Parts 264 and 265. Subpart
AA governs organic chemical emissions from certain hazardous waste treatment processes, while Subpart BB
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
governs equipment that contains or contacts hazardous waste with at least 10% organic chemicals by weight.
Subpart CC includes requirements for controlling VOC emissions from tanks, surface impoundments, containers,
and certain miscellaneous "Subpart X" units. The Subpart CC Final Rule was signed on December 6, 1994, and
the Final Rule Amendments were signed on October 4, 1996.
State and Local Regulations
RCRA encourages states to develop their own parallel regulatory programs for hazardous waste management.
This includes the enacting of statutory authority and operating hazardous waste regulatory programs. Many states
have met the requirements established by EPA in 40 CFR271 (Requirements for Authorization of state
Hazardous Waste Programs) and have been approved to manage their own state programs. Many states have
adopted the EPA regulations by reference or have promulgated regulations that are identical to the EPA
regulations, while other states have promulgated regulations stricter than the federal RCRA. These differences
between individual state regulations and the federal program require that auditors check the status of their state's
authorization and then determine which regulations apply. For example, some states have listed additional waste
as hazardous waste (used oil, PCBs, asbestos). Since the section checklists are based exclusively on the
requirements of the federal RCRA program, the auditor should determine in what ways the applicable state
program differs from the federal program and tailor this checklist accordingly.
Key Compliance Requirements
Financial Responsibility
Owners/operators of hazardous and solid waste landfills have financial assurance responsibilities as defined in
Subpart H of 40 CFR Parts 258, 264, and 265. A written estimate of costs for closure, post-closure care, liability
and sudden and non-sudden occurrences is required. These estimates are to be updated annually; some states may
require a more frequent update.
Permitted TSDF Requirements
The operation of a TSDF is subject to regulation and permitting under federal and state regulations. These
regulations are both administrative as well as technical in nature. The administrative standards require that
various plans be developed to ensure that emergencies can be dealt with, waste received is properly identified,
and operating personnel are adequately trained to operate the TSDF and respond to emergencies. These
administrative standards also include requirements that the TSDF be inspected routinely, records of operations be
compiled and maintained, and reports of both routine and contingency operations be made to the applicable
regulatory agency. The administrative standards also require that a plan for ceasing operations and closing the
TSDF be developed, kept on-hand, and updated frequently.
The technical standards which are applicable to TSDFs fall into two classes: general standards which apply to all
TSDFs, and specific standards which apply to various types of facilities (e.g., container storage areas, tanks,
containment buildings, surface impoundments, waste piles, land treatment facilities, incinerators, landfills,
thermal treatment facilities, and chemical, physical, biological treatment facilities).
Administrative and technical standards are applied to a particular facility through a RCRA permit issued to a
facility. New TSDFs requiring a permit must submit a two part permit application. Part A is a short, standard
form that collects general information about the facility, while Part B of the application is much more extensive
and requires the facility to supply detailed and highly technical information. This submission must be made at
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
least 180 days prior to the date on which physical construction is expected to start. Once issued, RCRA permits
are valid up to 10 years.
TSDFs fall into two categories: interim status facilities and permitted facilities. Interim status regulations (40
CFR Part 265) apply to facilities that are eligible to operate under a Part A permit while their Part B permit
application is being reviewed. Any facility that is in existence on the effective date of the statutory or regulatory
amendments that render the facility subject to permitting requirements is eligible for interim status, provided that
the facility notifies EPA of hazardous waste activity and complies with application requirements under 40 CFR
Part 270.10. Interim status standards are "good housekeeping" types of requirements that must be addressed until
a permit is issued. TSDF permit standards (40 CFR Part 264) are facility-specific requirements that are
incorporated into a TSDF permit.
TSDF Requirements - Subpart CC
Subpart CC applies to tanks, surface impoundments, containers, and certain miscellaneous units that:
• are not expressly exempted from the rule;
• are subject to permit standards (40 CFR 264), interim status standards (40 CFR 265), or less-than 90-day
LQG standards (40 CFR 262.34 (a)(l)(i) or (ii) for tanks and containers); and
• manage hazardous waste that have an average volatile organic concentration at the point of waste origination
equal to or greater than 500 parts per million by weight (ppmw).
Transport Requirements
Containers of hazardous waste shipped offsite must be labeled to identify the waste and its hazard class.
Shipments from the facility to an off-site TSDF must also be accompanied by manifests and are subject to the full
transportation requirements as stipulated in Department of Transportation (DOT) hazardous materials
transportation regulations.
For further information regarding the RCRA regulations, contact U.S. EPA's RCRA/UST, Superfund and
EPCRA Hotline at 800-424-9346 (or 703-412-9810 in the D.C. area) from 9 a.m. to 6 p.m., Monday through
Friday.
This EPA hotline provides up-to-date information on regulations developed under RCRA, CERCLA
(Superfund), and the Oil Pollution Act. The hotline can assist with Section 112(r) of the Clean Air Act (CAA)
and Spill Prevention, Control and Countermeasures (SPCC) regulations. The hotline also responds to
requests for relevant documents and can direct the caller to additional tools that provide a more detailed
discussion of specific regulatory requirements.
Key Terms and Definitions
Acknowledgement of Consent
The cable sent to the EPA from the U.S. Embassy in a receiving country that acknowledges the written consent of the
receiving country to accept the hazardous waste and describes the terms and conditions of the receiving country's
consent to the shipment (40 CFR 262.51).
Active Life
The period from the initial receipt of hazardous waste at the facility until the regulatory agency receives
certification of final closure (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Active Portion
That portion of a facility where treatment, storage, or disposal operations are being or have been conducted and
which is not a closed portion (40 CFR 260.10).
Acute Hazardous Waste
Any waste listed under 40 CFR 261.31 through 261.33(c) with a hazard code of H. These include EPA hazardous
waste numbers: F020, F021, F022, F023, F026, and F027 (40 CFR 261.31) and the P listed wastes in 40 CFR
261.33(e).
Aquifer
A geologic formation, group of formations, or part of a formation capable of yielding a significant amount of
groundwater to wells or springs (40 CFR 260.10).
Average Volatile Organic (VO) Concentration
The mass-weighted average VO concentration of a hazardous waste (40 CFR 265.1081).
Boiler
An enclosed device using controlled flame combustion and having the following characteristics (40 CFR 260.10):
• The unit has physical provisions for recovering and exporting thermal energy in the form of steam, heated
fluids, or heated gases;
• The unit's combustion chamber and primary energy recovery section(s) must be of integral design;
• While in operation the unit maintains a thermal energy recovery efficiency of at least 60 percent;
• The unit has been approved by the EPA's Administrator; and
• The unit must export and utilize 75% of the recovered energy.
Certification
A statement of professional opinion based upon knowledge and belief (40 CFR 260.10).
Characteristics of Hazardous Waste
The characteristics of ignitability, corrosivity, reactivity, and toxicity, which identify a waste as hazardous waste
(40 CFR 261.20 through 261.24).
Closed Portion
The portion of a facility that has been closed in accordance with the approved closure plan and all applicable
closure requirements (40 CFR 260.10).
Competent Authorities
The regulatory authorities of concerned countries having jurisdiction over transfrontier movements of wastes destined
for recovery operations (40 CFR 262.81).
Consignee
The ultimate treatment, storage, or disposal facility in a receiving country to which the hazardous waste will be sent (40
CFR 262.51).
Container
Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled (40
CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Containment Building
A hazardous waste management unit that is used to store or treat hazardous waste under 40 CFR 264.1100
through 264.1103 and 40 CFR 265.1100 through 265.1103 (40 CFR 260.10).
Contingency Plan
A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire,
explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or
the environment (40 CFR 260.10).
Corrective Action Management Unit (CAMU)
An area within a facility that is designated by the regulatory agency under 40 CFR 264 Subpart S, for the purpose
of implementing corrective action requirements under 264.101 and RCRA section 3008(h). A CAMU shall only
be used for the management of remediation wastes pursuant to implementing such corrective action requirements
at the facility (40 CFR 260.10).
Cover
A device that provides a continuous barrier over the hazardous waste managed in a unit to prevent or reduce air
pollutant emissions to the atmosphere. A cover may have openings (such as access hatches, sampling ports, gauge
wells) that are necessary for operation, inspection, maintenance, and repair of the unit on which the cover is used. A
cover may be a separate piece of equipment which can be detached and removed form the unit or a cover may be
formed by structural features permanently integrated into the design of the unit (40 CFR 265.1081).
Debris
Solid material exceeding a 60 mm particle size that is intended for disposal and that is a manufactured object,
plant or animal matter, or natural geologic material. The following materials are not debris: any material for
which a specific treatment standard is provided; process residuals such as smelter slag and residues from the
treatment of waste, wastewater, sludges, or air emissions residues; and intact containers of hazardous waste that
are not ruptured and retain at least 75 percent of their original volume (40 CFR 268.2).
Designated Facility
A hazardous waste TSDF that is identified on a manifest as the destination of a hazardous waste shipment. The
facility must have an appropriate permit, interim status, or be regulated under specific recycling requirements (40
CFR 260.10).
Detonation
An explosion in which chemical transformation passes through the material faster than the speed of sound (0.33
km/s at sea level) (40 CFR 265.382).
Dike
An embankment or ridge of either natural or man-made materials used to prevent the movement of liquids,
sludges, solids, or other materials (40 CFR 260.10).
Discharge or Hazardous Waste Discharge
The accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous
waste into or on any land or water (40 CFR 260.10).
Disposal
The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste
into or on any land or water so that such solid waste or hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into any waters, including groundwaters (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 5
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Do-it-Yourselfer Used Oil Collection Center
Any site or facility that accepts/aggregates and stores used oil collected only from household do-it-yourselfers.
Elementary Neutralization Unit
A device used for neutralizing only those hazardous wastes that exhibit corrosivity (as defined in 40 CFR 261.22)
or are listed in Subpart D of 40 CFR 261 only because of corrosivity and that meets the definition of tank, tank
system container, transport vehicle, or vessel in 40 CFR 261.10 (40 CFR 260.10).
Enclosure
A structure that surrounds a tank or container, captures organic vapors emitted from the tank or container, and vents the
captured vapors through a closed-vent system to a control device (40 CFR 265.1081).
EPA Hazardous Waste Number
The number assigned by EPA to each hazardous waste listed in Part 261, Subpart D and to each characteristic
identified in Part 261, Subpart C (40 CFR 260.10).
EPA Identification Number
The number assigned by EPA to each generator, transporter, and treatment, storage, or disposal facility (40 CFR
260.10).
Existing Hazardous Waste Management Facility or Existing Facility
A facility which was in operation or for which construction commenced on or before November 19, 1980 (40
CFR 260.10).
Existing Portion
The land surface area of an existing waste management unit, included in the original Part A permit application,
on which wastes have been placed prior to the issuance of a permit (40 CFR 260.10).
External Floating Roof
A pontoon or double-deck type floating roof that rests on the surface of a hazardous waste being managed in a tank that
has no fixed roof (40 CFR 265.1081).
Facility
All contiguous land and structures, other appurtenances, and improvements on the land, used for treating, storing,
or disposing of hazardous waste. A facility may consist of several treatment, storage, or disposal operational units
(e.g., one or more landfills, surface impoundments, or combination of them) (40 CFR 260.10).
Final Closure
The closure of all hazardous waste management units at the facility in accordance with all applicable closure
requirements so that hazardous waste management activities under 40 CFR Parts 264 and 265 are no longer
conducted at the facility unless subject to the provisions of §262.34 (40 CFR 260.10).
Fixed Roof
A cover that is mounted on a unit in a stationary position and does not move with fluctuations in the level of material
managed in the unit (40 CFR 265.1081).
Floating Membrane Cover
A cover consisting of a synthetic flexible membrane material that rests upon and is supported by the hazardous waste
being managed in a surface impoundment (40 CFR 265.1081).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 6
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Floating Roof
A cover consisting of a double deck, pontoon single deck, or internal floating cover which rests upon and is supported
by the material being contained, and is equipped with a continuous seal (40 CFR 265.1081).
Food-Chain Crops
Tobacco, crops grown for human consumption, and crops grown for feed for animals whose products are
consumed by humans (40 CFR 260.10).
Free Liquids
Liquids which readily separate from the solid portion of a waste under ambient temperature and pressure (40
CFR 260.10).
Groundwater
Water below the land surface in a zone of saturation (40 CFR 260.10).
Halogenated Organic Compounds (HOC)
Those compounds having a carbon-halogen bond which are listed in Appendix A (40 CFR 268.2).
Hazardous Debris
Debris that contains a hazardous waste or that exhibits a characteristic of hazardous waste (40 CFR 268.2).
Hazardous Waste
A solid waste identified as a characteristic or listed hazardous waste in 40 CFR 261.3 (40 CFR 260.10).
Hazardous Waste Constituent
A constituent that caused the hazardous waste to be listed in 40 CFR Part 261, Subpart D (lists of hazardous
wastes from non-specific and specific sources, and listed hazardous wastes), or a constituent listed in the table of
maximum concentrations of contaminants for the toxicity characteristic) (40 CFR 260.10).
Hazardous Waste Management Unit
A contiguous area of land on or in which hazardous waste is placed, or the largest area in which there is
significant likelihood of mixing hazardous waste constituents in the same area. Examples include a surface
impoundment, a waste pile, a treatment area, a landfill cell, an incinerator, a tank and its associated piping and
underlying containment system, and a container storage area. A container alone does not constitute a unit; the
unit includes containers and the land or pad upon which they are placed (40 CFR 260.10).
In Light Liquid Service
The piece of equipment contains or contacts a waste stream where the vapor pressure of one or more of the organic
components in the stream is greater than 0.3 kPa at 20°C, the total concentration of the pure organic components
having a vapor pressure greater than 0.3 kPa at 20°C is equal to or greater than 20 percent by weight, and the fluid is a
liquid at operating conditions (40 CFR 264.1031).
In Light Material Service
The container is used to manage a material for which both of the following conditions apply:
• The vapor pressure of one or more of the organic constituents in the material is greater than 0.3 kPa at 20°C
• The total concentration of the pure organic constituents having a vapor pressure greater than 0.3 kPa at 20°C is
equal to or greater than 20 percent by weight (40 CFR 265.1081).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Incinerator
An enclosed device using controlled flame combustion that neither meets the criteria for classification as a boiler
nor is listed as an industrial furnace (40 CFR 260.10).
Incompatible Waste
A hazardous waste that is unsuitable for:
• Placement in a particular device or facility because it may cause corrosion or decay of containment materials
(e.g., container liners or tank walls); or
• Commingling with another waste or material under uncontrolled conditions because the commingling
conditions produce heat or pressure; fire or explosion; violent reaction; toxic dusts, mist, fumes, or gases; or
flammable fumes or gases (40 CFR 260.10).
Industrial Furnace
Any of the following enclosed devices that are integral components of manufacturing processes and that use controlled
flame devices to accomplish recovery of materials or energy: cement kilns, lime kilns, aggregate kilns, phosphate kilns,
coke ovens, blast furnaces, smelting, melting and refining furnaces, titanium dioxide chloride process oxidation
reactors, methane reforming furnaces, pulping liquor recovery furnaces, combustion devices used in the recovery of
sulfur values from spent sulfuric acid, halogen acid furnaces, and other devices designated by the administrator (40
CFR 260.10).
Injection Wells
A well into which fluids are injected (40 CFR 260.10).
Inner Liner
A continuous layer of material placed inside a tank or container which protects the construction materials of the
tank or container from the contained waste or reagents used to treat the waste (40 CFR 260.10).
International Shipment
The transportation of hazardous waste into or out of the jurisdiction of the United States (40 CFR 260.10).
Land Disposal
Includes, but is not limited to, any placement of hazardous waste in a landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome formation, underground mine or cave, or placement in a concrete
vault or bunker intended for disposal purposes (40 CFR 268.2).
Land Treatment Facility
A facility or part of a facility at which hazardous waste is applied onto or incorporated into the soil surface; such
facilities are disposal facilities if the waste will remain after closure (40 CFR 260.10).
Landfill
A disposal facility or part of a facility where hazardous waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an underground injection well, a salt bed formation, an underground
mine, or a cave (40 CFR 260.10).
Landfill Cell
A discrete volume of a hazardous waste landfill which uses a liner to provide isolation of wastes from adjacent
cells or wastes. Examples include trenches and pits (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Leachate
Any liquid, including any suspended components in the liquid, that has percolated through or drained from
hazardous waste (40 CFR 260.10).
Leak Detection System
A system capable of detecting the failure of either the primary or secondary containment structure or the presence
of a release of hazardous waste or accumulated liquid in the secondary structure. Such a system must employ
operational controls (e.g., daily visible containment for releases into the secondary containment system of
aboveground tanks) or consist of an interstitial monitoring device designed to detect continuously and
automatically the failure of the primary or secondary containment structure or the presence of a release of
hazardous waste into the secondary containment structure (40 CFR 260.10).
Liner
A continuous layer of natural or man-made materials, beneath or on the sides of a surface impoundment, landfill,
or landfill cell, which restricts the downward or lateral escape of hazardous waste, hazardous waste constituents,
or leachate (40 CFR 260.10).
Malfunction
Any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment,
or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless
operations are not malfunctions (40 CFR 265.1081).
Management or Hazardous Waste Management
The systematic control of the collection, source separation, storage, transportation, processing, treatment,
recovery, and disposal of hazardous waste (40 CFR 260.10).
Management Practice (MP)
Practices which, although not mandated by law, are encouraged to promote safe operating procedures.
Manifest
The shipping document originated and signed by the generator containing the information required by 40 CFR
262, Subpart B (40 CFR 260.10).
Manifest Document Number
The EPA 12-digit number assigned to the generator plus a unique 5 digit number assigned to the manifest by the
generator for recording and reporting purposes (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Miscellaneous Unit
A hazardous waste management unit where hazardous waste is treated, stored, or disposed of and that is not a
container, tank, surface impoundment, pile, land treatment unit, landfill, incinerator, boiler, industrial furnace,
underground injection well with appropriate technical standards under 40 CFR 146, containment building, or unit
eligible for a research development and demonstration permit under 40 CFR 270.65 (40 CFR 260.10
Movement
Hazardous waste transported to a facility in an individual vehicle (40 CFR 260.10).
New Hazardous Waste Management Facility
A facility which began operation, or for which construction commenced after October 21, 1976 (40 CFR 260.10).
No Detectable Emissions
No escape of organics to the atmosphere as determined by using the procedures specified in 40 CFR 265.1084(d) (40
CFR 265.1081).
Nonwastewaters
Wastes that do not meet the criteria for wastewaters (40 CFR 268.2) (see definition of wastewaters).
Notifier
The person under jurisdiction of the exporting country who has, or will have at the time the planned transfrontier
movement commences, possession or other forms of legal control of the wastes and who proposes their transfrontier
movement for the ultimate purpose of submitting them to recovery operations. When the United States is the exporting
country, notifier is interpreted to mean a person domiciled in the U.S. (40 CFR 262.81).
OECD Country
Designated member countries of the Organization for Economic Cooperation and Development (OECD) consisting of
Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Japan, Luxembourg,
Netherlands, New Zealand, Norway, Portugal, Spain, Sweden, Switzerland, Turkey, United Kingdom, and the United
States. Canada and Mexico are considered OECD member countries under the RCRA regulations only for the purpose
of transit (40 CFR 262.58).
On site
On the same or geographically continuous property which may be divided by a public right-of-way, provided the
entrance and exit between the properties is at a cross-roads intersection and access is by crossing as opposed to
going along the right-of-way (40 CFR 260.10).
Open Burning
Combustion of any material without the following characteristics (40 CFR 260.10):
• Control of combustion air to maintain adequate temperature for efficient combustion,
• Containment of the combustion-reaction in an enclosed device to provide sufficient residence time and
mixing for complete combustion,
• Control of emission of the gaseous combustion products.
Partial Closure
The closure of a hazardous waste management unit in accordance with the applicable closure requirements of 40
CFR 264 and 265 at a facility that contains other active hazardous waste management units. For example, partial
closure may include the closure of a tank (including its associated piping and underlying containment systems)
while other units of the same facility continue to operate (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 10
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Pile
Any non-containerized accumulation of solid, nonflowing hazardous waste that is used for treatment or storage
that is not a containment building (40 CFR 260.10).
Point of Waste Treatment
The point where a hazardous waste exits a waste management unit used to destroy, degrade, or remove organics in the
hazardous waste (40 CFR 265.1081).
Point Source
Any discernible, confined, and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel,
conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, or vessel or
floating craft, from which pollutants are or may be discharged. This term does not include return flows from
irrigated agriculture (40 CFR 260.10).
Pollution Prevention
The term includes equipment or technology modifications; process or procedure modifications; reformulation or
redesign of products; substitution of raw materials; and improvements in housekeeping, maintenance, training or
inventory control as defined in the Pollution Prevention Act.
Primary Exporter
Any person who is required to originate the manifest for a shipment of hazardous waste in accordance with 40 CFR
262, Subpart B or an equivalent state provision, that specifies a treatment, storage, or disposal facility in a receiving
country as the facility to which the hazardous waste will be sent and any intermediate arranging for the export (40 CFR
262.51).
Prohibited Wastes
A subset of restricted wastes (under the land disposal restriction (LDR) regulations) that have established treatment
standards, are not subject to variances or waiver, and do not meet the respective treatment standard.
Publicly Owned Treatment Works (POTW)
Any device or system used in the treatment (including recycling and reclamation) of municipal sewage or
industrial wastes of a liquid nature which is owned by a state or municipality (as defined by section 502(4) of the
CWA). This definition includes sewers, pipes, or other conveyances only if they convey wastewater to a POTW
providing treatment (40 CFR 260.10).
Pump Operating Level
A liquid level proposed by the owner or operator and approved by the regulatory agency based on pump
activation level, sump dimensions, and level that avoids backup into the drainage layer and minimizes head in the
sump (40 CFR264.226(d)(3)).
Qualified Groundwater Scientist
A scientist or engineer who has received a baccalaureate or postgraduate degree in the natural sciences or
engineering and has sufficient training and experience in groundwater hydrology and related fields as may be
demonstrated by state registration, professional certification, or completion of accredited university courses that
enable that individual to make sound professional judgments regarding groundwater monitoring and contaminant
fate and transport (40 CFR 260.10).
RCRA Permit Programs
RCRA regulations under 40 CFR 258.50-258.58 outline the requirements of a groundwater monitoring and
corrective action program. RCRA regulations under 40 CFR 264 and 265 require that any facility that treats,
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 11
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
stores or disposes of hazardous waste must apply to the state for an operating permit. If the state has not yet
given final approval or denial of the permit application, then the facility is considered an "interim status" facility,
and the temporary permit issued by the state is called a "Part A permit." If a final permit, called a "Part B
permit" has been issued, then the facility is considered a Treatment, Storage, and Disposal Facility (TSDF). The
facility RCRA permit, whether it is Part A or B, will have requirements in it for groundwater monitoring and
those requirements tend to differ from state to state.
In the federal regulations, there are basic requirements for both interim status facilities and TSDFs including the
development and maintenance of a groundwater monitoring program. The programs generally have different
levels of requirements depending on the potential level of groundwater contamination at the facility, and
proximity to sensitive receptors.
Receiving Country
A foreign country to which a hazardous waste is sent for the purpose of treatment, storage, or disposal (except short-
term storage incidental to transportation) (40 CFR 262.51).
Regional Administrator
The Regional Administrator for the EPA Region in which the facility is located, or his designee.
Replacement Unit
A landfill, surface impoundment or waste pile unit (40 CFR 260.10) from which all or substantially all of the
waste is removed, and that is subsequently reused to treat, store, or dispose of hazardous waste. This does not
apply to a unit from which waste is removed during closure, if the subsequent reuse solely involves the disposal
of waste from that unit and other closing units or corrective action areas at the facility, in accordance with an
approved closure plan or EPA or state approved corrective action.
Representative Sample
A sample of a universe or whole (e.g., waste pile, lagoon, groundwater) which can be expected to exhibit the
average properties of the universe or whole (40 CFR 260.10).
Re-Refining Distillation Bottoms
The heavy fraction produced by vacuum distillation of filtered and dehydrated used oil. The composition of still
bottoms varies with column operation and feedstock.
Restricted Wastes
The RCRA hazardous wastes that are subject to the LDR program. A waste is restricted if EPA has established a
treatment standard for it, or if it has been specifically designated by Congress as ineligible for land disposal.
Runoff
Any rainwater, leachate, or other liquid that drains from any part of a facility (40 CFR 260.10).
Run-on
Any rainwater, leachate, or other liquid that drains onto any part of a facility (40 CFR 260.10).
Sludge
Any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater
treatment plant, water supply treatment plant, or air pollution control facility exclusive of the treated effluent
from a wastewater treatment plant (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 12
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Storage
The holding of hazardous wastes for a temporary period, at the end of which the hazardous wastes are treated,
disposed of, or stored elsewhere (40 CFR 260.10).
Sump
Any pit or reservoir that meets the definition of tank and those troughs/trenches connected to it that serve to
collect hazardous waste for transport to hazardous waste TSDFs. Except that as used in the landfill, surface
impoundment, and waste pile rules, "sump" means any lined pit or reservoir that serves to collect liquids drained
from a leachate collection and removal system or leak detection system for subsequent removal from the system
(40 CFR 260.10).
Surface Impoundment
A facility or part of a facility that is a natural topographic depression, manmade excavation, or diked area formed
primarily of earthen materials designed to hold an accumulation of liquid wastes or wastes containing free liquids
and which is not an injection well (40 CFR 260.10).
Thermal Treatment
The treatment of hazardous waste in a device that uses elevated temperature as the primary means to change the
chemical, physical, or biological character or composition of the hazardous waste (40 CFR 260.10).
Totally Enclosed Treatment Facility
A facility for the treatment of hazardous waste which is directly connected to an industrial production process and
which is constructed and operated in a manner which prevents the release of any hazardous waste or any constituent
thereof into the environment during treatment. An example is a pipe in which waste acid is neutralized (40 CFR
260.10).
Transfer Facility
Any transportation-related facility including loading docks, parking areas, storage areas and other similar areas
where shipments of hazardous wastes are kept during the normal course of transportation (40 CFR 260.10).
Transfrontier Movement
Any shipment of hazardous wastes destined for recovery operations from an area under the national jurisdiction of one
OECD member country to an area under the national jurisdiction of another OECD country (40 CFR 262.81).
Transit Country
Any foreign country, other than a receiving country, through which a hazardous waste is transported (40 CFR 260.10).
Transport Vehicle
A motor vehicle or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer,
railroad freight car, etc.) is a separate transport vehicle (40 CFR 260.10).
Transporter
A person engaged in the offsite transportation of hazardous wastes by air, rail, highway, or water (40 CFR
260.10).
Treatability Study
A study in which a hazardous waste is subjected to a treatment process to determine (40 CFR 260.10):
• Whether the waste is amenable to the treatment process,
• What pretreatment (if any) is required,
• The optimal process conditions needed to achieve the desired treatment,
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 13
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
• The efficiency of a treatment process for a specific waste or wastes, or
• The characteristics and volumes of residuals from a particular treatment process.
Also included in this definition for the purpose of the 40 CFR261.4(e) and (f) exemptions are liner compatibility,
corrosion, and other material compatibility studies and toxicological and health effects studies. A treatability
study is not a means to commercially treat or dispose of hazardous waste.
Treatment
Any method, technique, or process, including neutralization, designed to change the physical, chemical or
biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover
energy or material resources from the waste, or so as to render such waste nonhazardous, or less hazardous; safer
to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume (40 CFR
260.10).
Treatment Zone
A soil area of the unsaturated zone of a land treatment unit within which hazardous constituents are degraded,
transformed, or immobilized (40 CFR 260.10).
Underground Injection
The subsurface emplacement of fluids through a bored, drilled or driven well; or through a dug well, where the
depth of the dug well is greater than the largest surface dimension (40 CFR 260.10).
Unsaturated Zone or Zone of Aeration
The zone between the land surface and the water table (40 CFR 260.10).
United States
The 50 states, the District of Columbia, the Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam,
American Samoa, and the Commonwealth of the Northern Mariana Islands (40 CFR 260.10).
Uppermost Aquifer
The geologic formation nearest the natural ground surface that is an aquifer, as well as lower aquifers that are
hydraulically interconnected with this aquifer within the facility's property boundary (40 CFR 260.10).
Volatile Organic Concentration
The fraction by weight of the volatile organic compounds in a hazardous waste expressed in terms of ppmw as
determined by direct measurement or by knowledge of the waste (40 CFR 265.1081).
Waste Stabilization Process
Any physical or chemical process used to either reduce the mobility of hazardous constituents in a hazardous waste or
eliminate free liquids (40 CFR 265.1081).
Wastewater Treatment Unit
A device that (1) is part of a wastewater treatment facility subject to regulation under section 402 or 307(b) of the
CWA; and (2) receives and treats or stores an influent wastewater that is a hazardous waste (as defined in 40
CFR 261.3), or that generates and accumulates a wastewater treatment sludge that is a hazardous waste, or treats
or stores a wastewater treatment sludge; and (3) meets the definition of tank or tank system (40 CFR 260.10).
Wastewaters
Wastes that contain less than one percent by weight total organic compounds and total suspended solids (40 CFR
268.2).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 14
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Zone of Engineering Control
An area under the control of the owner/operator that upon detection of a hazardous waste release, can be readily
cleaned up before the release of hazardous waste or hazardous constituents to groundwater or surface water (40
CFR260.10).
Typical Records to Review
• Hazardous substance spill control and contingency plan;
• Land disposal restriction certifications;
• Emergency plan documents;
• Placarding of hazardous waste and hazardous materials;
• Location map of TSDF;
• Employee training documentation;
• Spill records;
• Permits, if issued, otherwise Part A Application;
• Unmanifested waste reports;
• TSDF audit reports (inspection log);
• Waste analysis plan(s);
• Operating record;
• Groundwater monitoring records and annual reports (where required);
• Biennial reports, closure/post-closure plans, closure/post-closure notices (where applicable); and
• Other documents as required by the permit
If the TSDF is also a generator, refer to the protocol for hazardous waste generators for applicable requirements.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 15
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Typical Physical Features to Inspect
• Disposal sites;
• Incinerators;
• Vehicles used for transport;
• Container storage areas and containment buildings;
• Surface impoundments;
• Marshaling facilities;
• Fuel burners;
• Site security measures (e.g., door locks, fencing, etc.);
• Posted signs;
• Communication equipment; and
• Bulk storage tank areas.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 16
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Index for Checklist Users
All Facilities
Transportation of Hazardous Waste
All Treatment, Storage
and Disposal Facilities (TSDFs)
• General
• Personnel Training
• Containers
• Container Storage Areas
• Containment Buildings
• Restricted Wastes
• Emissions from Process Vents
• Air Emissions Standards for
Equipment Leaks
• Documentation Requirements
• Surface Impoundments
• Waste Piles
• Land Treatment Units
• Hazardous Waste Landfills
• Closure
Additional Requirements for
Permitted TSDFs
• General
• Surface Impoundments
• Waste Piles
• Land Treatment Units
• Hazardous Waste Landfills
• Incinerators
• Miscellaneous Units
Additional Requirements for Interim
Status TSDFs
• General
• Surface Impoundments
• Waste Piles
• Land Treatment Units
• Hazardous Waste Landfills
• Incinerators
• Thermal Treatment
• Chemical/Physical/ Biological
Treatment
Refer To
Checklist Items
DF.1 through DF.4
DF.5 through DF.9
DF. 10 through DF.1 9
DF.20 through DF.21
DF.22 through DF.33
DF.34 through DF.36
DF.37 through DF.43
DF.44 through DF.49
DF.50 through DF.55
DF.56 through DF.65
DF.66 through DF.76
DF.77 through DF.83
DF.84
DF.85
DF.86
DF.87 through DF.91
DF.92 through DF.1 08
DF.1 09 through DF.1 19
DF. 120 through DF. 124
DF. 125 through DF. 131
DF.1 32 through DF.1 35
DF.1 36 through DF.1 39
DF. 140 through DF. 142
DF. 143 through DF. 151
DF.1 52 through DF.1 55
DF.1 56 through DF.1 59
DF. 160 through DF. 163
DF.164
DF. 165 through DF. 169
DF.1 70 through DF.1 72
DF.1 73 through DF.1 75
Page Numbers
19
20-21
21-24
25
26-35
35-36
36-39
39-42
42-48
49-55
55-59
60-69
70
71
71
71-72
72-77
77-80
81-83
83-85
86-87
88-89
90-91
91-93
94-95
96-97
98-99
100
101-102
103
104
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
17
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Refer To
Checklist Items
Page Numbers
Export/Import of Hazardous Waste
• Exports of Hazardous Waste for
Recovery Within the OECD
Member Countries
• Exports of Hazardous Waste
(Except to the OECD Member
Countries) for Recovery
• Imports of Hazardous Waste for
Recovery Within the OECD
Member Countries
• Imports of Hazardous Waste
(Except from the OECD
Member Countries) for
Recovery
DF.176 through DF.182
DF.183 through DF.190
DF.191 through DF.196
DF.197 through DF.198
105-108
109-110
111-112
112
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
18
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Checklist
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice;
Reviewer Checks:
All Facilities
DF.1. The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of Violation
(NOVs), or equivalent state
enforcement actions should be
examined.
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent orders, compliance agreements, NOVs, interagency
agreements or equivalent state enforcement actions.
For those open items, indicate what corrective action is planned and milestones
established to correct problems.
DF.2. Facilities are required to
comply with all applicable
federal regulatory requirements
not contained in this checklist.
Determine if any new regulations have been issued since the finalization of the guide.
If so, annotate checklist to include new standards.
Determine if the facility has activities or facilities which are federally regulated, but not
addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued regulations.
DF.3. Facilities are required to
comply with state and local
regulations concerning
hazardous waste management.
Verify that the facility is abiding by state and local hazardous waste requirements.
Verify that the facility is operating according to permits issued by the state or local
agencies where approved.
(NOTE: Issues typically regulated by state and local agencies include:
- Additional manifesting requirements
- More frequent reporting requirements
- Transportation
- Identification of special waste or waste categories
- Regulation of specific substances as hazardous waste such as: medical,
pathological, and infectious waste; used oil; explosives; used batteries
- Small and very small quantity generator requirements
- RCRA permitting of oil/water separators
- Disposal requirements
- Construction and operation of storage and disposal facilities
- Satellite accumulation point requirements
- Container marking and labeling requirements.)
Verify that the actions detailed in compliance agreements are being taken according to
the schedule established in the agreements.
DF.4. Specific persons should
be designated responsible for
hazardous waste storage areas,
and the precise nature of their
responsibilities should be
specified (MP).
Verify that specific individuals have been designated responsible for hazardous waste
storage areas.
Verify that the individuals designated responsible for hazardous waste storage areas
are aware of the precise nature of their responsibilities.
Verify that required hazardous waste handling training is in personnel file.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
19
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Transportation of Hazardous Waste
DF.5. Transporters of hazardous
waste that is required to be
manifested must have an EPA
identification number and must
comply with manifest
management requirements (40
CFR 263.10(a), 263.10(b),
263.11,263.20(a) through
263.20(d), 263.21 and
263.22(3)).
(NOTE: These requirements do not apply to the onsite transportation of hazardous
waste. Nor do they apply to CESQGs.)
Determine if the facility transports hazardous waste offsite using their own vehicles or
a contractor.
Verify that the transporter has an EPA identification number.
Verify that all waste accepted, transported, or offered for transport is accompanied by
a manifest.
Verify that prior to transport, the transporter signs and dates the manifest and returns a
copy to the generator prior to leaving the facility.
Verify that the transporter retains a copy of the manifest after delivery.
Verify that manifests are kept on file for three years.
(NOTE: Special issues involved in the transportation of hazardous waste by air, rail or
water are not addressed in this guide.)
DF.6. Before transporting
hazardous waste or offering
hazardous waste for
transportation offsite in the
United States, the facility must
package and label the waste in
accordance with DOT
regulations contained in 49 CFR
172, 173, 178, and 179 (40 CFR
262.30 through 262.33).
Determine what pretransport procedures for hazardous waste are used.
Inspect a sample of containers awaiting transport to verify that containers are properly
constructed and contain no leaks, corrosion, or bulges.
Examine end-seams for minor weeping that indicates drum failure.
Verify that labeling and marking on each container is compatible with the manifests.
Verify that the following information is displayed on a random sample of containers of
110 gal. (416.40 L) or less in accordance with 49 CFR 172.304:
- "HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact
the nearest police or public safety authority or the U.S. Environmental Protection
Agency."
- Generator's name and address
- Manifest Document Number .
Verify that proper DOT placarding is available for the transporter.
DF.7. Transporters of waste
offsite must take immediate
notification and clean-up action
if a discharge occurs during
transport (40 CFR 263.30 and
263.31).
Verify that transport operators have instructions to notify local authorities and take
clean-up action so that the discharge does not present a hazard.
Verify that transporters give notice to the NRC and report in writing as required by 49
CFR 171.15 and 49 CFR 171.16.
DF.8. The facility should ensure
that transportation of hazardous
wastes between buildings is
accomplished in accordance
with good management
practices to help prevent spills,
releases, and accidents (MP).
Determine if procedures exist to manage movement of hazardous wastes throughout
the facility.
Determine if drivers are trained in spill control procedures.
Determine if provisions have been made for securing wastes in vehicles during
transport.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
20
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.9. Transporters must not
store manifested shipments in
containers meeting DOT
packaging requirements for
more than 10 days at a transfer
facility (40 CFR 263.12).
Determine if the facility has a transfer facility.
Verify the following:
- Transfer facility storage is for 10 days or less
- DOT packaging requirements are met
- Shipments are manifested and manifests accompany shipments
- Storage is consistent with good management practices.
(NOTE: Storage for more than 10 days will require a TSDF permit.)
All Treatment, Storage and Disposal Facilities (TSDFs)
General
DF.10. All permitted TSDFs are
required to meet the hazardous
waste management
requirements outlined in their
permit (40 CFR 270.10 and
270.30 through 270.33).
Determine if the facility is operating as a permitted disposal facility.
Verify that the TSDF is not treating, storing, or disposing of waste other than those
listed in their permit or for interim status facilities, their permit application.
Verify that the TSDF is meeting the requirements outlined in the permit for the
following:
- Reporting and recordkeeping
- Compliance schedules
- Allowable wastes
- Allowable activities
- Corrective action, if applicable.
DF.11. All TSDFs which have
Interim Status are required to
meet the hazardous waste
management requirements of 40
CFR 265 and apply for a Part B
permit (40 CFR 270.71 and
279.73(g)).
Determine if the TSDF is an Interim Status disposal facility.
Verify that the TSDF is only treating, storing, or disposing of wastes listed in their Part
A application.
Verify that the TSDF is meeting all the requirements for Interim Status TSDFs outlined
in 40 CFR 265.
Verify that the TSDF has submitted a Part B permit application.
DF.12. All TSDFs that store,
treat, transport, handle, or
dispose of hazardous wastes
must obtain an EPA
identification number (40 CFR
264.11 and 265.11).
Examine documentation from EPA for the facility's TSDF identification number.
Verify that the correct identification number is used on all appropriate documentation
(i.e., manifests).
DF.13. TSDFs must control
entry to the active portion of the
facility (40 CFR 264.14 and
265.14).
Verify that the following items are in place at the TSDF, unless the TSDF can
demonstrate that physical contact with the waste, structures, and equipment within the
active portion of the TSDF will not injure unknowing or unauthorized person or
livestock, and that disturbance of the waste or equipment will not cause a RCRA
violation:
- A 24-hour surveillance system (e.g., television monitors, surveillance by guards), or
a fence or natural barrier with controlled entry (an attendant, television monitors,
locked entrances, or controlled roadway access), and
- Signs with the words "Danger-Unauthorized Personnel Keep Out" posted at each
entrance and other locations as appropriate and signs are legible from 25 ft. (7.62
m).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
21
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.14. All TSDFs must be
designed, constructed,
maintained, and operated to
minimize the possibility of a fire,
explosion, or any unplanned
release of hazardous waste or
hazardous constituents (40 CFR
264.30 through 264.37 and
265.30 through 265.37).
Determine if the following required equipment is easily accessible and in working
condition at the storage area (unless none of the hazards posed by the waste
managed at the facility would require the particular kind of equipment):
- Internal communications or alarm system capable of providing immediate
emergency instruction to facility personnel
- A telephone or hand-held two way radio, capable of summoning emergency
assistance
- Portable fire extinguishers and fire control equipment, including special
extinguishing equipment (foam, inert gas, or dry chemicals)
- Spill control equipment
- Decontamination equipment
- Fire hydrants or other source of waster (reservoir, storage tank, etc.) with adequate
volume and pressure, foam-producing equipment, or automatic sprinklers, or water
spray systems.
Determine if equipment is tested and maintained as necessary to insure proper
operation in an emergency.
Verify that sufficient aisle space is maintained to allow unobstructed movement of
personnel, fire protection equipment, spill control equipment, and decontamination
equipment to any area of the operation.
Review procedures employed by facility management to familiarize police, fire
departments, and emergency response teams with the layout of the facility, properties
of the waste being handled, and general operations as appropriate for the type of
waste and potential need for such services.
Review procedures employed by facility management to familiarize the hospital with
the site and the types of injuries that could result in an emergency as appropriate for
the type of waste and potential need for such services.
(NOTE: Where state or local authorities decline to enter into arrangements, the facility
must document this refusal in the operating record.)
DF.15. All TSDFs must take
precautions to prevent
accidental ignition or reaction of
ignitable or reactive wastes (40
CFR 264.17(a) and 265.17(a)).
Verify from the operating record and/or observation that the following safe
management practices are used:
- Wastes are separated and protected from sources of ignition or reaction
- Smoking and open flame is confined to specially designated locations when
ignitable or reactive wastes is handled
- No Smoking signs are used when necessary.
DF.16. TSDFs that treat, store or
dispose of ignitable, reactive, or
incompatible wastes must meet
specific prevention standards
(40CFR264.17(b)and
265.13(b)).
Verify from the operating record and/or observation that during treatment, storage, or
disposal of ignitable or reactive wastes, or during mixing of incompatible wastes and
other materials, precautions are taken to prevent the following reactions:
- Generation of extreme heat or pressure, fire or explosions, or violent reactions
- Production of uncontrolled toxic mists, fumes, dusts, or gases sufficient to threaten
human health or the environment
- Production of uncontrolled flammable fumes or gases sufficient to pose a risk of fire
or explosions
- Damage the structural integrity of the device or facility
- Threats to human health or the environment through other like means.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
22
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.17. A detailed chemical and
physical analysis of a
representative sample, as
specified in the TSDF's waste
analysis plan, of the hazardous
waste must be obtained prior to
treatment, storage or disposal
(40 CFR 264.13(a) and
265.13(a)).
Verify that a detailed physical and chemical analysis is done of a representative
sample of the wastes prior to treatment, storage, or disposal.
(NOTE: Prior studies or published information may be included as a part of the
analysis.)
Verify that the analysis is repeated as necessary to ensure that it is accurate and up to
date, specifically when the process or operation generating the waste has changed.
Verify that for off-site facilities, the TSDF ensures that the waste matches the identity
of the waste designated on the manifest.
DF.18. Each TSDF must have
an emergency coordinator on
the TSDF premises or on call at
all times (40 CFR 264.55 and
265.55).
Verify that, at all times, there is at least one employee at the TSDF or on call with
responsibility for coordinating all emergency response measures.
Verify that the emergency coordinator is thoroughly familiar with the TSDF, the
characteristics of the waste handled, and the provisions of the contingency plan. In
addition, verify the emergency coordinator has the authority to commit the resources
needed to carry out the contingency plan.
DF.19. TSDF emergency
coordinators must follow certain
emergency procedures
whenever there is an imminent
or actual emergency situation
(40 CFR 264.56(a) through
264.56(i) and 265.56(a) through
265.56(i)).
Verify that the emergency coordinator is required to follow these emergency
procedures:
- Immediately activate facility alarms or communication systems and notify
appropriate facility, state, and local response parties
- Identify the character, exact source, amount, and a real extent of any released
materials
- Assess possible hazards to human health or the environment, including direct and
indirect effects (e.g., release of gases, surface runoff from water or chemicals used
to control fire or explosions, etc.)
- Take all reasonable measures necessary to ensure that fires, explosions and
releases do not occur, recur, or spread to other hazardous waste at the facility.
These measures must include where applicable:
- stop processes and operations at the facility when necessary to prevent fires,
explosions, or further releases
— collect and contain the released waste
— remove or isolate containers when necessary
- Monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or
other equipment whenever appropriate
- Provide for treatment, storage, or disposal of recovered waste, contaminated soil, or
surface water, or other material immediately after emergency
- Ensure that no waste that may be incompatible with the released material is treated,
stored, or disposed of until cleanup is completed
- Ensure that all emergency equipment is cleaned and fit for its intended use before
operations are resumed
- Notify EPA, and appropriate state and local authorities that the facility is in
compliance with 40 CFR 265.56(h) before operation resumes.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
23
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Personnel Training
DF.20. All TSDF personnel who
handle hazardous waste must
meet certain training
requirements (40 CFR 264.16(a)
through 264.16(c) and 265.16(a)
through 265.16(c)).
Ensure that the facility personnel complete classroom instruction or on-the-job training
as set forth below:
Verify that the training program is directed by a person trained in hazardous waste
management procedures and that the program includes instruction which teaches
facility personnel hazardous waste management procedures relevant to positions in
which they are employed.
Although not specified by the regulations, examples of training topics for hazardous
waste management procedures could include (but would not be limited to) the
following:
- Waste turn in procedures
- Identification of hazardous wastes
- Container use, marking, labeling and on-site transportation
- Manifesting and off-site transportation
- 90 day storage area management
- Personal health and safety and fire safety
Verify that the training program includes contingency plan implementation and is
designed to ensure that facility personnel are able to respond to emergencies
including (where applicable):
- Key parameters for automatic waste feed cut-off systems
- Procedures for using, inspecting, repairing, and replacing emergency and
monitoring equipment
- Operation of communications and alarm systems
- Response to fire or explosion
- Response to groundwater contamination incidents
- Response to leaks or spills
- Shutdown of operations.
Verify that new employee training is completed within six months of employment/
assignment.
Verify that an annual review of initial training is provided.
Verify that employees do not work unsupervised until training is completed.
Verify specifically that waste storage area managers and hazardous waste handlers
have been trained.
DF.21. Training records must be
maintained for all TSDF staff
who manage hazardous waste
(40 CFR 264.16(d), 264.16(e),
265.16(d) and 265.16(e)).
Verify through examination that training records include the following:
- Job title and description for each employee by name
- Written description of how much training each position will obtain
- Documentation of training received by name.
Determine if training records are retained for three years for former employees.
Determine if training records on current employees are maintained. (NOTE: Training
records on current employees must be maintained until the closure of the facility).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
24
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Containers
DF.22. Empty containers at
TSDFs previously holding
hazardous wastes must meet
the regulatory definition of empty
before they are exempted from
hazardous waste requirements
(40CFR261.7).
Verify that for containers or inner liners holding hazardous wastes:
- Wastes are removed that can be removed using practices commonly employed to
remove materials from that type of container (e.g., pouring, pumping, aspirating)
- No more than 2.5 cm (1 in.) of residue remains, or
- If the container is less than or equal to 110 gal. (416.40 L), no more than 3 percent
by weight of total container capacity remains, or
- When the container is greater than 110 gal. (416.40 L), no more than 0.3 percent by
weight of the total container capacity remains.
Verify that for containers that held a compressed gas, the pressure in the container
approaches atmospheric.
Verify that for a container or inner liner that held an acute hazardous waste listed in
Appendix C, one of the following is done:
- It is triple rinsed
- It is cleaned by another method identified through the literature or testing as
achieving equivalent removal
- The inner liner is removed.
DF.23. Containers used to store
hazardous waste at TSDFs must
be in good condition and not
leaking (40 CFR 264.171 and
265.171).
Verify that containers are not leaking, bulging, rusting, damaged or dented.
Verify that waste is transferred to a new container or managed in another appropriate
manner when necessary.
DF.24. Containers used at
TSDFs must be made of or lined
with materials compatible with
the waste stored in them (40
CFR 264.172 and 265.172).
Verify that containers are compatible with waste, in particular, check that strong
caustics and acids are not stored in metal drums.
DF.25. Containers at TSDFs
must be closed during storage
and handled in a safe manner
(40 CFR 264.173 and 265.173).
Verify that containers are closed except when it is necessary to add or remove waste
(check bungs and look for open funnels).
Verify that handling and storage practices do not cause damage to the containers or
cause them to leak.
DF.26. The handling of
incompatible wastes, or
incompatible wastes and
materials in containers at TSDFs
must comply with safe
management practices (40 CFR
264.17(b), 264.177, 265.17(b)
and 265.177).
Verify that incompatible wastes or incompatible wastes and materials are not placed in
the same containers unless it is done so that it does not:
- Generate extreme heat or pressure, fire, or explosion, or violent reaction
- Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to
threaten human health
- Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a
risk of fire or explosions
- Damage the structural integrity of the device or TSDF or by any other like means
threaten human health.
(NOTE: Incompatible wastes as listed in Appendix D should not be placed in the same
containers.)
Verify that hazardous wastes are not placed in an unwashed container that previously
held an incompatible waste or material.
Verify that containers holding hazardous wastes incompatible with wastes stored
nearby in other containers, open tanks, piles, or surface impoundments are separated
or protected from each other by a dike, berm, wall or other device.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
25
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.27. Containers of hazardous
waste at TSDFs should be
managed in accordance with
specific management practices
(MP).
Verify the following by inspecting the container storage areas:
- Containers are not stored more than two high and have pallets between them
- Containers of highly flammable wastes are electrically grounded (check for clips and
wires and make sure wires lead to ground rod or system)
- At least 3 ft. (0.91 m) of aisle space is provided between rows of containers.
DF.28. Containers with design
capacities greater than 0.1 m3
[-26 gal.] and less than or equal
to 0.46 m3 [-122 gal.] into which
hazardous waste is placed are
required to meet specific design
and operating standards (40
CFR 265.1086(a) through
265.1086(b)(1)(i), 265.1087(a)
through 265.1087(b)(1)(l) and
265.1087(c)).
(NOTE: The requirements of 40 CFR 264.1086 and 265.1087 do not apply to
containers in which all the hazardous waste entering the container meets one of the
following (40 CFR 265.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste entering the waste management unit
has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the regulatory agency for the waste in 268.42(a) or an
equivalent method approved by the regulatory agency pursuant to 268.42(b).)
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 264.1080(b)(2) and 265.1080(b)(2)).)
(NOTE: Standards for containers used in waste stabilization processes (40 CFR
264.1086(b)(2) and 265.1087(b)(2)) are in checklist item DF.30.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
26
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.28. (continued)
Verify that, for containers with a design capacity greater than 0.1 m [-26 gal.] and
less than or equal to 0.46 m3 [-122 gal.], air emissions are controlled according to the
following Container Level 1 standards:
- A container is used that meets applicable U.S. DOT regulations on the packaging of
hazardous materials for transportation
- A container is used that is equipped with a cover and closure devices that form a
continuous barrier over the container openings so that when the cover and closure
devices are secured in the closed position there are not visible holes, gaps or other
open spaces into the interior of the container
- An open-top container is used in which an organic vapor suppressing barrier is
placed on or over the hazardous waste in the container so that no hazardous waste
is exposed to the atmosphere.
Verify that when a container using Level 1 standards, other than DOT approved
containers, is used, it is equipped with covers and closure devices composed of
suitable materials to minimize exposure, to the extent practical, of the hazardous
waste to the atmosphere and to maintain the equipment integrity throughout the
intended service life.
Verify that, whenever waste is in a container using Level 1 controls, covers and
closure devices are installed and closure devices are secured and maintained in the
closed position except as follows:
- Opening of a closure device or cover is allowed for adding waste or other material
to the container as follows:
— when the container is filled to the intended final level in one continuous operation,
the closure devices are secured in the closed position and the covers installed at
the conclusion of the filling operation
- when discrete batches or quantities of material are added intermittently to the
container over a period of time, the closure devices are secured in the closed
position and covers installed upon either:
— the container being filled to the intended final level
— the completion of a batch loading after which no additional material will be
added to the container within 15 minutes
— the person performing the loading operation leaving the immediate vicinity of
the container, or
— the shutdown of the process generating the material being added to the
container, whichever condition occurs first.
- Opening of a closure device or cover is allowed for removing the hazardous waste
as follows:
- in order to meet the requirements for an empty container
— when discrete quantities or batches of material are removed from the container
but the container is not empty, the closure devices will promptly be returned to
the closed position and the covers installed upon either:
— completion of batch removal after which no additional material will be removed
within 15 minutes or
— the person performing the unloading leaves the immediate vicinity, whichever
condition occurs first
- Opening of a closure device or cover is allowed when access inside the container is
needed to perform routine activities other than transfer of hazardous waste
- Opening of a spring loaded, pressure vacuum relief valve, conservation vent, or
similar type of pressure relief device which vents to the atmosphere is allowed
during normal operations for the purpose of maintaining internal container pressure
- Opening of a safety device to avoid unsafe conditions.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
27
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.29. Containers with design
capacities greater than 0.46 m3
[-122 gal.] into which hazardous
waste is placed are required to
meet specific design and
operating standards (40 CFR
264.1086(a), 264.1087(b)(1)(ii)
through 264.1086(b)(1)(iii),
264.1086(c)(1) through
264.1086(c)(3), 264.1086(d),
265.1087(a), 265.1087(b)(1)(ii)
through 265.1087(b)(1)(iii),
265.1087(c)(1) through
265.1087(c)(3), and
265.1087(d)).
(NOTE: The requirements of 40 CFR 264.1086 and 265.1087 do not apply to
containers in which all the hazardous waste entering the container meets one of the
following (40CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste entering the waste management unit
has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the regulatory agency for the waste in 268.42(a) or an
equivalent method approved by the regulatory agency pursuant to 268.42(b).)
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2) and 265.1080(b)(2)).)
(NOTE: Standards for containers used in waste stabilization processes (40 CFR
265.1087(b)(2)) are in checklist item DF.30.)
Verify that, for containers with a design capacity greater than 0.46 m3 [-122 gal.] that
are not in light material service, air emissions are controlled according to the following
Container Level 1 standards:
- A container is used that meets applicable U.S. DOT regulations on the packaging of
hazardous materials for transportation
- A container is used that is equipped with a cover and closure devices that form a
continuous barrier over the container openings so that when the cover and closure
devices are secured in the closed position there are not visible holes, gaps or other
open spaces into the interior of the container
- An open-top container is used in which an organic vapor suppressing barrier is
placed on or over the hazardous waste in the container so that no hazardous waste
is exposed to the atmosphere.
Verify that, for containers with a design capacity greater than 0.46 m3 [-122 gal.] that
are in light material service, air emissions are controlled according to the following
Container Level 2 standards:
- A container is used that meets applicable U.S. DOT regulations on the packaging of
hazardous materials for transportation
- A container is used that operates with no detectable organic emissions
- A container is used that has been demonstrated within the preceding 12 months to
be vapor tight.
(NOTE: Level 2 standards apply only to containers that are in light material service.
For the containers that are not in light material service, Level 1 standards apply. (See
40 CFR 265.1087(b)(ii) and (Hi).)
Verify that when a container using Level 1 standards, other than DOT approved
containers, is used it is equipped with covers and closure devices composed of
suitable materials to minimize exposure of the hazardous waste to the atmosphere
and to maintain the equipment integrity for as long as it is in service.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
28
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.29. (continued)
Verify that whenever waste is in a container using Level 1 or Level 2 controls, covers
and closure devices are installed and closure devices are secured and maintained in a
closed position except as follows:
- Opening of a closure device or cover is allowed for adding waste or other material
to the container as follows:
— when the container is filled to the intended final level in one continuous operation,
the closure devices are secured in the closed position and the covers installed at
the conclusion of the filling operation
— when discrete batches or quantities of material are added intermittently to the
container over a period of time, the closure devices are promptly secured in the
closed position and covers installed upon either:
— the container being filled to the intended final level
— the completion of a batch loading after which no additional material will be
added to the container within 15 minutes
— the person performing the loading operation leaving the immediate vicinity of
the container
— the shutdown of the process generating the material being added to the
container, whichever condition occurs first
- Opening of a closure device or cover is allowed for removing the hazardous waste
as follows:
— in order to meet the requirements for an empty container
— when discrete quantities or batches of material are removed from the container
but the container is not empty, the closure devices are promptly secured in the
closed position and the covers installed upon either:
— completion of batch removal after which no additional material will be removed
within 15 minutes
— the person performing the unloading leaves the immediate vicinity, whichever
condition occurs first
- Opening of a closure device or cover is allowed when access inside the container is
needed to perform routine activities other than transfer of hazardous waste
- Opening of a spring loaded, pressure vacuum relief valve, conservation vent, or
similar type of pressure relief device which vents to the atmosphere and is allowed
during normal operations for the purpose of maintaining internal container pressure
- Opening of a safety device to avoid unsafe conditions.
Verify that the transfer of hazardous waste in or out of containers meeting Container
Level 2 controls is done in a manner to minimize exposure of the hazardous waste to
the atmosphere (i.e., a submerged fill pipe, a vapor balancing system, a vapor
recovery system, a fitted opening in the top of the container through which the
hazardous waste is filled and subsequently purge the transfer line before removing it).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
29
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.30. Containers with design
capacities greater than 0.1 m3
[-26 gal.] used for the treatment
of a hazardous waste by a waste
stabilization process are
required to meet specific design
and operating standards (40
CFR 264.1086(a),
264.1086(b)(2), 264.1086(e)(1)
through 264.1086(e)(3),
265.1087(a), 265.1087(b)(2),
and 265.1087(e)(1) through
265.1087(e)(3)).
(NOTE: The requirements of 40 CFR 264.1086 and 265.1087 do not apply to
containers in which all the hazardous waste entering the container meets one of the
following (40 CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmv
- The organic content of the hazardous waste entering the waste management unit
has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the regulatory agency for the waste in 268.42(a) or an
equivalent method approved by the regulatory agency pursuant to 268.42(b).)
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 264.1080(b)(2) and 265.1080(b)(2)).)
(NOTE: Safety devices may be installed and operated as necessary.)
Verify that containers with design capacities greater than 0.1 m3 [-26 gal.] used for the
treatment of a hazardous waste by a stabilization process meet the following Container
Level 3 standards at those times during the waste stabilization process when the
hazardous waste in the container is exposed to the atmosphere:
- A container is used that is vented directly through a closed-vent system to a control
device
- A container is used that is vented inside an enclosure which is exhausted through a
closed-vent system to a control device
- The container closure is designed and operated in accordance with the criteria for a
permanent total enclosure under 40 CFR 52.741
- The closed-vent system and control device is designed and operated in accordance
with 264.1087 and 265.1088 (see checklist item DF.33).
DF.31. Facilities are required to
have a written plan and
schedule for inspection and
monitoring requirements for
containers and meet specific
inspection requirements (40
CFR 264.15, 264.1086(c)(4),
264.1086(d)(4), 264.1088(b),
265.1087(c)(4), 265.1087(d)(4),
and 265.1089).
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 264.1086(b)(2) and 265.1080(b)(2)).)
Verify that the facility has a written plan and schedule for performing inspections and
monitoring.
Verify that the plan and schedule are being met.
Verify that inspections of the containers and their covers and closure devices for
containers using Container Level 1 or Level 2 controls are done as follows:
- When a hazardous waste is already in the container when it is first accepted and
the container is not emptied within 24 hours after it is accepted, the container and
its cover are visually inspected on the date of acceptance for cracks, holes, gaps, or
other open spaces into the interior of the container when the cover and closure
devices are secured in the closed position
- When a container is used for managing hazardous waste for 1 year or more, it is
visually inspected at least once every 12 months for visible cracks, holes, gaps, or
other open spaces when the cover and closure devices are secured in the closed
position.
Verify that when a defect is detected, the first efforts at repairs are within 24 hours
after detection, and repair is completed as soon as possible but no later than 5
calendar days after detection.
(NOTE: If repair cannot be completed within 5 calendar days, the hazardous waste
must be removed from the container.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
30
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.32. Facilities are required to
meet documentation
requirements for containers (40
CFR264.1086(c)(5),
264.1089(a), 264.1089(d)
through 264.1089(1),
265.1087(c)(5), 265.1090(a),
and 265.1090(d) through
265.1090(1)).
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 264.1080(b)(2) and 265.1080(b)(2)).)
Verify that a copy is available of the procedure used to determine that containers with
a capacity of 0.46 m3 [-122 gal.] or greater which do not meet DOT standards are not
managing hazardous waste in light material service.
Verify that if using Container Level 3 air emissions controls, the facility prepares and
maintains records that include:
- The most recent set of calculations and measurements performed by the
owner/operator to verify that the enclosure meets the criteria of a permanent total
enclosure as specified in 40 CFR 52.741, Appendix B
- All the records required for closed-vent systems.
Verify that, if using a closed-vent system and control device, the following records are
maintained:
- Certification that is signed and dated by the owner/operator stating that the control
device is designed to operate at the performance level documented by a design
analysis or by performance tests when the container is operating at capacity or the
highest level reasonably expected to occur
- Design documents if design analysis is used, including certification that the
equipment meets the applicable specification
- A performance test plan if performance tests are used and all test results
- Description and date of each modification, as applicable
- Identification of operating parameters, description of monitoring devices, and
diagrams of monitoring sensor locations, as applicable
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
31
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
DF.32. (continued)
DF.32. (continued)
Reviewer Checks:
- Semiannual records of the following for those planned routine maintenance
operations that would require the control device to exceed limitations:
- a description of the planned routine maintenance that is anticipated to be
performed for the control device during the next 6-month period, including the
type of maintenance needed, planned frequency, and lengths of maintenance
periods.
- a description of the planned routine maintenance that was performed for the
control device during the previous 6-month period, including the type of
maintenance performed and the total number of hours during those 6-months
that the control device did not meet applicable requirements
- Records of the following for those unexpected control device system malfunctions
that would cause the control device to not meet specifications:
- the occurrence and duration of each malfunction of the control device system
- the duration of each period during a malfunction when gases, vapors, or fumes
are vented from the waste management unit through the closed-vent system to
the control device while the control device is not properly functioning
- actions taken during periods of malfunction to restore a malfunctioning control
device to its normal or usual manner of operation
- Records of the management of the carbon removed from a carbon adsorption
system.
Verify that, for exempted containers, the following records are prepared and
maintained as applicable:
- If exempted under the hazardous waste concentration conditions, information used
for the waste determination in the facility operating log and/or the date, time, and
location of each waste sample if analysis results for samples are used
- If exempted under incinerator use or process destruction use, the identification
number for the incinerator, boiler, or industrial furnace in which the hazardous waste
is treated.
Verify that covers designated as unsafe to monitor are listed in a log kept in the facility
operating record with an explanation of why they are unsafe to inspect and monitor
and a plan and schedule of inspection and monitoring is recorded.
Verify that, for containers not using the air emissions controls specified in 40 CFR
265.1085 through 265.1088 (see checklist items DF.28 through DF.33), the following
information is maintained:
- A list of the individual organic peroxide compounds manufactured at the facility if it
produces more than one functional family of organic peroxides or multiple organic
peroxides within one functional family, and one or more of these organic peroxides
could potentially undergo self-accelerating thermal decomposition at or below
ambient temperatures
- A description of how the hazardous waste containing the organic peroxide
compounds identified in the above list is managed, including:
- a facility identification number for the container or group of containers
— the purpose and placement of this container or group of containers in the
management train of this hazardous waste
- the procedures used to ultimately dispose of the hazardous waste handled in the
containers
- An explanation why managing these containers would be an undue safety hazard.
Verify that all records, except design information records, are kept for at least 3 years.
Verify that design information records are maintained in the operating record until the
air emissions control equipment is replaced or otherwise no longer in service.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
32
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.33. Facilities are required to
meet specific requirements for
closed-vent systems and control
devices used to achieve
compliance (40 CFR 264.1087
and 265.1088).
(NOTE: The requirements of 40 CFR 264.1087 and 265.1088 do not apply to
containers in which all the hazardous waste entering the container meets one of the
following (40 CFR 265.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste entering the waste management unit
has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the regulatory agency for the waste in 268.42(a) or an
equivalent method approved by the regulatory agency pursuant to 268.42(b).)
(NOTE: These requirements do not apply to a container that has a design capacity
less than or equal to 0.1 m3 [-26 gal.] (40 CFR 264.1080(b)(2) and 265.1080(b)(2)).)
Verify that closed-vent systems meet the following:
- It routes the gases, vapors and fumes emitted from the hazardous waste in the
waste management unit to a control device
- It is designed and operated in accordance with 40 CFR 264.1033Q) or265.1033(j)
- If it includes bypass devices that could be used to divert the gas or vapor stream to
the atmosphere before entering the control device, one of the following equipment
requirements is met for each type of bypass device (NOTE: low leg drains, high
point bleeds, analyzer vents, open-ended valve or lines, spring loaded pressure
relief valves, and other fittings used for safety purposes are not considered bypass
devices):
— a flow indicator is installed, calibrated, maintained, and operated at the inlet to
the bypass line used to divert gases and vapors from the closed-vent system to
the atmosphere at a point upstream of the control device inlet
— a seal or locking device is placed on the mechanism by which the bypass device
position is controlled when the bypass valve is in the closed position so that the
bypass device cannot be opened without breaking the seal or removing the lock.
Verify that the seal or closure mechanism is visually inspected at least once every
month.
Verify that one of the following control devices is used:
- A device designed and operated to reduce the total organic content of the inlet
vapor stream vented to the control device by at least 95 percent by weight
- An enclosed combustion device designed and operated in accordance with
264.1033(c)and265.1033(c)
- A flare designed and operated in accordance with 40 CFR 264.1033(d) and
265.1033(d).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
33
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
DF.33. (continued)
Reviewer Checks:
Verify that, when a closed-vent system and control device is used, the following are
met:
- Periods of planned routine maintenance of the control device during which the
device does not meet specifications do not exceed 240 hours per year
- Control device system malfunctions are corrected as soon as practicable
- It is operated such that gases, vapors, and/or fumes are not actively vented to the
control device during periods of planned maintenance or control device system
malfunction, except in cases where it is necessary to do so in order to avoid an
unsafe condition or to implement malfunction corrective actions or planned
maintenance actions.
Verify that, if a carbon adsorption system is used, the following requirements are met:
- All activated carbon is replaced with fresh carbon on a regular basis as outlined in
40 CFR 264.1033(g), 264.1033(h), 265.1033(g) and 265.1033(h)
- All carbon that is a hazardous waste and that is removed from the control device is
managed according to 264.1033(n) or 265.1033(m) regardless of the average
volatile organic concentration.
Verify that, if a control device other than a thermal vapor incinerators, flare, boiler,
process heater, condenser, or carbon adsorption system is used, the requirements in
40 CFR 264.1033(1) and 265.1033(1) are met.
Verify that, for control devices, it is demonstrated by either a performance test or a
design analysis that the device achieves compliance except for the following:
- A flare
- A boiler or process heater with a design input capacity of 44 MW or greater
- A boiler or process heater into which the vent stream is introduced with the primary
fuel
- A boiler or process heater burning hazardous waste for which the owner or operator
has been issued a final permit under 40 CFR 270 and has designed and operates
the unit in accordance with the requirements of 40 CFR 266, subpart H
- A boiler or industrial furnace burning hazardous waste for which the owner or
operator has certified compliance with the interim status requirements of 40 CFR
265, subpart H.
Verify that the readings from each control device are inspected at least once each
operating day to check control device operation.
Container Storage Areas
DF.34. Containers at TSDFs
should be kept in storage areas
designated in the management
plan and identified by signs
(MP).
DF.35. Containers holding
ignitable or reactive waste must
be located 15 meters (50 feet)
from the property line of a TSDF
(40 CFR 264.176 and 265.176).
DF.36. TSDF personnel must
conduct weekly inspections of
container storage areas (40
CFR 264. 174 and 265. 174).
Verify that all containers are identified and stored in appropriate areas.
(NOTE: Any unidentified contents of solid waste containers and/or containers not in
designated storage areas must be tested to determine if solid or hazardous waste
requirements apply.)
Determine the distance from any storage containers to the property line.
(NOTE: This restriction does not apply to SQGs).
Verify that inspections are conducted at least weekly to look for leaking containers and
signs of deterioration of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
34
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Containment Buildings
(NOTE: According to the "Background Information' published on page 37221 of the 18 August 1992 edition of the Federal
Register, a hazardous waste containment building involves "the management of a hazardous waste inside a unit designed
and operated to contain the hazardous waste within the unit." This is not a building that holds drums or tanks filled with
hazardous waste, but a building that holds the hazardous waste itself.)
DF.37. TSDFs with containment
buildings that are in compliance
are not subject to the definition
of land disposal if specific
requirements are met (40 CFR
264.1100 and 265.1100).
Verify that the containment building meets the following:
- It is a completely enclosed, self-supporting structure that is designed and
constructed of manmade materials of sufficient strength and thickness to support
themselves, the waste contents, and any personnel and heavy equipment that
operate within the unit
- It is designed to prevent failure due to pressure gradients, settlement, compression,
or uplift, physical contact with the hazardous wastes, climatic conditions, and the
stress of daily operations
- It has a primary barrier that is designed to be sufficiently durable to withstand the
movement of personnel, wastes, and handling of equipment within the unit
- If the unit is used to manage liquids:
— there is a primary barrier designed and constructed of materials to prevent
migration of hazardous constituents into the barrier
- there is a liquid collection system designed and constructed of materials to
minimize the accumulation of liquid on the primary barrier
— there is a secondary containment system designed and constructed of materials
to prevent migration of hazardous constituents into the barrier, with a leak
detection and liquid collection system capable of detecting, collecting, and
removing leaks of hazardous constituents at the earliest practicable time
- It has controls sufficient to prevent fugitive dust emissions
- It is designed and operated to ensure containment and prevent the tracking of
materials from the unit by personnel and equipment.
DF.38. Containment buildings
are required to be designed
according to specific standards
(40 CFR 264.1101 (a)(1) through
264.1101(a)(2), 264.1101(a)(4),
264.1101(b), 265.1101(a)(1)
through 265.1101(a)(2), and
265.1101 (b)).
Verify that containment buildings meet the following design standards:
- It is completely enclosed with a floor, walls, and a roof to prevent exposure to the
elements and to assure containment of wastes
- The floor and containment walls, including any required secondary containment
system, are designed and constructed of man-made materials of sufficient strength
and thickness to support themselves, the waste contents, and any personnel and
heavy equipment that operate within the unit
- It is designed to prevent failure due to pressure gradients, settlement, compression,
or uplift, physical contact with the hazardous wastes, climatic conditions, and the
stress of daily operations
- It has sufficient structural strength to prevent collapse or other failure
- All surfaces in contact with hazardous wastes are compatible with the wastes
- It has a primary barrier that is designed to be sufficiently durable to withstand the
movement of personnel, wastes, and handling of equipment within the unit and is
appropriate for the chemical and physical characteristics of the waste.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
35
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.38. Continued
Verify that if the containment building is going to manage hazardous wastes with free
liquids or treated with free liquids the following design requirements are also met:
- There is a primary barrier designed and constructed of materials to prevent
migration of hazardous constituents into the barrier (e.g., a geomembrane covered
by a concrete wear surface)
- There is a liquid collection and removal system designed and constructed of
materials to minimize the accumulation of liquid on the primary barrier
- The primary barrier is sloped to drain liquids to the associated collection system
- Liquids and wastes are collected and removed to minimize hydraulic head on the
containment system at the earliest practicable time
- There is a secondary containment system, including a secondary barrier, designed
and constructed of materials to prevent migration of hazardous constituents into the
barrier, with a leak detection and liquid collection system capable of detecting,
collecting, and removing leaks of hazardous constituents at the earliest practicable
time
- The leak detection component of the secondary containment system meets the
following:
- it is constructed with a bottom slope of one percent or more
— it is constructed of granular drainage materials with a hydraulic conductivity of 1 x
10~2 cm/s or more and a thickness of 12 in. (30.5 cm) or more, or constructed of
synthetic or geonet drainage materials with a transmissivity of 3 x 10"5 m2/s or
more
- If treatment is to be conducted in the building, the treatment area is designed to
prevent the release of liquids, wet materials, or liquid aerosols to other portions of
the building
- The secondary containment system is constructed of materials that are chemically
resistant to the waste and liquids managed in the building and of sufficient strength
and thickness to prevent collapse under pressure exerted by overlaying materials
and by any equipment used.
(NOTE: An exception to the structural strength requirement may be made for
lightweight doors and windows based on the nature of the waste management
operations if the following criteria are met:
- The doors and windows provide an effective barrier against fugitive dust emissions
- The unit is designed and operated in a manner that ensures that the waste will not
come in contact with the doors or windows.)
(NOTE: A containment building can serve as secondary containment systems for
tanks within the building if:
- It meets the requirements of 264.193(d) (see protocol for storage tank management)
- It meets the requirements of 264.193(b) and 264.193(c)(1) and (2) (see protocol for
storage tank management.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
36
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.39. Containment buildings
are required to be operated
according to specific standards
(40 CFR 264.1101(a)(3),
264.1101(c)(1), 264.1101(c)(4),
265.1101(a)(3), 26
and 265.1101(c)(4)).
Verify that incompatible wastes or treatment reagents are not placed in the building or
its secondary containment system if they could cause the unit or the secondary
containment system to leak, corrode, or otherwise fail.
Verify that the following operational procedures are done:
- Controls and practices are used to ensure the containment of the waste within the
building
- The primary barrier is maintained so that it is free of significant cracks, gaps,
corrosion, or other deterioration that could cause hazardous waste to be released
from the primary barrier
- The level of the stored/treated hazardous waste is maintained so that the height of
any containment wall is not exceeded
- Measures are implemented to prevent the tracking of hazardous waste out of the
unit by personnel or equipment used in the handling of the waste
- There is a designated area for the decontamination of equipment and collection of
rinsate
- Any collected rinsate is managed as needed according to its constituents
- Measures are implemented to control fugitive dust emissions so that no openings
exhibit visible emissions
- Particulate collection devices are maintained and operated according to sound air
pollution control practices.
Verify that data is gathered from monitoring equipment and leak detection equipment
and the site is inspected at least once every seven days and the results recorded in
the operating record.
DF.40. Containment buildings
are required to be certified by a
registered professional engineer
(40CFR264.1101(c)(2)and
265.1101(c)(2)).
Verify that the building has been certified.
DF.41. Leaks in containment
buildings must be repaired and
reported (40 CFR
264.1101(c)(3)and
265.1101(c)(3)).
Verify that if a condition is detected that could lead to a leak or has already caused a
leak, it is repaired promptly.
Verify that when a leak is discovered:
- The discovery is recorded in the TSDF operating record
- The portion of the containment building that is affected is removed from service
- A cleanup and repair schedule is established
- Within seven days the regulatory agency is notified and within 14 working days
written notice is provided to the regulatory agency
- The regulatory agency is notified upon the completion of all repairs and certification
from a registered professional engineer is also submitted.
DF.42. Containment buildings
that contain both areas with and
without secondary containment
must meet specific requirements
(40 CFR 264.1101(d) and
265.1101 (d)).
Verify that each area is designed and operated according to the appropriate
requirements.
Verify that measures are taken to prevent the release of liquids or wet materials into
areas without secondary containment.
Verify that a written description is maintained in the TSDF operating log of operating
procedures used to maintain the integrity of areas without secondary containment.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
37
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.43. When a containment
building is closed specific
requirements must be met (40
CFR 264.1102 and 265.1102).
Determine if the TSDF has closed a containment building recently.
Verify that at closure, all waste residues, contaminated containment system
components, contaminated subsoils, structures, and equipment contaminated with
waste and leachate were removed or decontaminated.
Verify that the containment building is closed in accordance with closure and post-
closure requirements for TSDFs as outlined in the subsections pertaining to all TSDFs
titled Documentation Requirements and Closure.
Verify that if it is found that not all contaminated subsoils can be practicably removed
or decontaminated, the site is closed and landfill post-closure requirements are
implemented.
Restricted Wastes
DF.44. TSDFs must not dispose
of the wastes listed in Appendix
E on land unless specific
parameters are met (40 CFR
268.1, 268.4, and Appendix VII).
Verify that the wastes listed in Appendix E are not land disposed after the indicated
dates in the appendix unless:
- The TSDF was granted an extension
- The waste is hazardous only because it exhibits a hazardous characteristic, and is
otherwise prohibited from land disposal, but is not prohibited from land disposal if
the waste:
— is disposed of into a nonhazardous or hazardous injection well
- does not exhibit any prohibited characteristic of a hazardous waste at the point of
injection
- Disposal is done in a surface impoundment and treatment of the wastes occurs at
the impoundment
- Sampling, testing, and removal procedures and design requirements outlined in 40
CFR 268.4 are followed
- The waste is treated.
(NOTE: The following are exempted from all of the requirements concerning restricted
wastes found in 40 CFR 268:
- Waste generated by a SQG of less than 100 kg (220.46 Ib.) of hazardous waste or
less than 1 kg of acute hazardous waste per month
- Waste pesticides that a farmer disposes of
- Wastes identified or listed as hazardous after 8 November 1984 for which EPA has
not promulgated land disposal prohibitions or treatment standards
- De minimis losses to wastewater treatment systems of commercial chemical
product or chemical intermediates that are ignitable (D001) or corrosive (D002) and
that contain underlying hazardous constituents
- Laboratory wastes displaying the characteristic of ignitability (D001), or corrosivity
(D002), that are commingled with other plant wastewaters under designated
circumstances
- Laboratory wastes that are ignitable and corrosive containing underlying hazardous
constituents from laboratory operations that are mixed with other plant wastewaters
at TSDFs whose ultimate discharge is subject to CWA regulations if the annualized
flow of laboratory wastewater into the facility's headwork does not exceed one
percent or the laboratory wastes combined annualized sewage concentration does
not exceed one ppm in the facility's headwork.)
(NOTE: As of May 8, 1993, debris that is contaminated with the wastes listed in
Appendix E and debris that is contaminated with any characteristic waste for which
there are treatment standards are prohibited from land disposal.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
38
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.45. Wastes that are
restricted from land disposal or
the residual from the treatment
of a waste restricted from land
disposal shall not be diluted as a
substitute for adequate
treatment (40 CFR 268.3(a) and
268.3(b)).
Verify that restricted wastes or the residual from the treatment of restricted wastes are
not diluted unless they are hazardous only because they exhibit a characteristic in a
treatment system which treats wastes that are then discharged into a water of the
United States by permit or which treats wastes for the purpose of pre-treatment or
unless the waste is a D003 reactive cyanide wastewater or nonwastewater.
DF.46. A restricted waste may
be land disposed only if the
constituent concentrations in the
waste or waste treatment
residue meet applicable
treatment standards, or if the
waste is treated using a
specified treatment technology
or equivalent treatment method
(40 CFR 268.40 through
268.43).
Verify that for restricted wastes identified in Appendix F that are land disposed, the
associated constituent concentrations in the extract of the waste or waste treatment
residual do not exceed the values shown in Appendix F.
Verify that for restricted wastes listed in Appendix G that are land disposed, the waste
is treated using the treatment technology specified in Appendix G or an equivalent
treatment method approved by the regulatory agency.
Verify that for restricted wastes identified in Appendix H that are land disposed, the
associated constituent concentrations in the waste or waste treatment residue do not
exceed the values shown in Appendix H.
(NOTE: As used in Appendices G and H, the term wastewater has the following
meaning: wastes that contain less than 1 percent by weight total organic carbon (TOC)
and less than 1 percent by weight total suspended solids (TSS), with the following
exceptions:
- F001, F002, F003, F004, F005 wastewaters are solvent-water mixtures that contain
less than 1 percent by weight TOC or less than 1 percent by weight total F001,
F002, F003, F004, F005 solvent constituents listed in Appendix F
- K011, K013, K014 wastewaters contain less than 5 percent by weight TOC and less
than 1 percent by weight TSS, as generated
- K103 and K104 wastewaters contain less than 4 percent by weight TOC and less
than 1 percent by weight TSS
- Waste analysis plan compliance.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
39
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.47. Treatment facilities are
required to follow specific
procedures for restricted wastes
(40CFR268.7(b)).
Verify that treatment facilities are testing their waste according to the procedures
outlined in their waste analysis plan.
Verify that the generating facility sends a one-time notification with the first hazardous
waste shipment going to a treatment or disposal facility. A copy of this notification
would also be placed in the treatment facility's files. This one-time notification
requirement also applies to lab packs.
A new notification is needed if there is a change in the waste, process, or receiving
facility. This change should affect the determination of which treatment standards
apply.
The notification shall include the following information:
- EPA hazardous waste number
- The waste is subject to the LDRs and the constituents of concern for F001-F005
and F039 and underlying hazardous constituents (for wastes that are not managed
in a CWA or CWA-equivalent facility), unless the waste will be treated and
monitored for all constituents (NOTE: If all wastes will be treated and monitored,
there is no need to put them on the LDR notice.)
- Determination of applicable wastewater/nonwastewater category and subdivisions
made within a waste code based on waste-specific criteria
- The manifest number associated with the shipment of waste
- Waste analysis data, when available
- Certification statement.
Verify that the treatment facility submits a certification of waste or treatment residue of
a restricted waste to the land disposal facility stating that the waste has been treated in
compliance with applicable standards.
(NOTE: If waste or treatment residues will be further managed at a different treatment
or storage facility, the TSDF sending the waste or treatment residue offsite must
comply with notice and certification requirements.)
(NOTE: Where the wastes are recyclable materials used in a manner constituting
disposal, the treatment facility is not required to notify the receiving facility.)
DF.48. Land disposal facilities
for restricted wastes are
required to maintain copies of
notices and certifications and
test the waste except when
disposing of waste that is
recycled material used in a
manner constituting disposal (40
CFR268.7(c)).
Verify that copies of the certifications and notification are kept on hand.
Verify that the facility is testing waste as specified in the facilities waste analysis plan.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
40
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.49. The storage of
hazardous waste that is
restricted from land disposal is
not allowed unless specific
conditions are met (40 CFR
268.50).
Verify that land disposal restricted waste is not stored at the TSDF unless the TSDF is
storing the wastes in tanks, containers, or containment buildings in order to
accumulate the necessary quantities for proper recovery, treatment or disposal and:
- Each container is marked to identify contents and the date accumulation began
- Each tank is clearly marked with a description of the contents, the quantity of each
hazardous waste received, and the start date of accumulation or a record of such
information is maintained.
Verify that transporters do not store manifested shipments of land disposal restricted
wastes for more than 10 days.
(NOTE: A TSDF may store the land disposal restricted wastes for up to one year if
they can prove that the reason for storage is to accumulate such quantities of
hazardous waste as are necessary to facilitate proper treatment and disposal.)
(NOTE: The prohibition on storage does not apply to hazardous wastes that have met
treatment standards.)
Verify that liquid hazardous wastes containing PCBs at concentrations greater than 50
ppm are stored at a site that meets the requirements of 40 CFR 761.65(b) (see Toxic
Substance Control Act (TSCA)) and is removed from storage within one year of the
date it was first placed into storage.
Emissions from Process Vents
DF.50. TSDFs with process
vents associated with distillation,
fractionation, thin-film
evaporation, solvent extraction,
or air or steam stripping
operations that manage
hazardous wastes with organic
concentrations of at least 10
ppmw are required to meet
specific standards (40 CFR
264.1030(b), 264.1030(e),
264.1032, 265.1030(b),
265.1030(d) and 265.1032).
(NOTE: This applies only if the operation are conducted in one of the following:
- A unit that is subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt from
permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste
recycling unit that is not a 90-day storage tank or container) and that is located at a
hazardous waste management unit facility that is otherwise subject to the permitting
requirements of 40 CFR 270
- A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e.,
a 90-day tank or container) and is not a recycling unit under the provisions of 40
CFR 261.6.)
Verify that one of the following is met:
- Total organic emissions from the process vents do not exceed 1.4 kg/h (3 Ib/h) and
2.8Mg/yr(3.1 tons/yr)
- Total organic emissions are reduced by use of a control device from all process
vents by 95 weight percent.
(NOTE: These requirements do not apply to the process vents at a facility where the
owner/operator certifies all of the process vents that would otherwise have to meet
these requirements are equipped with and operating air emission controls in
accordance with the process vent requirements of an applicable regulation under 40
CFR part 60, part 61, or part 63. The documentation of compliance with these other
regulations must be kept with, or made readily available with, the facility operating
record.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
41
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.51. When a TSDF uses a
closed-vent system and control
device to meet the standards for
total organic emissions, the
closed-vent system and control
device must meet certain
minimum requirements (40 CFR
264.1030(b), 264.1030(e),
264.1033(a) through
264.1033(h), 264.1033(j),
264.1033(k), 265.1030(b),
265.1030(d) and 265.1033(a)
through 265.1033(j)).
(NOTE: This applies to TSDFs with process vents associated with distillation,
fractionation, thin-film evaporation, solvent extraction, or air or steam stripping
operations that manage hazardous wastes with organic concentrations of at least 10
ppmw, if the operations are conducted in one of the following:
- A unit that is subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt from
permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste
recycling unit that is not a 90-day tank or container) and that is located at a
hazardous waste management facility that is otherwise subject to the permitting
requirements of 40 CFR 270
- A unit that is exempt form permitting under the provisions of 40 CFR 262.34(a) (i.e.,
a 90-day tank or container) and is not a recycling unit under the provisions of 40
CFR 261.6.)
(NOTE: These requirements do not apply to the process vents at a facility where the
owner/operator certifies all of the process vents that would otherwise have to meet
these requirements are equipped with and operating air emission controls in
accordance with the process vent requirements of an applicable regulation under 40
CFR part 60, part 61, or part 63. The documentation of compliance with these other
regulations must be kept with, or made readily available with, the facility operating
record.)
Verify that control devices involving vapor recovery are designed and operated to
recovery the organic vapors vented to the air with an efficiency of 95 weight percent or
greater unless the total organic emission limit(s) can be attained at an efficiency of
less than 95 weight percent.
Verify that if an enclosed combustion device is used (i.e., vapor incinerator, boiler, or
process heater), it is designed and operated to reduce the organic emissions vented to
it by 95 weight percent or greater, to achieve a total organic compound concentration
of 20 ppmv expressed as the sum of the actual compounds, not carbon equivalents,
on a dry basis corrected to 3 percent oxygen, or to provide a minimum residence time
of 0.50 seconds at a minimum temperature of 760°C [1400°F].
Verify that if a boiler or process heater is used as the control device, the vent stream is
introduced into the flame zone of the boiler or process heater.
Verify that if flares are used:
- They are designed and operated with no visible emissions except for periods not in
excess of five minutes during any two consecutive hours
- They are operated with a flame present at all times
- They are used only if the net heating value of the gas being combusted is 11.2
MJ/scm (300 Btu/scf) or greater, if the flare is steam-assisted or air-assisted
- If nonassisted, the net heating value of the gas being combusted is 7.45 MJ/scm
(200 Btu/scf) or greater
- If nonassisted or steam-assisted, they have an exit velocity less than 18.3 m/s (60
ft/s) except when the net heating value of the gas being combusted is greater than
37.3 MJ/scm (1000 Btu/scf) and the exit velocity is equal to or greater than 18.3 m/s
(60 ft/s) but less than 122 m/s (400 ft/s).
Verify that each monitor and control device is inspected on a routine basis.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
42
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.51. (continued)
Verify that each required control device is installed, calibrated, monitored and
inspected as follows:
- A flow indicator is installed in the vent stream at the nearest feasible point to the
control device inlet, but before being combined with other streams, and provides a
record of vent stream flow from each affected process vent to the control device at
least once every hour
- A device to continuously monitor control device operations as specified:
— a temperature monitoring device equipped with a continuous recorder for a
thermal vapor incinerator
- a temperature monitoring device equipped with a continuous recorder for a
catalytic vapor incinerator
— a heat sensing monitor with a continuous recorder for flares
- a temperature monitoring device equipped with a continuous recorder to
measure a parameter that indicates good combustion operating practices are
being used for a boiler or process heater having a design heat input capacity less
than 44 MW
- for a condenser, one of the following:
— a monitoring device with a continuous recorder to measure the concentration
level of the organic compound in the exhaust vent stream from the condenser
— a temperature monitoring device equipped with a continuous recorder capable
of monitoring temperature in the exhaust vent stream from the condenser exit
with an accuracy of ± 1 percent of the temperature being monitored in Celsius
or in ± 0.5 Celsius, whichever is greater
— for a carbon adsorption system such as a fixed bed carbon adsorber that
regenerates the carbon bed directly in the control device, one of the following:
— a monitoring device equipped with a continuous recorder to measure the
concentration levels of the organic compounds in the exhaust vent stream
from the carbon bed
— a monitoring device equipped with a continuous recorder to measure a
parameter that indicates the carbon bed is regenerated on a regular,
predetermined time cycle.
Verify that readings from monitoring devices are checked at least once a day.
Verify that if a carbon adsorption system is being used that regenerates the carbon
bed directly onsite, the existing carbon in the control device is replaced with fresh
carbon at regular, predetermined time intervals.
(NOTE: The predetermined time interval is based on the design analysis required
under 40 CFR 265.1035(b)(4)(iii)(F).)
Verify that if a carbon adsorption system is being used that does not regenerate the
carbon bed directly onsite, the existing carbon in the control device is replaced on a
regular basis.
(NOTE: When to replace the carbon is determined by one of the following procedures:
- Monitoring the concentration level of the organic compound in the exhaust vent
stream from the carbon adsorption system daily or at an interval no greater than 20
percent of the time required to consume the total carbon working capacity,
whichever is longer
- Replace the carbon at a regular predetermined time interval that is less than the
design carbon replacement interval.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
43
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.51. (continued)
Verify that closed-vent systems meet one of the following:
- Are designed and operated with no detectable emissions as indicated by an
instrument reading of less than 500 ppm above background as determined by the
procedures in 40 CFR 264.1035(b) and 265.1034(b) and by visual inspection
- Are designed to operate at a pressure below atmospheric pressure and are
equipped with at least one pressure gauge or other pressure measurement device
that can be read from a readily accessible location.
DF.52. TSDFs are required to
maintain specific records
pertaining to process vent
emissions (40 CFR 264.1035
and 265.1035).
Verify that the following information is kept in the operating record:
- An implementation schedule, if appropriate
- Up-to-date documentation of compliance with process vents and with closed-vent
systems
- The test performance plan if test data is used to determine the organic removal
efficiency or total organic compound concentration achieved by a control device
- Documentation of compliance with 40 CFR 265.1033, including:
— a list of all information references and sources used in preparing the
documentation
- records, including the dates of required compliance tests
— design analysis, specifications, drawings, schematics, and piping and
instrumentation diagrams if engineering calculations are used
- A statement signed and dated by the operator or owner certifying that the operating
parameters used in the design analysis reasonably represent the conditions which
exist when the hazardous waste management unit is or would be operating at the
highest load or capacity level reasonably expected
- A statement signed and dated by the owner or operator certifying that the control
device is designed to operate at an efficiency of 95 percent or greater unless the
total organic concentration limit is achieved at an efficiency of less than 95 weight
percent or the total organic emissions limits for affected process vents can be
attained by a control device involving vapor recovery at an efficiency less than 95
weight percent
- All performance test results if used to demonstrate compliance
- Design documentation
- Monitoring and inspection results
- Notations of exceedance
- Explanation for each period of exceedance
- For carbon adsorption systems:
— when the carbon is replaced in carbon adsorption systems
- date and time when a control device is monitored for carbon breakthrough
- The date of each control device startup and shutdown.
Verify that records of monitoring operations and inspection information are kept for
three years.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
44
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.53. Closed-vent systems are
required to be monitored,
inspected, and leaks repaired
(40CFR264.1030(b),
264.1030(e), 264.1033(1),
264.1033(0), 265.1030(b),
265.1030(d), 265.1033(k), and
265.1033(n)).
(NOTE: This applies to TSDFs with process vents associated with distillation,
fractionation, thin-film evaporation, solvent extraction, or air or steam stripping
operations, that manage hazardous wastes with organic concentrations of at least 10
ppmw, if the operations are conducted in one of the following:
- A unit that is subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt form
permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste
recycling unit that is not a 90-day tank or container) and that is located at a
hazardous waste management facility that is otherwise subject to the permitting
requirements of 40 CFR 270
- A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e.,
a 90-day tank or container) and is not a recycling unit under the provisions of 40
CFR 261.6.)
(NOTE: These requirements do not apply to the process vents at a facility where the
owner/operator certifies all of the process vents that would otherwise have to meet
these requirements are equipped with and operating air emission controls in
accordance with the process vent requirements of an applicable regulation under 40
CFR part 60, part 61, or part 63. The documentation of compliance with these other
regulations must be kept with, or made readily available with, the facility operating
record.)
Verify that closed-vent systems designed and operated with no detectable emissions
(i.e., one at a pressure below atmospheric pressure) as indicated by an instrument
reading of less than 500 ppm above background are monitored as follows:
- An initial leak detection monitoring of the closed-vent system using the procedures
outlined in 40 CFR 264.1034(b) or 265.1034(b) on or before the date the system
becomes subject to this section of the CFR
- Visual inspection at least once a year for closed-vent system joints, seams, or other
connections that are permanently or semi-permanently sealed (e.g., a welded joint
between two sections of hard piping or a bolted and gasketed ducting flange)
- Annual and at times required by the regulatory agency for all other parts of the
system using the procedures specified in 40 CFR 265.1034(b).
Verify that closed-vent systems designed to operate at no detectable emissions are
monitored as follows:
- Annual visual inspection to check for defects that could result in air pollutant
emissions
- Initial inspection on or before the date the system becomes subject to this section of
the CFR.
(NOTE: For closed-vent systems designed to operate at no detectable emissions,
portions of the system designated as unsafe to monitor are exempt from the visual
monitoring if:
- The components are unsafe to monitor because monitoring personnel would be
exposed to an immediate danger
- A written plan that requires monitoring as practicable during safe to monitor periods
is in place and followed.)
Verify that detectable emissions, as indicated by visual inspection or by an instrument
reading of greater than 500 ppmv above background, are controlled as soon as
practicable but not later than 15 days after the emission is detected.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
45
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.53. (continued)
Verify that a first attempt at repair is made no later than 5 calendar days after the
emission is detected.
(NOTE: Delay of repair of a closed-vent system for which leaks have been detected is
allowed if the repair is technically infeasible without a process unit shutdown, or if it is
determined that the emissions resulting from the immediate repair would be greater
than the fugitive emissions likely to result from delay of repair.)
DF.54. Closed-vent systems and
control devices used to comply
with the provisions of 40 CFR
264.1030 through 264.1035 and
265.1030 through 265.1035 are
required to be operated at all
times when emissions may be
vented to them (40 CFR
264.1030(b), 264.1030(e),
264.1033(m), 265.1030(b),
265.1030(d), and 265.1033(1)).
(NOTE: This applies to TSDFs with process vents associated with distillation,
fractionation, thin-film evaporation, solvent extraction, or air or steam stripping
operations, that manage hazardous wastes with organic concentrations of at least 10
ppmw, if the operations are conducted in one of the following:
- A unit that is subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt form
permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste
recycling unit that is not a 90-day tank or container) and that is located at a
hazardous waste management facility that is otherwise subject to the permitting
requirements of 40 CFR 270
- A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e.,
a 90-day tank or container) and is not a recycling unit under the provisions of 40
CFR 261.6.)
Verify that closed-vent systems and control devices are operated at all times when
emissions may be vented to them.
(NOTE: These requirements do not apply to the process vents at a facility where the
owner/operator certifies all of the process vents that would otherwise have to meet
these requirements are equipped with and operating air emission controls in
accordance with the process vent requirements of an applicable regulation under 40
CFR part 60, part 61, or part 63. The documentation of compliance with these other
regulations must be kept with, or made readily available with, the facility operating
record.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
46
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.55. When carbon adsorption
systems are used, operators are
required to manage all carbon
that is a hazardous waste
according to specific parameters
(40CFR264.1030(b),
264.1030(e), 264.1033(n),
265.1030(b), 265.1030(d), and
265.1033(m)).
(NOTE: This applies to TSDFs with process vents associated with distillation,
fractionation, thin-film evaporation, solvent extraction, or air or steam stripping
operations, that manage hazardous wastes with organic concentrations of at least 10
ppmw, if the operations are conducted in one of the following:
- A unit that is subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt form
permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste
recycling unit that is not a 90-day tank or container) and that is located at a
hazardous waste management facility that is otherwise subject to the permitting
requirements of 40 CFR 270
- A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e.,
a 90-day tank or container) and is not a recycling unit under the provisions of 40
CFR 261.6.)
(NOTE: These requirements do not apply to the process vents at a facility where the
owner/operator certifies all of the process vents that would otherwise have to meet
these requirements are equipped with and operating air emission controls in
accordance with the process vent requirements of an applicable regulation under 40
CFR part 60, part 61, or part 63. The documentation of compliance with these other
regulations must be kept with, or made readily available with, the facility operating
record.)
Verify that carbon removed form control devices that is a hazardous waste is managed
in one of the following manners, regardless of the average VOC concentration of the
carbon:
- Regenerated or reactivated in a thermal treatment unit that meets one of the
following:
- the unit has a final permit under 40 CFR 270 which implements the requirements
of 40 CFR 264, subpartX
— the unit is equipped with and operating air emission controls in accordance with
applicable requirements
- Incinerated in a hazardous waste incinerator for which the operator either:
— has a final permit under 40 CFR 270 which implements the requirements of 40
CFR 264, subpart O
- has designed and operates the incinerator in accordance with the interim status
required in 40 CFR 265, subpart O
- Burned in a boiler or industrial furnace for which the operator either:
- has been issued a final permit under 40 CFR 270 implementing 40 CFR 266
— has designed and operates the boiler or industrial furnace in accordance with the
interim status requirements of 40 CFR 266, subpart H.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
47
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Air Emission Standards for Equipment Leaks
(NOTE: This section applies to equipment that contains or contacts hazardous waste with organic concentrations of at
least 10 percent by weight that are managed in one of the following (40 CFR 264.1050(b) and 265.1050(b)):
- A unit that us subject to the permitting requirements of 40 CFR 270
- A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR
262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a
hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270
- A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container) and is
not a recycling unit under the provisions of 40 CFR 261.6.)
(NOTE: This section does not apply to the following (40 CFR 264.1050(e), 264.1050(f), 265.1050(d), and 265.1050(e)):
- Equipment that is in vacuum service and is identified as such on the required list
- Equipment that contains or contacts hazardous waste with an organic concentration of at least 10 percent by weight for
less than 300 hours per calendar year and is identified as such.
DF.56. TSDFs with pumps in
light liquid service that contain or
contact hazardous wastes with
organic concentrations of at
least 10 percent by weight are
required to meet specific
standards (40 CFR 264.1052
and 265.1052).
Verify that pumps in light liquid service are monitored monthly according to designated
reference methods and visually inspected weekly.
(NOTE: A leak is detected if there is an instrument reading of 10,000 ppm or greater
or if there is an indication of liquid dripping from the pump seal.)
Verify that when a leak is detected, the first attempt at repair is made within five
calendar days and repair is completed within 15 calendar days.
Verify that, if the TSDF has chosen not to monitor monthly or visually check weekly,
pumps equipped with a dual mechanical seal system meet the following design and
operation requirements:
- The dual mechanical seal system is operated with barrier fluid at a pressure that is
at all times greater than the pump stuffing box or equipped with a barrier fluid
degassing reservoir that is connected by a closed-vent system to a control device or
equipped with a system that purges the barrier fluid into a hazardous waste stream
with no detectable emission to the atmosphere
- The barrier fluid system must not be a hazardous waste with organic concentrations
10 percent or greater by weight
- The barrier fluid system is equipped with a sensor that will detect failure if the seal is
broken
- Pumps are checked by visual inspection weekly
- Sensors are checked daily or equipped with an audible alarm that is checked
monthly.
Verify that, if the TSDF has chosen not to monitor monthly or visually check weekly,
pumps designated for no detectable emissions as indicated by an instrument reading
of 500 ppm above background or less meet the following:
- They are operated with no detectable emissions
- They are tested for compliance initially upon designation, annually, and at other
times as requested by the regulatory agency
- No externally actuated shaft penetrates the pump housing.
(NOTE: Any pump that is equipped with a closed-vent system capable of capturing
and transporting any leakage from the seal or seals to a control device is exempt from
these requirements.)
DF.56. (continued)
Verify that the owner/operator has determined, based on design considerations and
operating experience, a criterion that indicates failure of the seal system, the barrier
fluid system, or both.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
48
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.57. TSDFs with compressors
that contain or contact
hazardous wastes with organic
concentrations of at least 10
percent by weight are required
to meet specific standards (40
CFR 264.1053 and 265.1053).
Verify that each compressor is equipped with a seal system that includes a barrier fluid
system and that prevents leakage of total organic emissions to the atmosphere except
if:
- It is equipped with a closed-vent system capable of capturing and transporting any
leakage from the seal to a control device
- It is designated for no detectable emission and:
— it operates at an instrument reading of less than 500 ppm above background
— it is tested for compliance initially upon designation, annually, and at times as
requested by the regulatory agency.
Verify that compressor seal systems meet one of the following:
- It is operated with the barrier fluid at a pressure that is at all times greater than the
compressor stuffing box pressure
- It is equipped with a barrier fluid system that is connected to a closed-vent system to
a control device
- It is equipped with a system that purges the barrier fluid into a hazardous waste
stream with no detectable emissions to the atmosphere.
Verify that the barrier fluid is not a hazardous waste with organic concentrations 10
percent or greater by weight.
Verify that each barrier fluid system is equipped with a sensor that will detect failure of
the seal system, barrier fluid system, or both.
Verify that each sensor is checked daily or is equipped with an audible alarm that is
checked monthly.
(NOTE: Sensors on compressors located within the boundary of an unmanned site
must be checked daily.)
Verify that when a leak is detected, the first attempt at repair is made within five
calendar days and the repair is made within 15 calendar days.
DF.58. TSDFs with pressure
relief devices in gas/vapor
service that contain or contact
hazardous wastes with organic
concentrations of at least 10
percent by weight are required
to meet specific standards (40
CFR 264.1054 and 265.1054).
Verify that, except during pressure releases, each pressure relief device in gas/vapor
service is operated with no detectable emissions as indicated by an instrument reading
of less than 500 ppm above background.
Verify that, if there is a pressure release, the device is returned to a no detectable
emission status within 5 calendar days and the device is monitored to ensure
compliance.
(NOTE: Any pressure relief device that is equipped with a closed-vent system capable
of capturing and transporting leakage from the pressure relief device to a control
device is exempt from these requirements.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
49
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.59. TSDFs with sampling
connecting systems that contain
or contact hazardous wastes
with organic concentrations of at
least 10 percent by weight are
required to meet specific
standards (40 CFR 264.1055
and 265.1055).
Verify that each sampling connection system is equipped with a closed purge, closed
loop system or closed-vent system.
Verify that each system collects the sample purge for return to the processing or for
routing to the appropriate treatment system.
(NOTE: Gases displaced through filling of the sample container are not required to be
collected or captured.)
Verify that each closed purge, closed loop system or closed-vent system does one of
the following:
- Returns the purged process fluid directly to the process line
- Collects and recycles the purged process fluid
- Is designed and operated to capture and transport all the purged process fluid to a
waste management unit that is in compliance or a control device that is in
compliance.
(NOTE: In-situ sampling systems are exempt from these requirements.)
DF.60. TSDFs with open-ended
valves or lines that contain or
contact hazardous wastes with
organic concentrations of at
least 10 percent by weight are
required to meet specific
operation standards (40 CFR
264.1056 and 265.1056).
Verify that each open-ended valve or line is equipped with a cap, blind flange, plug, or
a second valve.
Verify that the cap, blind flange, plug, or second valve seals the open end at all times
except during operations requiring hazardous waste stream flow through the open-
ended valve of line.
Verify that each open-ended valve or line equipped with a second valve is operated so
that the valve on the hazardous waste stream end is closed before the second valve is
closed.
Verify that when a double block and bleed system is being used, the bleed valve is
shut or plugged except during operations that require venting the line between the
block valves.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
50
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.61. TSDFs with valves in
gas/vapor service or light liquid
service that contain or contact
hazardous wastes with organic
concentrations of at least 10
percent by weight are required
to meet specific monitoring and
repair standards (40 CFR
264.1057, 264.1061, 265.1057,
and 265.1061).
Verify that valves in gas/vapor service or light liquid service are monitored monthly to
detect leaks.
(NOTE: A leak is detected if an instrument reading of 10,000 ppm or greater is
measured. But, if a leak is not detected for two consecutive months, monitoring may
be cut back to quarterly until a leak is detected.)
(NOTE: Valves that are designated for no detectable emissions, as indicated by an
instrument reading of less than 500 ppm above background, do not have to be
monitored monthly if:
- The valve has no external actuating mechanism in contact with the hazardous waste
stream
- The valve is operated with emission less than 500 ppm above background
- The valve is tested initially upon designation, annually, and at the request of the
regulatory agency.)
(NOTE: Valves that are designated as unsafe-to-monitor are exempt from the
requirement for monthly monitoring if:
- The valve is unsafe to monitor because monitoring personnel would be exposed to
an immediate danger
- A written monitoring plan is followed that requires monitoring as often as is
reasonably practicable during safe-to-monitor times.)
(NOTE: Valves that are designated as difficult-to-monitor are exempt from monthly
monitoring requirements if:
- The valve cannot be monitored without elevating the monitoring personnel more
than 2 meters above a support surface
- The hazardous waste management unit within which the valve is located was in
operation before June 21, 1990
- A written monitoring plan is followed that requires the monitoring of the valve at least
once per calendar year.)
(NOTE: The TSDF may elect to have all valves within a hazardous waste
management unit comply with an alternative standard of no greater than 2 percent of
the valves to leak.)
(NOTE: The following are alternatives to the prescribed monitoring schedule which can
be used until the percentage of valves leaking is greater than 2 percent:
- After 2 consecutive quarterly leak detection periods with the percentage of valves
leaking equal to or less than 2 percent, an owner or operator may begin to skip one
of the quarterly leak detection periods for the valves
- After 5 consecutive quarterly leak detection periods with the percentage of valves
leaking equal to or less than 2 percent, an owner or operator may begin to skip 3 of
the quarterly leak detection periods.
Verify that, when a leak is detected, the first attempt at repair is made within five
calendar days after detection, and leak repair is completed within 15 calendar days
after detection.
(NOTE: First attempts at repair include, but are not limited to:
- Tightening of bonnet bolts
- Replacement of bonnet bolts
- Tightening of packing gland nuts
- Injection of lubricant into lubricated packing.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
51
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.62. TSDFs with pumps and
valves in heavy liquid service,
pressure relief devices in light
liquid service or heavy liquid
service, and other connectors
that contain or contact
hazardous wastes with organic
concentrations of at least 10
percent by weight are required
to meet specific monitoring and
repair standards (40 CFR
264.1058 and 265.1058).
Verify that pumps and valves in heavy liquid service, pressure relief devices in light
liquid service or heavy liquid service, and other connectors are required to be
monitored within five days if evidence of a potential leak is found by visual, olfactory,
audible, or other detection method.
(NOTE: A leak is detected if an instrument reading of 10,000 ppm or greater is
measured.)
Verify that, when a leak is detected, the first attempt at repair occurs within five days
and repair is done within 15 days after discovery.
(NOTE: First attempts at repair include, but are not limited to:
- Tightening of bonnet bolts
- Replacement of bonnet bolts
- Tightening of packing gland nuts
- Injection of lubricant into lubricated packing.)
(NOTE: Any connector that is inaccessible or is ceramic or ceramic-lined is exempt
from the monitoring requirements.)
DF.63. TSDFs are required to
keep specific records pertaining
to the valves, pumps, pressure
relief devices, and connecting
systems being monitored for
leaks and submit certain reports
(40 CFR 264.1058(e), 264.1064,
264.1065,265.1058(6), and
265.1064).
Verify that the following information is maintained in the TSDF operating record:
- Equipment identification number and hazardous management unit identification
- Approximate locations
- Type of equipment
- Percent-by-weight total organics in the hazardous waste stream at the equipment
- Hazardous waste state at the equipment (gas, liquid, vapor)
- Method of compliance
- Implementation schedule if needed
- A performance plan for control devices as needed
- Documentation of compliance
- Documentation of repair, including:
- the instrument and operator identification numbers and the equipment
identification number
— the date evidence of a potential leak was found
— the date the leak was detected and the date of each attempt to repair the leak
- repair methods applied in each attempt
- "Above 10,000" if the maximum instrument reading after each repair attempt is
greater than 10,000 ppm
— "Repair delayed" and the reason for delay if the leak is not repaired within 15
calendar days after discovery
- documentation supporting the delay of valve repair
— signature of the owner or operator whose decision it was that repair could not be
made without a hazardous waste management unit shutdown
- the expected date of successful repair of the leak when it is not repaired within
15 calendar days
— the date of the successful repair of the leak
- Design documentation and monitoring, operating, and inspection information for
each closed-vent system control device required to comply with the provisions of 40
CFR 265.1060
- Monitoring and inspection information indicating proper operation and maintenance
of the control device for a control device other than a thermal vapor incinerator,
catalytic vapor incinerator, flare, boiler, process heater, condenser, or carbon
adsorption system
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
52
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.63. (continued)
- The following information for all equipment subject to 40 CFR 265.1052 through
265.1060:
- a list of identification numbers for equipment (except welded fittings)
— a list of identification numbers for equipment that the owner or operator elects to
designate for no detectable emissions
- a list of equipment identification numbers for pressure relief devices
- the dates of required compliance tests, background levels, maximum instrument
reading, measured during the compliance test
— a list of identification numbers for equipment in vacuum service
- identification either by list or location (area or group) of equipment that contains
or contacts hazardous waste with an organic concentration of at least 10 percent
by weight for less than 300 hours per calendar year.
Verify that the following information is kept for all valves subject to 40 CFR
265.1057(g)and(h):
- A list of identification numbers for valves listed as unsafe to monitor, an explanation
for each valve stating why it is unsafe to monitor, and the plan for monitoring each
valve
- A list of identification numbers for valves that are designated as difficult to monitor,
an explanation for each valve stating why it is difficult to monitor, and the plan for
monitoring each valve
- The following for all valves complying with 40 CFR 265.1062:
- a schedule of monitoring
- the percent of valves found leaking in each monitoring period.
Verify that the following information is kept for use in determining exemptions:
- An analysis determining the design capacity of the unit
- A statement listing the hazardous waste influent to and effluent from each unit
subject to 40 CFR 265.1052 through 265.1060 and an analysis determining whether
these hazardous wastes are heavy liquids
- An up-to-date analysis and the supporting information and data used to determine if
equipment is subject to the requirements.
(NOTE: If repairs are made and the control device does not exceed or operate outside
of the design specifications for more than 24 hours, a report to the regulatory agency
is not required.)
Verify that permitted TSDFs submit a semiannual report indicating leaks and repairs to
the regulatory agency.
(NOTE: Any connector that is inaccessible or is ceramic or ceramic-lined is exempt
from the recordkeeping requirements.
DF.64. Each piece of equipment
subject to the requirements in 40
CFR 264.1050 through
264.1064 and 265.1050 through
265.1064 is required to be
marked so that it can be
distinguished from other
equipment (40 CFR 264.1050(d)
and265.1050(c)).
Verify that each piece of equipment subject to the requirements in 40 CFR 264.1050
through 264.1064 and 265.1050 through 265.1064 is marked so that it can be
distinguished from other equipment.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
53
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.65. When a TSDF
owner/operator has elected to
comply with alternative
standards, specific actions are
required (40 CFR 264.1061 and
265.1061).
Determine if the owner/operator subject to 40 CFR 264.1057/265.1057 (see checklist
item DF.61) has elected to have all valves within a hazardous waste management unit
comply with an alternative standard of allowing 2 percent of the valves to leak.
Verify that the following actions have been taken if complying with the 2 percent
alternative:
- The regulatory agency has been notified of the choice to comply with the alternative
standard
- A performance test was conducted initially upon designation, annually, and at other
times as required by the regulatory agency
- If a valve leak is detected, first attempt at repair is within 5 calendar days and leak
repair is completed within 15 days after detection.
Verify that, if the owner/operator has decided to no longer apply with the 2 percent
rule, they have notified the regulatory agency.
Documentation Requirements
OF.66. TSDFs must develop and
follow a written waste analysis
plan(40CFR264.13(b),
264.13(c), 265.13(b), and
265.13(c)).
Determine if the TSDF treats, stores, or disposes of hazardous waste.
Verify that the TSDF has a waste analysis plan.
Verify that the TSDF is following the waste analysis plan by comparing the plan to
records of actual procedures.
Verify that the waste analysis plan contains the following:
- Testing parameters for which each hazardous waste will be analyzed
- Test methods
- Sampling methods used to obtain a representative sample
- Frequency in which the analysis will be reviewed or repeated to ensure that the
analysis is up-to-date and accurate
- Waste analysis supplied by offsite generators
- Methods used to meet the additional analysis requirements for management of
ignitable, reactive, or incompatible wastes, bulk and containerized liquids, and
incineration are stated (if applicable)
- Procedures and schedules for sampling, analysis and removal of residues, where
required, for the surface impoundments exempted from the LDR restrictions
- Additional information required for TSDFs seeking an exemption from the air
emission standards of subpart CC
- Additional information as follows for offsite facilities:
- specific procedures to inspect (and analyze if necessary) each movement of
hazardous waste received to ensure that it matches the identity of the waste
designated in the manifest
- the method of sampling used to obtain a representative sample (if the
identification method includes sampling)
— the procedures that an offsite landfill receiving containerized hazardous waste
will use to determine if a hazardous waste generator or treater has added a
biodegradable sorbent to the waste in the container.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
54
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.67. Each TSD site on the
facility must have a formal
written inspection schedule and
a log of inspection results (40
CFR 264.15 and 265.15).
Verify that the TSDF has a formal written inspection schedule for inspecting monitoring
equipment, safety and emergency equipment, security devices, and operating and
structural equipment that are important to preventing, detecting, or responding to
environmental or human health hazards.
Verify that the schedule is kept at the TSDF and lists types of problems to be looked
for during the inspection.
Verify that areas subject to spills, such as loading and unloading areas, are inspected
daily when in use.
Verify that any deterioration or malfunction detected by the inspections has been
corrected.
Verify that logs, or records, of the inspections are kept for three years and include the
following:
- The date and time of the inspection
- The name of the inspector
- A notation of the observations made
- The date and nature of any repairs or other remedial actions.
DF.68. TSDFs must have a
contingency plan (40 CFR
264.50 through 264.54 and
265.50 through 265.54).
(NOTE: TSDFs may be addressed in the facility's SPCC plan or other emergency
plan, or if none exists, in a separate contingency plan.)
Verify that the contingency plan is designed to minimize hazards to human health or
the environment from fires, explosions, or any unplanned sudden or non-sudden
release of hazardous waste or hazardous waste constituents.
Verify that the plan includes the following:
- A description of actions to be taken during an emergency
- A description of arrangements, as appropriate, agreed to by local police
departments, fire departments, hospitals, contractors, and state and local
emergency response teams
- Names, addresses, and phone numbers of all persons qualified to act as
emergency coordinator
- A list of all emergency equipment at the TSDF, its location, a physical description,
and an outline of its capabilities
- An evacuation plan for TSDF personnel where there is a possibility evacuation
would be needed.
Verify that copies of the contingency plan are maintained at the TSDF and also have
been submitted to organizations which may be called upon to provide emergency
services.
Verify that the contingency plan is routinely reviewed and updated, especially when the
TSDF is issued a new permit, the plan fails in an emergency, the emergency
coordinators change, the waste being handled changes, and/or the list of emergency
equipment changes.
DF.69. TSDF operators must
record the time, date, and
details of any incident that
requires implementing the
contingency plan (40 CFR
264.56G) and 265.56Q)).
Review TSDF operating records to determine if incidents have been recorded and
corrective actions taken.
Verify that written reports have been submitted to the regulatory agency within 15 days
after the incident.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
55
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.70. TSDF operators must
keep written operating records
at the facility (40 CFR 264.73
through 264.74 and 265.73
through 265.74).
Verify that the TSDF has a written operating record.
Determine if the operating record includes:
- A description and quantity of each hazardous waste received at the TSDF and the
method(s) and date(s) of treatment, storage, or disposal of each waste received at
the TSDF
- The location of each hazardous waste within the TSDF (cross-referenced to specific
manifest document numbers and the quantity at each location)
- For disposal facilities, the location and quantity is recorded on a map or diagram of
each cell or disposal area
- Records and results of waste analyses and waste determinations performed
- Reports of all the incidents that required the implementation of the contingency plan
- Records and results of inspections (only a 3 year retention period)
- Monitoring, testing, and analytical data (where required)
- For offsite facilities, notices to the generator
- Annual certification that the TSDF has a program in place to reduce the volume and
toxicity of hazardous waste, and that the proposed method of treatment, storage, or
disposal minimizes the present and future threat to human health and the
environment
- The record of the quantities and date of placement for each shipment of hazardous
waste placed in land disposal units under an extension granted by 40 CFR 268.5, a
petition granted under 40 CFR 268.6, or a certification granted under 40 CFR 268.8
- A copy of the applicable notice, demonstration, and certification required for any
restricted hazardous wastes
- Certifications and demonstrations provided to generators or received from
generators
- Closure cost estimates or, for disposal facilities, post-closure cost estimates.
(NOTE: This information must be recorded and maintained in the operating record
until closure of the disposal facility.)
(NOTE: The retention period for all records is extended automatically during the
course of any unresolved enforcement action or as required by the regulatory agency.)
DF.71. TSDFs must prepare and
submit a single copy of a
biennial report to the regulatory
agency by March 1 of each even
numbered year (40 CFR 264.75
and 265.75).
Obtain a copy of the biennial report (EPA Form 8700-13D or applicable state form).
Verify that biennial reports are prepared and submitted and contain the following
information:
- EPA identification number
- TSDF name and address
- Calendar year covered by report
- Description and quantity of each waste received
- Method of treatment, storage, or disposal for each waste
- Certification signed by owner or operator of the TSDF
- Offsite facilities must also report EPA identification number for each hazardous
waste generator from which waste was received
- Description of efforts undertaken during the year to reduce the volume and toxicity
of waste generated (for onsite facilities only)
- Description of changes in volume and toxicity of waste actually achieved during the
year in comparison to previous years to the extent that information is available for
the years prior to 1984 (for onsite facilities only).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
56
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.72. TSDFs must have a
written closure plan for each
TSDF(40CFR264.110,
264.112(a), 264.112(b),
265.110,265.112(3), and
265.112(b)).
Determine if the TSDF has a written closure plan.
Determine, by review, if the closure plan addresses:
- How the TSDF will be closed
- Estimates of the maximum amount of wastes in storage and in treatment during the
life of the TSDF
- Description of removal or decontamination procedures to be used during closure
- Schedule for closure of each unit.
DF.73. TSDFs with hazardous
waste disposal units and certain
surface impoundments and
waste piles are required to have
a written post-closure plan (40
CFR 264.118 and 265.118(3)
through 265.118(d)).
Verify that the plan includes the following information:
- Identifies the monitoring and maintenance activities that will be carried on after
closure of each disposal unit and the frequency of these activities
- Name address and phone number of the person or office to contact during post-
closure care.
Verify that the plan is amended if there is a change in the expected year of final
closure, if events occur during the life of the TSDF that impact closure care or there is
a change in TSDF design.
DF.74. TSDFs that receive
waste from offsite sources must
comply with manifest
requirements (40 CFR 264.70,
264.71, 265.70 and 265.71).
Determine if the TSDF receives waste from offsite sources and if their permit allows for
the receipt of offsite waste.
Determine if manifests contain the following by reviewing a random number of
manifests:
- Proper signature
- Date of receipt.
Verify that a copy was sent to the generator within 30 days of receipt of waste.
Verify that copies are retained at the TSDF for three years from the date of delivery of
hazardous waste.
Verify that wastes received by the TSDF are included in their permit.
(NOTE: Periods of retention of records are extended automatically during the course
of any unresolved enforcement action or as requested by the regulatory agency.)
DF.75. TSDFs which receive
waste from offsite sources are
required to attempt to resolve
manifest discrepancies when
they occur (40 CFR 264.72 and
265.72).
Determine if significant discrepancies existed between the quantity or type of waste
designated on the manifest or shipping paper, and the quantity or type of waste the
TSDF received.
Verify that on discovery of a significant discrepancy, an attempt was made to reconcile
the discrepancy with the generator and/or the transporter.
Verify that if the discrepancy could not be resolved within 15 days after receipt of the
waste, the regulatory agency was notified by mail and the following was included:
- A letter describing the discrepancy and the attempts to reconcile it
- Copy of the manifest or shipping paper at issue.
(NOTE: For bulk waste, variations greater than 10 percent in weight, and for batch
waste, any variation in piece count is a significant discrepancy. Significant
discrepancies in type are obvious differences which can be discovered by inspection
or waste analysis, such as waste solvent substituted for waste acid, or toxic
constituents not reported on the manifest or shipping paper. These discrepancies may
only be discovered after waste analysis.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
57
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.76. Reports must be
submitted to the regulatory
agency when a TSDF accepts
an unmanifested waste
shipment (40 CFR 264.76 and
265.76).
Determine if unmanifested shipments have been accepted.
Verify that reports (Form 8700-13B or applicable state form) are submitted within 15
days.
(NOTE: When small quantities (i.e., waste from CESQGs) are received without
certification that the waste is excluded from manifest requirements, an unmanifested
waste report should be filed.)
Surface Impoundments
DF.77. TSDFs must follow
specific restrictions concerning
the types of wastes placed in
any surface impoundment (40
CFR 264.229, 264.230, 265.229
and 265.230).
Verify that incompatible wastes or incompatible wastes and materials are not placed in
the same surface impoundment unless precautions are taken to prevent:
- Generation of extreme heat or pressure, fire or explosions, or violent reactions
- Production of uncontrolled toxic mists, fumes, dusts, or gases in quantities that
would threaten human health or the environment
- Production of uncontrolled flammable fumes or gases in quantities that would pose
a risk of fire or explosion
- Damage to structural integrity of the device or TSDF
- Threats to human health or the environment through other means.
Verify that ignitable or reactive wastes are not placed in surface impoundments unless
the wastes and impoundments satisfy the restrictions in 40 CFR 268 (see checklist
items DF.44 through DF.49, "Restricted Wastes") and they are treated, rendered or
mixed so that it is no longer ignitable or reactive.
Verify that one of the following conditions is met for the surface impoundment when
used for ignitable or reactive waste:
- Precautions are taken so that the following are prevented:
- generation of extreme heat or pressure, fire or explosions, or violent reactions
— production of uncontrolled toxic mists, fumes, dusts, or gases in quantities that
would threaten human health or the environment
- production of uncontrolled flammable fumes or gases in quantities that would
pose a risk of fire or explosion
— damage to structural integrity of the device or TSDF
— threats to human health or the environment through other means
- The waste is managed so that it is protected from any materials or conditions which
may cause it to ignite or react
- The surface impoundment is used only for emergencies.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
58
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.78. When surface
impoundments use floating
membrane covers, the covers
are required to meet specific
design standards (40 CFR
264.1085(a) through
264.1085(c)(2), and 265.1086(a)
through 265.1086(c)(ii)).
(NOTE: These requirements do not apply to a surface impoundment in which an owner
or operator has stopped adding hazardous waste (except to implement an approved
closure plan) and the owner or operator has begun implementing or completed closure
following an approved closure plan (40 CFR 264.1080(b)(4) and 265.1080(b)(4)).)
(NOTE: These requirements do not apply to surface impoundments in which all the
hazardous waste entering the surface impoundment meets one of the following (40
CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste has been reduced by an organic
destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the EPA for the waste in 268.42(a) or an equivalent
method.)
Verify that the surface impoundment has installed and operates one of the following:
- A floating membrane cover
- A cover that is vented through a closed-vent system to an approved control device.
DF.78. (continued)
Verify that the floating membrane cover is designed and operated to meet the
following:
- It is designed to float on the liquid surface during normal operations and form a
continuous barrier over the entire surface area of the liquid
- It is fabricated from a synthetic membrane material that is either high density
polyethylene with a thickness no less than 2.5 millimeters or a material or a
composite of different materials determined to have both organic permeability
properties that are equivalent to the polyethylene and chemical and physical
properties that maintain the material integrity for the intended service life of the
material
- It is installed so that there are no visible cracks, holes, gaps, or other open spaces
between cover section seams or between the interface of the cover edge and its
foundation mountings
- All openings, except for emergency cover drains, are quipped with a closure device
designed to operate so that when the closure device is secured in the closed
position, there are no visible cracks, holes, gaps, or other open spaces in the
closure device or between the perimeter of the cover opening and the closure
device
- The emergency cover drains are equipped with a slotted membrane fabric cover
that covers at least 90 percent of the area of the opening or a flexible fabric sleeve
seal
- The closure device is made of suitable materials to minimize the exposure of the
hazardous waste to the atmosphere and maintain the integrity of the closure
devices through their intended service life.
Verify that, whenever hazardous waste is in the surface impoundment, the floating
membrane cover floats on the liquid and each closure device is secured in the closed
position except for the following:
- To provide access to the surface impoundment for performing routine maintenance,
inspection, or other activities for normal operations
- To remove accumulated sludge or other residues from the bottom of the surface
impoundments
- When necessary to avoid an unsafe condition.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.79. When surface
impoundments use a cover that
is vented through a closed-vent
system to a control device, the
cover is required to meet
specific design standards (40
CFR264.1085(d)(1),
264.1085(d)(2), 265.1086(d)(1),
and265.1086(d)(2)).
(NOTE: These requirements do not apply to a surface impoundment in which an owner
or operator has stopped adding hazardous waste (except to implement an approved
closure plan) and the owner or operator has begun implementing or completed closure
following an approved closure plan (40 CFR 264.1080(b)(4) and 265.1080(b)(4)).)
(NOTE: These requirements do not apply to surface impoundments in which all the
hazardous waste entering the surface impoundment meets one of the following (40
CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste has been reduced by an organic
destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the EPA for the waste in 268.42(a) or an equivalent
method.)
Verify that the cover is vented directly through a closed-vent system to a control device
as follows:
- The cover and the closure devices form a continuous barrier over the entire surface
area of the liquid in the surface impoundment
- Each opening not vented to the control device is equipped with a closure device
- When the pressure in the vapor headspace underneath the cover is less than
atmospheric pressure when the control device is in operation, closure devices are
designed to operate so that when the closure device is secure in the closed
position, there are no visible cracks, holes, gaps, or other open spaces in the
closure device or between the perimeter of the cover opening and the closure
device
- When the pressure in the vapor headspace is equal to or greater than atmospheric
pressure when the control device is operating, the closure device is designed to
operate with no detectable organic emissions
- The cover and its closure devices are made of suitable materials to minimize
exposure of the hazardous waste to the atmosphere, to the extent practical, and
maintains the integrity of the cover and closure devices throughout their intended
life service.
Verify that, when a hazardous waste is in the surface impoundment, the cover is
installed with each closure device secured in the closed position, and the vapor
underneath the cover vented to the control devices except as follows:
- Venting to the control device is not done and opening of the closure devices or
removal is allowed in order to provide access to the surface impoundment for
performing routine inspection, maintenance, or other activities needed for normal
operations
- Venting to the control device is not done and opening of the closure devices or
removal is allowed to remove accumulated sludge or other residues from the bottom
of the surface impoundment
- Opening of safety devices to avoid an unsafe condition.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
60
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.80. Closed-vent systems and
control devices are required to
be designed according to 40
CFR 264.1087 or 265.1088 (40
CFR264.1085(d)(1)(iv),
264.1087, 265.1086(d)(1)(iv),
and 265.1088).
(NOTE: These requirements do not apply to a surface impoundment in which an owner
or operator has stopped adding hazardous waste (except to implement an approved
closure plan) and the owner or operator has begun implementing or completed closure
following an approved closure plan (40 CFR 264.1080(b)(4) and 265.1080(b)(4)).)
(NOTE: These requirements do not apply to surface impoundments in which all the
hazardous waste entering the surface impoundment meets one of the following (40
CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste has been reduced by an organic
destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the EPA for the waste in 268.42(a) or an equivalent
method.)
Verify that closed-vent systems:
- Route the gases, vapors, and fumes emitted from the hazardous waste to a control
device
- Are designed according to 264.1033(k) or265.1033(j) as appropriate
- Are equipped with one of the following when the system includes bypass devices
(except for low leg drains, high point bleeds, analyzer vents, open-ended valves or
lines, spring-loaded pressure relief valves, and other fittings used for safety
purposes) that could be used to divert the gas or vapor stream to the atmosphere:
- a flow indicator at the inlet to the bypass device that indicates whether gas or
vapor flow is present in the bypass device
— a seal or locking device placed on the mechanism by which the bypass device
position is controlled when the bypass device is in the closed position so that the
bypass device cannot be opened without breaking the seal or removing the lock.
Verify that if a control device is used, it is one of the following:
- A control device designed and operated to reduce the total organic content of the
inlet vapor stream vented to the control device by at least 95 percent weight
- An enclosed combustion device (i.e., vapor incinerator, boiler, or process heater),
designed and operated to reduce the organic emissions vented to it by 95 weight
percent or greater, to achieve a total organic compound concentration of 20 ppmv,
expressed as the sum of the actual compounds, not carbon equivalents, on a dry
basis corrected to 3 percent oxygen, or to provide a minimum residence time of
0.50 seconds at a minimum temperature of 760°C [1400°F]
- A flare that:
- is designed and operated with no visible emissions except for periods not in
excess of 5 minutes during any 2 consecutive hours
— is operated with a flame present at all times
— is used only if the net heating value of the gas being combusted is 11.2 MJ/scm
(300 Btu/scf) or greater if the flare is steam-assisted or air-assisted.
- if nonassisted, the net heating value of the gas being combusted is 7.45 MJ/scm
(200 Btu/scf) or greater
— if nonassisted or steam-assisted, has an exit velocity less than 18.3 m/s (60 ft/s)
except when the net heating value of the gas being combusted is greater than
37.3 MJ/scm (1000 Btu/scf) and the exit velocity is equal to or greater than 18.3
m/s (60 ft/s) but less than 122 m/s (400 ft/s).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.80. (continued)
(NOTE: These specifications do not apply during periods of planned routine
maintenance, nor do they apply during control device system malfunctions.)
(NOTE: The performance of each flare will be demonstrated in accordance with 40
CFR 265.1033(e).)
Verify that, when using a closed-vent system and control device, periods of planned
routine maintenance of the control device during which specifications will be exceeded
do not exceed 240 hours/year.
Verify that malfunctions are corrected as soon as is practical.
Verify that closed-vent systems are operated so that gases, vapors, and/or fumes are
not actively vented to the control device during periods of planned maintenance or
control device system malfunctions.
Verify that, when a carbon adsorption system is used, all activated carbon in the
control device is replaced on a regular basis after start-up.
Verify that carbon removed from control devices that is a hazardous waste is managed
in one of the following manners, regardless of the average VOC concentration of the
carbon:
- Regenerated or reactivated in a thermal treatment unit that meets one of the
following:
— the unit has a final permit under 40 CFR 270 which implements the requirements
of 40 CFR 264, subpartX
- the unit is equipped with and operating air emission controls in accordance with
applicable requirements
- Incinerated in a hazardous waste incinerator for which the operator either:
- has a final permit under 40 CFR 270 which implements the requirements of 40
CFR 264, subpartO
— has designed and operates the incinerator in accordance with the interim status
required in 40 CFR 265, subpart O
- Burned in a boiler of industrial furnace for which the operator either:
— has been issued a final permit under 40 CFR 270 implementing 40 CFR 266
- has designed and operates the boiler or industrial furnace in accordance with the
interim status requirements of 40 CFR 266, subpart H.
Verify that operation and maintenance is done in accordance with 264.1033(j) or
265.1033(i) if a control device is used other than a thermal vapor incinerator, flare,
boiler, process heater, condenser, or carbon adsorption system.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.80. (continued)
Verify that achievement of control device performance requirements is demonstrated
by a performance test or design analysis is used for each control device except for the
following:
- A flare
- A boiler or process heater with a design heat input capacity of 44 MW or greater
- A boiler or process heater into which the vent stream is introduced with the primary
fuel
- A boiler of process heater burning hazardous waste for which a final permit has
been issued under 40 CFR 270 and is designed and operated in accordance with
the requirements of 40 CRR 266, subpart H
- A boiler or industrial furnace burning hazardous waste which the owner or operator
has designed and operates in accordance with the interim status requirements of 40
CFR 266, subpart H.
Verify that carbon adsorption systems demonstrate achievement of performance
requirements based on the total quantity of organics vented to the atmosphere from all
carbon adsorption equipment that is used for organic adsorption, organic desorptions
or carbon regeneration, organic recovery, and carbon disposal.
DF.81. Surface impoundments
are required to have enclosed
pipes or other closed systems
for the transfer of hazardous
waste in certain circumstances
(40 CFR 264.1085(e) and
265.1086(e)).
(NOTE: These requirements do not apply to a surface impoundment in which an owner
or operator has stopped adding hazardous waste (except to implement an approved
closure plan) and the owner or operator has begun implementing or completed closure
following an approved closure plan (40 CFR 264.1080(b)(4) and 265.1080(b)(4)).)
(NOTE: These requirements do not apply to surface impoundments in which all the
hazardous waste entering the surface impoundment meets one of the following (40
CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste has been reduced by an organic
destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the EPA for the waste in 268.42(a) or an equivalent
method.)
Verify that transfer of hazardous waste is done using continuous hard piping or
another closed system that does not allow exposure of the waste to the atmosphere.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.82. Facilities are required to
meet inspection and monitoring
requirements and requirements
for the repair of defects
identified in the inspection and
monitoring process for surface
impoundments (40 CFR
264.1085(c)(3), 264.1085(d)(3),
264.1085(f), 264.1085(g),
264.1087(c)(7), 264.1088,
265.1086(c)(3), 265.1086(d)(3),
265.1086(f), 265.1086(g),
265.1088(c)(7), and 265.1089).
(NOTE: These requirements do not apply to a surface impoundment in which an owner
or operator has stopped adding hazardous waste (except to implement an approved
closure plan) and the owner or operator has begun implementing or completed closure
following an approved closure plan (40 CFR 264.1080(b)(4) and 265.1080(b)(4)).)
(NOTE: These requirements do not apply to surface impoundments in which all the
hazardous waste entering the surface impoundment meets one of the following (40
CFR 264.1082(c) and 265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
origination is less than 500 ppmw
- The organic content of the hazardous waste has been reduced by an organic
destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
constituents as specified in 40 CFR 268.40 or has been treated by the treatment
technology established by the EPA for the waste in 268.42(a) or an equivalent
method.)
Verify that the facility has a written plan and schedule for performing inspections and
monitoring.
Verify that, when a floating membrane cover is used, inspection is done as follows:
- Initial visual inspection of the cover and its closure devices to check for defects that
could result in air emissions on or before the date that the surface impoundment
becomes subject to this section
- Annual visual inspection of the cover and its closure devices to check for defects
that could result in air emissions.
Verify that, when a cover vented to a control device is used, inspection is done as
follows:
- Initial visual inspection of the cover and its closure devices to check for defects that
could result in air emissions on or before the date that the surface impoundment
becomes subject to this section
- Annual visual inspection of the cover and its closure devices to check for defects
that could result in air emissions.
(NOTE: After the initial inspection, subsequent inspection and monitoring may be done
at intervals longer than 1 year when inspecting or monitoring the cover would expose a
worker to dangerous, hazardous, or other unsafe conditions as long as there is a
written explanation stating the reasons the cover is unsafe to inspect and there is a
written plan to inspect the cover.)
Verify that, when a defect is identified, the first efforts at repair are made no later than
5 calendar days after detection and repair is completed as soon as possible, but no
later than 45 calendar days after detection.
(NOTE: Repair may be delayed beyond 45 calendar days if the owner or operator
determines that repair requires emptying or temporary removal from service of the
surface impoundment and no alternative capacity is available at the site to accept the
hazardous waste normally managed in the surface impoundment.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.82. (continued)
Verify that each required control device has a device to continuously monitor it as
follows:
- A temperature monitoring device equipped with a continuous recorder for a thermal
vapor incinerator
- A temperature monitoring device equipped with a continuous recorder for a catalytic
vapor incinerator
- A heat sensing monitor with a continuous recorder for flares
- A temperature monitoring device equipped with a continuous recorder to measure a
parameter that indicates good combustion operating practices are being used for a
boiler or process heater having a design heat input capacity less than 44 MW
- For a condenser, one of the following:
— a monitoring device with a continuous recorder to measure the concentration
level of the organic compound in the exhaust vent stream from the condenser
- a temperature monitoring device equipped with a continuous recorder capable of
monitoring temperature in the exhaust vent stream from the condenser with an
accuracy of ± 1 percent of the temperature being monitored in Celsius or in ±
0.5°C, whichever is greater
- For a carbon adsorption system such as a fixed bed carbon adsorber that
regenerates the carbon bed directly in the control device, one of the following:
— a monitoring device equipped with a continuous recorder to measure the
concentration levels of the organic compounds in the exhaust vent stream from
the carbon bed
— a monitoring device equipped with a continuous recorder to measure a
parameter that indicates the carbon bed is regenerated on a regular,
predetermined time cycle.
Verify that the continuous monitoring devices are inspected at least once each
operating day to check control device operation.
Verify that closed-vent systems designed and operated with no detectable emissions,
as indicated by an instrument reading of less than 500 ppm above background, are
monitored as follows:
- An initial leak detection monitoring of the closed-vent system on or before the date
the system becomes subject to this section of the CFR
- Visual inspection according to 40 CFR 264.1034(b)/265.1034(b) at least once a
year for closed-vent system joints, seams, or other connections that are
permanently or semi-permanently sealed (e.g., a welded joint between two sections
of hard piping or a bolted and gasketed ducting flange)
- Annually and at times required by the regulatory agency for all other parts of the
system.
Verify that closed-vent systems designed to operate at no detectable emissions are
monitored as follows:
- Annual visual inspection to check for defects that could result in air pollutant
emissions
- Initial inspection on or before the date the system becomes subject to this section of
the CFR.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
65
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.82. (continued)
(NOTE: For closed-vent systems designed to operate at no detectable emissions,
portions of the system designated as unsafe to monitor are exempt from the visual
monitoring if:
- The components are unsafe to monitor because monitoring personnel would be
exposed to an immediate danger
- A written plan that requires monitoring as practicable during safe to monitor periods
is in place and followed.)
Verify that detectable emissions, as indicated by visual inspection or by an instrument
reading of greater than 500 ppmv above background, are controlled as soon as
practicable but not later than 15 days after the emission is detected.
Verify that a first attempt at repair is made no later than 5 calendar days after the
emission is detected.
(NOTE: Delay of repair of a closed-vent system for which leaks have been detected is
allowed if the repair is technically infeasible without a process unit shutdown, or if it is
determined that the emissions resulting from the immediate repair would be greater
than the fugitive emissions likely to result from delay of repair.)
DF.83. Facilities are required to
meet documentation
requirements for surface
impoundments (40 CFR
264.1089(a), 264.1089(c),
264.1089(e) through
264.1089(h), 265.1090(a),
265.1090(c), and 265.1090(e)
through 265.1090(h)).
Verify that the facility records and maintains the following:
- The surface impoundment identification number (or other unique identification
description as selected by the owner/operator)
- Documentation describing the floating membrane cover or cover design, as
applicable, that includes information prepared by the owner/operator or provided by
the cover manufacturer or vendor describing the cover design, and certification by
the owner/operator that the cover meets specifications
- A record of each required inspection, including the following information:
— date inspection was completed
— for each defect, the location, description of the defect, date of detection, and
corrective action taken.
Verify that the following documentation is kept for closed-vent systems and control
devices:
- Certification that the control device is designed to operate at the necessary
performance level when the surface impoundment is or would be operating at
capacity or the highest level reasonably expected to occur
- Design documentation, if design analysis is used
- A performance test plan, if performance tests are used
- Description and date of each modification
- Identification of operating parameters, description of monitoring devices, and
diagram of monitoring sensor location or locations
- For planned routine maintenance operations where the control device would not
meet requirements, the following semiannually:
- a description of the planned routine maintenance that is anticipated for the next
6-month period
— a description of the planned routine maintenance that was performed during the
previous 6-month period
- the total number of hours that the control device did not meet the requirements of
40 CFR 264.1089(i)(1)/265.1090(l)(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.83. (continued)
- For unexpected malfunctions:
- the duration and occurrence of each malfunction
- the duration of each period during a malfunction when gases, vapors, or fumes
are vented from the waste management unit through the closed-vent system to
the control device while the control device is not properly functioning
- actions taken during periods of malfunction to restore a malfunctioning control
device to its normal or usual manner of operation
- Records of the management of carbon removed from a carbon adsorption system.
Verify that all records, except design information records, are kept for a minimum of 3
years.
Verify that design information records are kept in the operating record until the air
pollution control equipment is replaced or otherwise no longer in service.
Verify that records for exempted facilities are kept as long as the facility is not using air
emissions controls.
Verify that, for exempted facilities, the following information is kept:
- The information used for waste determination in the operating log
- The identification number of the incinerator, boiler, or industrial furnace in which the
hazardous waste is treated.
Verify that, for unsafe to inspect and monitor covers, a record is kept of the
identification numbers of the units and the reasons why the cover is unsafe to monitor
and a plan and a schedule for inspecting and monitoring each cover.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
67
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Waste Piles
DF.84. All waste piles containing
ignitable or incompatible wastes
must follow certain requirements
(40 CFR 264.256, 264.257,
265.256 and 265.257).
Verify that ignitable wastes are not placed into piles unless one of the following is met:
- The waste is treated or rendered, or mixed before or immediately after placement in
the pile so that:
- the waste or mixture no longer meets the definition of ignitable or reactive waste
— there is no generation of extreme heat or pressure, fire or explosions, or violent
reactions
- there is no production of uncontrolled toxic mists, fumes, dusts, or gases in
quantities that would threaten human health or the environment
— there is no production of uncontrolled flammable fumes or gases in quantities
that would pose a risk of fire or explosion
- there is no damage to structural integrity of the device or TSDF
- there is no threat to human health or the environment through other means
- The waste is managed in such a way that it is protected from any material or
conditions that may cause it to ignite or react.
Verify that ignitable or reactive wastes are not placed in waste piles unless the waste
and the waste pile meet the applicable requirements of 40 CFR 268 (see checklist
items under the section "Restricted Wastes").
Verify that incompatible wastes are not placed in the same pile and hazardous waste
is not piled on the same base where incompatible wastes or materials were previously
piled unless the base has been decontaminated and the following are avoided:
- Generation of extreme heat or pressure, fire or explosions, or violent reactions
- Production of uncontrolled toxic mists, fumes, dusts, or gases in quantities that
would threaten human health or the environment
- Production of uncontrolled flammable fumes or gases in quantities that would pose
a risk of fire or explosion
- Damage to structural integrity of the device or TSDF
- Threats to human health or the environment through other means.
Verify that piles of hazardous waste that are incompatible with any waste or other
material stored nearby in other containers, piles, open tanks, or surface
impoundments are separated from the other materials, or protected from them by
means of a dike, berm, wall, or other device.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Land Treatment Units
DF.85. All land treatment
facilities must follow specific
guidelines for ignitable or
reactive wastes and
incompatible wastes (40 CFR
264.281, 264.282; 265.281 and
265.282).
Determine if the land treatment facility handles any ignitable or incompatible waste.
Verify that ignitable or reactive wastes are not land treated unless the waste and the
treatment zone meet all the requirements of 40 CFR 268 (see checklist items under
the section "Restricted Wastes").
Verify that ignitable or reactive waste are not land treated unless:
- The waste is immediately incorporated into the soil so that the resulting mixture no
longer meets the definition of ignitable or reactive waste and the following are
prevented:
- generation of extreme heat or pressure, fire or explosions, or violent reactions
- production of uncontrolled toxic mists, fumes, dusts, or gases in quantities that
would threaten human health or the environment
— production of uncontrolled flammable fumes or gases in quantities that would
pose a risk of fire or explosion
- damage to structural integrity of the device or facility
— threats to human health or the environment through other means, or
— the waste is managed in such a way that it is protected from any materials that
may cause it to react.
Hazardous Waste Landfills
DF.86. All hazardous waste
landfills are required to have a
run-on control system, a runoff
management system and control
the wind dispersal of particulate
matter (40 CFR 264. 301 (g)
through 264.301 (k), 265.301 (f)
through 265.301(1)).
Verify that:
- The run-on control system has the capacity to prevent flow onto the active portion of
the landfill during peak discharge of 25 year storm
- The runoff management system has adequate capacity to collect and control water
from a 24 hour, 25 year storm and the contents tested to determine correct disposal
methodology
- Collection and holding tanks or basins for run-on and runoff control systems are
emptied expeditiously after storms
- There is adequate control of wind dispersal and no blowing debris.
(NOTE: For permitted TSDFs, the permit will specify all design and operating
practices necessary to ensure compliance.)
Closure
OF. 87. TSDFs must comply with
certain closure schedules (40
CFR 264.113(a) through
264.1 13(d), 264.114, 265.1 13(a)
through 265.1 13(d), and
265.114).
Verify that within 90 days after receiving final volume of waste, all hazardous waste
has been treated and removed or disposed of onsite in accordance with the closure
plan.
Verify that partial and final closure activities are completed in accordance with
approved closure plan within 180 days after receiving the final volume of waste.
(NOTE: The regulatory agency may grant variances on the time period.)
(NOTE: During partial and final closure periods all contaminated equipment,
structures and soils must be properly disposed of. By removing any hazardous wastes
or constituents during closure, the TSDF becomes a hazardous waste generator and
is subject to the requirements of 40 CFR 262.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.88. All TSDFs are required to
follow certain notification
procedures for partial and final
closure (40 CFR 264.112(d)(1)
and 265.112(d)(1)).
Verify that TSDFs with surface impoundments, waste piles, land treatment or landfill
units notify the regulatory agency:
- 180 days prior to expected date of beginning closure of the first unit for interim
status TSDFs without an approved closure plan, 60 days with an approved closure
plan
- 60 days prior to expected date of beginning closure for all permitted TSDFs.
Verify that TSDFs with only tanks, containers, or incinerator units notify the regulatory
agency within 45 days prior to the date of beginning final closure.
DF.89. Within 60 days of
completion of closure of each
hazardous waste surface
impoundment, waste pile, land
treatment, and landfill unit,
facilities must submit a
certification of closure to the
regulatory agency (40 CFR
264.115 and 265.115).
Verify that a certification of closure was sent to the regulatory agency by registered
mail.
DF.90. By the time that
certification of closure has been
submitted, TSDFs are required
to submit a survey plat indicating
the location and dimensions of
landfill cells in relationship to
permanently surveyed
landmarks to specific authorities
(40 CFR 264.116 and 265.116).
Verify that a survey plat was submitted to the local zoning authorities or the authority
with jurisdiction over local land use, and the regulatory agency.
DF.91. Post-closure care of
hazardous waste management
units must meet specific
requirements (40 CFR 264.117
and 265.117).
Verify that post-closure care lasts for 30 years after closure and consists of the
following:
- Monitoring and reporting as required in other sections
- Maintenance of waste containment systems
- Use of the property is not allowed to disturb the integrity of the final cover, liner, or
any other components.
Additional Requirements for Permitted TSDFs
General
DF.92. Permitted TSDFs that
receive hazardous waste from
offsite sources must inform the
generator in writing that the
TSDF has the appropriate permit
and will accept the waste (40
CFR264.12(b)).
Verify that notification is sent and a copy is kept in the operating record.
DF.93. Permitted TSDFs that
treat, store, or dispose of
hazardous waste with solid
waste management units are
required to institute corrective
actions as outlined in the permit
to protect human health and the
environment from releases (40
CFR264.90(a)and264.101).
(NOTE: This applies regardless of when the waste was placed in solid waste
management units.)
Verify that corrective actions required by the permit are being done.
(NOTE: The regulatory agency may identify the unit as not having to comply with this
requirement.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.94. Container storage areas
at TSDFs must have a
containment system that meets
specific standards (40 CFR
264.175(a) and 264.175(b)).
Verify that all container storage areas meet the following criteria:
- Containers are stored on a base that is free from cracks or gaps and is impervious
so that leaks, spills, and precipitation are contained
- The base is sloped (or otherwise designed) to drain and remove liquids resulting
from leaks, spills, or precipitation unless the containers are elevated
- Spilled or leaked waste and accumulated precipitation is removed in a timely
manner
- The containment system has adequate capacity to contain 10 percent of the volume
of all the containers or the volume of the largest container, whichever is greater
- Run-on into the containment system is prevented unless the system has sufficient
capacity to contain any run-on that might enter the system in addition to the already
required capacity.
(NOTE: If the collected material is a hazardous waste, it must be handled accordingly.
If it is discharged through a point source, it is subject to the Clean Water Act
requirements.)
DF.95. Containment at permitted
TSDFs for containers holding
wastes that do not contain free
liquids must meet specific
criteria which is lesser than that
for general containment areas
(40CFR264.175(c)).
Verify that one of the following storage area criteria is met:
- The area is sloped or able to drain and remove liquid resulting from precipitation
- Containers are elevated or protected from contact with accumulated liquid.
(NOTE: Storage areas must have complete containment systems when the containers
holding F020, F022, F023, F026, and F027 do not contain free liquids.)
DF.96. When container storage
areas are closed at permitted
TSDFs, specific conditions must
be met (40 CFR 264.178).
Verify that closure criteria were met:
- All hazardous waste and residues were removed from the containment system
- Remaining containers, liners, bases, and soils (containing or contaminated with
hazardous waste or hazardous waste residues) were decontaminated or removed
- All hazardous wastes (including materials removed from the containment system)
were managed appropriately.
DF.97. The facility should
develop a formal groundwater
protection program which
includes groundwater
monitoring, documentation,
recordkeeping and standard
operating procedures for
groundwater related activities
(e.g., drilling, well inspection and
maintenance, etc.) (MP).
Confirm that facility standard operating procedures exist for
- Drilling
- Well construction
- Management and disposal of investigation derived waste (e.g., borehole cuttings,
development water and purge water, and drilling fluid)
- Well inspection and maintenance
- Groundwater and soil sampling, preservation and shipment and chain of custody
control
- Well abandonment
- Data management.
Verify that the facility developed and maintains documentation relating to
hydrogeologic characterization which includes the definition and description of site
geology and hydrology including identification of aquifers, and surface
water/groundwater relationships.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
(NOTE: DF.98 through DF. 103 describe the requirements for groundwater programs pursuant to 40 CFR 264 Subpart F,
Releases from Solid Waste Management Units, such as surface impoundments, waste piles, land treatment units, or
landfill units which have received waste after July 26, 1982 (40 CFR 264.90(a)(2)).)
DF.98. Facilities are required to
conduct a monitoring and
response program (40 CFR
264.91).
Verify that the facility conducts the following monitoring and response activities as
applicable:
- At a minimum, the facility must institute a detection monitoring program as
described in DF.101
- Whenever hazardous constituents are detected at statistically significant
concentrations at a compliance point, the facility must institute a compliance
monitoring program as described in DF.102
- Whenever the groundwater protection standard is exceeded or hazardous
constituents exceed concentration limits beyond the point of compliance, the facility
must institute a corrective action program as described in DF.103.
DF.99. The facility must comply
with the conditions specified in
the facility permit meant to
ensure that hazardous
constituents under 40 CFR
264.93 detected in the
groundwater do not exceed the
concentration limits under 40
CFR 264.94 in the uppermost
aquifer underlying the waste
management area beyond the
point of compliance under 40
CFR 264.95 (40 CFR 264.92).
Review the facility permit and determine whether the groundwater protection standards
set forth are addressed in the facility's groundwater protection program. The
groundwater protection standards should include at least the following parts:
- The identification of hazardous constituents listed in Appendix VIII of 40 CFR 261
that have been detected in the groundwater from the facility
- Concentration limits for the hazardous constituents identified
- The point of compliance at which monitoring must be conducted
- The compliance period during which the groundwater protection standard applies.
DF.100. Facilities must comply
with the requirements in 40 CFR
264.97 for any groundwater
monitoring program developed
to satisfy 40 CFR 264.98,
264.99, or 264.100 (40 CFR
264.97).
If there is a possibility of hazardous constituents in the groundwater, ensure that the
following activities are added to the groundwater monitoring plan:
- For each hazardous constituent in each well, one of the statistical methods
described in 40 CFR 264.97(h) for evaluating monitoring data has been chosen by
the facility, approved by the regulatory agency, and complies with the performance
standards in 40 CFR 264.97(1)
- All groundwater monitoring data collected is maintained in the facility operating
record and submitted for review as required by the regulatory agency
- The program includes sampling and analytical procedures that are appropriate and
accurately measure hazardous constituents in groundwater samples
- An appropriate method for determining background water quality has been selected
and background groundwater quality has been determined.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.101. Facilities required to
establish a detection monitoring
program under 40 CFR 264
Subpart F must, at a minimum,
comply with 40 CFR 264.98 (40
CFR 264.98).
If the facility is required by the regulatory agency to establish a detection monitoring
program, ensure that the following activities are included in the groundwater
monitoring plan:
- Monitoring for indicator parameters (e.g., specific conductance, total organic
carbon, or total organic halogen), waste constituents, or reaction products that
provide a reliable indication of the presence of hazardous constituents in the
groundwater
(NOTE: The regulatory agency will specify the parameters or constituents to be
monitored and their frequency for collection and statistical analysis in the facility
permit (40 CFR 264.98(a) and 264.98(d).)
- Determination of the groundwater flow rate and direction in the uppermost aquifer,
at least annually
- Determination of whether statistically significant evidence of contamination exists
and if it does exist, the following steps are taken:
(NOTE: If statistically significant evidence of contamination exists but, may have
been caused by contamination from another source or by an error in sampling, then
the facility must demonstrate that to the regulatory agency. Note also that facility
permits may provide additional time for resampling after an indication of a
groundwater release.)
- the regulatory agency is notified in writing within seven days
— the groundwater is immediately sampled in all monitoring wells to determine if
any constituents in Appendix IX of 40 CFR 264 are present, and if so, in what
concentration.
(NOTE: If Appendix IX constituents are present in the sample then the following
activities are required:
- An application for a permit modification to establish a compliance monitoring
program is submitted within 90 days to the regulatory agency
- An engineering feasibility plan for corrective action and all data necessary to justify
any alternative concentration limits are submitted to the regulatory agency within
180 days.)
DF.102. Facilities required to
establish a compliance
monitoring program under CFR
264 Subpart F must, at a
minimum, comply with 40 CFR
264.99 (40 CFR 264.99).
If the facility is required to establish a compliance monitoring plan, verify that the plan
contains procedures for the following activities to be done in conjunction with the
groundwater monitoring plan:
- Determination of whether any significant evidence of increased contamination exists
and if it does exist, the following steps are taken:
— the regulatory agency is notified in writing which limits are exceeded within seven
days
- an application for a permit modification to establish a corrective action program is
submitted to the regulatory agency within 180 days.
(NOTE: If statistically significant evidence of increased contamination exists but, may
have been caused by contamination from another source or by an error in sampling,
then the facility must demonstrate that to the regulatory agency. Note also that facility
permits may provide additional time for resampling after an indication of a groundwater
release.)
DF.103. Facilities required to
establish a corrective action
program under 40 CFR 264
Subpart F must, at a minimum,
comply with 40 CFR 264.100 (40
CFR 264.100).
If the facility is required to establish a corrective action program, determine whether
the following procedures are in place in addition to the groundwater monitoring plan:
- The facility either removes hazardous waste constituents or treats them in place to
prevent the constituents from exceeding their respective concentration limits. The
permit will specify the specific measures that will be taken
- The facility establishes a groundwater monitoring program to evaluate the
effectiveness of the corrective action program and submits the results of the
evaluation semi-annually in a written report to the regulatory agency.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.104. TSDFs operating
corrective actions programs are
required to report semi-annually
to the regulatory agency on their
effectiveness (40 CFR
264.100(g)).
Determine if the TSDF operates a corrective action program.
Verify that a semi-annual progress report is sent to the regulatory agency.
DF.105. TSDFs that are seeking
a permit for the treatment,
storage, or disposal of
hazardous waste must initiate
the corrective actions needed to
protect human health and the
environment from all releases of
hazardous waste of constituents
from any solid waste
management unit, regardless of
when the waste was placed in
the unit (40 CFR 264.101).
Verify that the corrective actions specified in the permit are being done and the
compliance schedule is being met.
(NOTE: As a part of the corrective action program the regulatory agency may
designate an area of the TSDF as a Corrective Action Management Unit (CAMU) or a
Temporary Unit (TU).)
DF.106. All permitted TSDFs are
required to document
compliance with ignitable,
reactive, or incompatible waste
management requirements (40
CFR264.17(c)).
Verify that compliance documentation is maintained at the TSDF. Such documentation
may be based on published scientific or engineering literature, data from field tests, or
the results of the treatment of similar wastes by similar treatment processes or similar
operating conditions.
DF.107. Permitted TSDFs with
process vents associated with
distillation, fractionation, thin film
evaporation, solvent extraction,
or air or steam stripping
operations that manage
hazardous wastes with organic
concentrations of at least 10
ppmw are required to submit a
semi-annual report concerning
process vent emissions (40 CFR
264.1036).
Verify that a semi-annual report is submitted to the regulatory agency and that it
includes the following:
- The EPA identification number, name, and address of the TSDF
- Dates when the control device exceeded or operated outside of design specification
and the exceedences were not corrected within 24 hours
- Dates when a flare operated with visible emissions
- The duration and cause of exceedences and corrective measures taken
(NOTE: If there are no exceedences a report is not required.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.108. Permitted facilities are
required to meet specific
reporting requirements as
related to air emissions controls
(40 CFR 1090(a), 264.1090(c),
and264.1090(d)).
Verify that a written report is submitted to the regulatory agency within 15 days of
becoming aware that hazardous waste is being managed in an exempted container in
noncompliance with the applicable design and operating requirements.
Verify that, in regard to required control devices, a semiannual written report is
submitted to the regulatory agency describing each occurrence of noncompliance
during the previous 6 months when either of the following occurred:
- A control device is operated continuously for 24 hours or longer in noncompliance
with the applicable operating values
- A flare is operated with visible emissions for 5 minutes or longer in a 2-hour period.
Verify that the report contains an explanation of why the control device could not be
returned to compliance within 24 hours and actions taken to correct noncompliance.
(NOTE: The semiannual report is not required for a 6-month period if all control
devices are operated so there is not a period of 24 hours or longer in which the control
device was in continuous noncompliance and no flare was operated with visible
emissions for 5 minutes or longer in a 2-hour period.)
(NOTE: If the facility received its permit under RCRA Section 3005 prior to 6
December 1996, these requirements will be incorporated in the permit when it is
reviewed. Until that time, the TSDF is required to comply with 40 CFR 265 Subpart
CC (40 CFR 264.1080(c) and 265.1080(c)).)
Surface Impoundments
DF.109. Permitted surface
impoundments must be
designed according to specific
parameters (40 CFR 264.221 (a)
264.221 (g) through 264.221(1)).
Determine if the TSDF has a permitted surface impoundment constructed before July
29, 1992. If so, the following items should be assessed:
Verify that surface impoundments have a liner for all portions of the impoundment.
Verify that the impoundment is designed, constructed, maintained, and operated to
prevent overtopping, overfilling, wind and wave action, rainfall, run-on, malfunctions of
level controllers, alarms and other equipment, and human error.
Verify that the impoundment has dikes that are designed and constructed and
maintained to prevent massive failure of the dikes.
(NOTE: The regulatory agency will specify in the permit all design and operating
practices that are necessary.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.110. New permitted surface
impoundments that started
construction after January 19,
1992, lateral expansions of
permitted surface
impoundments which started
construction after July 29, 1992,
and replacements of existing
surface impoundments where
reuse started after July 29,
1992, are required to meet
specific design and operating
criteria. (40 CFR 264.19,
264.221 (c) through 264.221 (f),
264.222, 264.223, and
264.226(d)).
Verify that the impoundment has two or more liners and a leachate collection and
removal system between liners, or the double liner requirement has been waived by
the regulatory agency.
Verify that the liner meets the specifications stated in 40 CFR 264.221 (c).
Verify that the TSDF has a Construction Quality Assurance (CQA) program to ensure
that constructed units meet or exceed all design criteria and specifications in the
permit.
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that these surface impoundments comply with the action leakage rate assigned
by the regulatory agency.
Verify that the surface impoundment facility has an approved response action plan
prior to the receipt of waste.
Verify that the amount of liquid removed from each leak detection system sump is
recorded at least once a week during the active life and closure period.
Verify that after a final cover is installed, the amount of liquids removed from each leak
detection system sump is recorded at least monthly or:
- If the liquid level in the sump stays below the pump operating level of two
consecutive months, then the liquid amounts may be recorded quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, then the liquid amounts may be recorded semiannually.
(NOTE: TSDFs with replacement surface impoundments may be exempt from these
requirements if the existing unit was constructed in compliance with the design
standards of sections 3004(o)(1 )(A)(i) and (o)(5) of RCRA and there is no reason to
believe the liner is not functioning as designed.)
DF.111. Permitted TSDFs must
inspect liners and cover systems
during construction and
installation of liners (40 CFR
264.226(a)).
(NOTE: This excludes existing portions of surface impoundments exempt from
264.221(a).)
Verify that liners and covers are inspected for uniformity, damage, and imperfections.
DF.112 TSDFs must conduct
inspections while surface
impoundments are in operation
(40 CFR 264.226(b)).
Verify that inspections are conducted at least weekly and after storms to detect
evidence of the following:
- Deterioration, malfunctions, or improper operation of overtop piping control systems
- Sudden drops in the level of the impoundment contents
- Severe erosion or other signs of deterioration in dikes or other containment devices.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.113. Prior to the issuance of
a permit and/or after any period
of greater than six months of
disuse, the TSDF must obtain
certification from a qualified
engineer that surface
impoundment dikes have
structural integrity (40 CFR
264.226(c)).
Determine if the TSDF is permitted or if any impoundment has been out of service for
six months or more.
Verify that the certification of structural integrity includes:
- Verification that the impoundment can withstand the amounts and types of waste it
will contain
- That without dependence on any liner system the impoundment will not fail due to
scouring or piping.
DF.114. TSDFs must follow
specific restrictions concerning
the types of wastes placed in
permitted surface
impoundments (40 CFR
264.231).
Verify that hazardous wastes F020, F021, F022, F023, F026, and F027 are not placed
in the impoundment unless it is done according to a management plan approved by
the regulatory agency.
DF.115. Permitted surface
impoundments are required to
be removed from service under
specific circumstances (40 CFR
264.227(a)).
Verify that surface impoundments have been removed from service if any of the
following circumstances exist:
- The level of liquid suddenly drops and the drop is not known to be cause by changes
in flow
- The dike leaks.
DF.116. In order to remove a
permitted surface impoundment
from service, specific
parameters have to be met (40
CFR 264.227(b), 264.227(c),
and 264.227(e)).
Verify that when a surface impoundment is removed from service the following
requirements are met:
- The flow or addition of waste is immediately shut off or stopped
- Surface leakage is immediately contained
- Leaks are stopped or the impoundment is emptied
- The regulatory agency is notified within seven days of problems.
Verify that the contingency plan specifies a procedure for taking a surface
impoundment out of service.
Verify that if a surface impoundment is removed from service and it is not being
repaired, it is closed.
DF.117. Surface impoundments
may not be restored to service
unless specific standards are
met (40 CFR 264.227(d)).
Verify that prior to being returned to service the following is done:
- The portion of the impoundment that was failing is repaired
- The dike is recertified if the reason for removal from service was faulty dike integrity
- Liners are correctly installed and operating.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.118. TSDFs that have
surface impoundments must
follow certain closure and post-
closure requirements (40 CFR
264.228(a) and 264.228(b)).
Determine if the TSDF has closed or plans to close any surface impoundments.
Verify that at closure the TSDF does one of the following:
- Removes or decontaminates all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated
with waste and leachate and manages them as hazardous waste
- Eliminates the free liquids by removing liquid wastes or solidifying the remaining
wastes and water residue and stabilizes remaining wastes to a bearing capacity
sufficient to support final cover and cover the surface impoundment with a final cover
designed and constructed to:
-provide long-term minimization of the migration of liquids
-function with minimum maintenance
— promote drainage and minimized erosion or abrasion of the final cover
— accommodate settling and subsidence so that the cover's integrity is maintained
- have a permeability less than or equal to the permeability of any bottom liner
system or natural subsoils present.
Verify that if waste residues or contaminated materials are left in place, the TSDF
meets post-closure requirements outlined in 40 CFR 264.117 through 264.120 and:
- Maintains the integrity and effectiveness of the final cover
- Maintains and monitors the leak detection system
- Maintains and monitors the groundwater monitoring system
- Prevents run-on and runoff from eroding or otherwise damaging the final cover.
DF.119. Facilities are required to
meet specific reporting
requirements as related to air
emissions (40 CFR 264.1090(a),
264.1090(c), and 264.1090(d)).
Verify that a written report is submitted to the regulatory agency within 15 days of
becoming aware that hazardous waste is being managed in an exempted surface
impoundment in noncompliance with the applicable design and operating
requirements.
Verify that, in regard to required control devices, a semiannual written report is
submitted to the regulatory agency describing each occurrence of noncompliance
during the previous 6 months when either of the following occurred:
- A control device is operated continuously for 24 hours or longer in noncompliance
with the applicable operating values
- A flare is operated with visible emissions for 5 minutes or longer in a 2-hour period.
Verify that the report contains an explanation of why the control device could not be
returned to compliance within 24 hours and actions taken to correct noncompliance.
(NOTE: The semiannual report is not required for a 6-month period if all control
devices are operated so there is not a period of 24 hours or longer in which the control
device was in continuous noncompliance and no flare was operated with visible
emissions for 54 minutes or longer in a 2-hour period.)
(NOTE: If the facility received its permit under RCRA Section 3005 prior to 6
December 1996, these requirements will be incorporated in the permit when it is
reviewed. Until that time, the TSDF is required to comply with all 40 CFR 265, Subpart
CC(40CFR 165.1080(c).)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Waste Piles
DF.120. Permitted TSDFs that
store or treat hazardous waste in
waste piles must meet specific
design and operating standards
(40 CFR 264.250 and
264.251(a), 264.251(b), and
264.251 (g) through 264.251 (k)).
(NOTE: Waste piles closed with wastes left in place are regulated as landfills. Waste
piles inside or under a protective structure are exempt from the standards in 40 CFR
264.250 through 264.259 if they contain no liquids, are protected from run-on, are
designed and operated to control dispersal of waste by wind, and do not generate
leachate through decomposition or other reactions.)
Determine if the TSDF treats or stores hazardous waste in waste piles.
Verify that the following standards are met for each waste pile:
- The pile has a liner and is located on a foundation that provides support
- The liner is installed to cover all surrounding earth likely to be in contact with the
waste or leachate
- A leachate collection and removal system is located immediately above the liner
- Leachate depth over the liner does not exceed 30 cm (1 ft.)
- Protection from wind and run-on is provided
- A runoff management system is in place and in operating condition
- Tanks and basins associated with the run-on and runoff control systems are
emptied.
(NOTE: The permit will designate all design and operating practices necessary to
ensure that the requirements are satisfied.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.121. Permitted waste piles
constructed after January 29,
1992, lateral expansions that
started after July 29, 1992, and
replacement of existing waste
piles where reuse started after
July 29, 1992, are required to
meet specific design and
operating requirements (40 CFR
264.19, 264.251 (c) through
264.251 (f), 264.252, 264.253).
Verify that the described waste piles have two or more liners and a leachate collection
and removal system above and between the liners.
Verify that the liner is designed and constructed of materials to prevent the migration
of hazardous constituents into the liner during the active life and post-closure care
period.
(NOTE: See 40 CFR 264.251 (c)(1) and 264.251 (c)(2) for details on the design of the
liner and the leachate collection system.)
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit.
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that the pumpable liquids in the leak detection sumps are removed to minimize
the head on the bottom liner.
Verify that the TSDF is complying with the action leakage rate assigned by the
regulatory agency.
Verify that the TSDF has an approved response action plan prior to the receipt of
waste.
(NOTE: The regulatory agency may approve alternative designs or grant a waiver.)
DF.122. TSDFs must conduct
inspections of permitted waste
piles during construction and
while they are in operation (40
CFR 264.254).
Verify that if construction of a waste pile is occurring at the TSDF the following are
taking place:
- Liners and cover systems are inspected for uniformity, damage, and imperfection
- Synthetic liners and covers are inspected for tight seams and joints immediately
after construction
- Soil based and admixed liners and covers are inspected for imperfections
Verify that the waste pile is inspected at least weekly and after storms to detect
evidence of the following:
- Deterioration, malfunctions, or improper operation in run-on and runoff systems
- Proper functioning of wind dispersal control system
- Presence of leachate in, and proper functioning of leachate control system.
Verify that the amount of liquids removed from each leak detection system is recorded
at least once a week during the active life and closure period.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
DF.123. TSDFs that treat F020,
F021, F022, F023, F026, and/or
F027 in permitted waste piles
are required to follow specific
operating procedures (40 CFR
264.259).
DF. 124. TSDFs that operate
permitted waste piles must
follow specific requirements for
closure and post-closure care
(40 CFR 264.258).
Reviewer Checks:
Determine if the TSDF treats F020-F023, F026, or F027.
Verify that these wastes are kept in enclosed piles unless the owner/operator has a
management plan approved by the regulatory agency.
Verify that at the time of closure all waste residues, contaminated containment system
components, subsoils, and structures and equipment contaminated with hazardous
waste have been removed or decontaminated.
Verify that if all contaminated subsoils cannot be removed or decontaminated
practicably, then the site is closed and managed according to closure and post-closure
care requirements for a landfill.
Verify that if the TSDF has a waste pile that does not comply with the liner
requirement, and is not exempted from this requirement, they comply with the
following:
- The written closure plan addresses the removal of all contaminated substances and
a contingency plan if all contamination cannot be removed from the pile
- A contingency post-closure plan is prepared for the waste pile and be submitted to
the appropriate agency within 90 days after determining the waste pile must be
closed.
Land Treatment Units
DF.125. TSDFs with permitted
hazardous waste land treatment
units must meet certain
standards (40 CFR 264.270
through 264.273(f)).
DF.126. TSDFs must conduct
inspections while land treatment
facilities are in operation (40
CFR264.273(g)).
Determine if the TSDF operates a land treatment facility.
Verify that the following standards are met at each permitted hazardous waste land
treatment unit:
- The treatment zone is no more than 1.5 m (5 ft.) from the initial soil surface
- The treatment zone is more than 1 m (3 ft.) above the seasonal high water table
- Only wastes with hazardous constituents that can be degraded, transformed, or
immobilized are placed in the treatment zone
- Run-on control systems are operated to prevent flow onto the treatment zone during
peak discharge from at least a 25 year storm
- Tanks and basins associated with the run-on and runoff control systems are
emptied or otherwise managed after storms
- Wind dispersal is controlled.
(NOTE: The regulatory agency will specify in a permit the exact elements of the
treatment program.)
Verify that the land treatment system is inspected weekly and after storms to detect
evidence of:
- Deterioration, malfunctions, or improper operation of run-on and runoff control
systems
- Improper functioning of wind dispersal control measures.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.127. TSDFs with food chain
crops grown in or on the
treatment zone are required to
meet specific operational
standards (40 CFR 264.276).
Determine if food chain crops are grown in or on the treatment zone.
Verify that prior to the growth of food chain crops in or on the treatment zone, it has
been demonstrated that there is no substantial risk to human health caused by the
growth of the crops by demonstrating that hazardous constituents other than cadmium
meet one of the following:
- Will not be transferred to the food or feed portions of the crop by plant uptake or
direct contact, and will not otherwise be ingested by food chain animals
- Will not occur in greater concentrations in or on food of feed portions of the crops
grown on untreated soils under similar conditions in the same region.
Verify that if food chain crops are grown, only those specified in the permit by the
regulatory agency are being grown.
Verify that if cadmium-containing wastes are applied to food chain crops in or on
treatment zones, the following are met:
- The pH of the waste and soil mixture is 6.5 or greater at the time of application,
except in cases where the waste contains cadmium at concentrations of 2 mg/kg or
less
- The annual application of cadmium from waste does not exceed 0.5 kg/ha on land
used for production of tobacco, leafy vegetables, root crops grown for human
consumption, or other food chain crops
- The cumulative application of cadmium from waste does not exceed 5 kg/ha if the
waste and soil mixture has a pH less than 6.5
- If the waste and soil mixture has a pH of 6.5 or greater or is maintained at a pH of
6.5 or greater during crop growth, then one of the following must be met:
— the cumulative application of cadmium from waste does not exceed 5 kg/ha if soil
cation exchange capacity is less than 5 meq/100 g
- the cumulative application of cadmium from waste does not exceed 10 kg/ha if
soil cation exchange capacity is 5 to 15 meq/100 g
— the cumulative application of cadmium from waste does not exceed 20 kg/ha if
soil cation exchange capacity is greater than 15 meq/100 g
- animal feed is the only food chain crop produced.
DF.128. Permitted land
treatment units must have an
unsaturated zone monitoring
program (40 CFR 264.278).
Verify that the unsaturated zone monitoring program meets the following:
- The soil and soil-pore liquid are monitored to determine if hazardous constituents
migrate out of the treatment zone
- A system is installed that includes soil monitoring using soil cores and soil-pore
liquid monitoring using devices such as lysimeters
- A background value has been established for each hazardous constituent to be
monitored (see permit)
- The soil monitoring and soil-pore liquid monitoring is done immediately below the
treatment zone
- Consistent sampling and monitoring procedures are used.
Verify that the contaminants listed in the permit are being monitored.
Verify that when it is found that there is a statistically significant increase of hazardous
constituents below the treatment zone the following steps are taken:
- The regulatory agency is notified in writing within seven days
- Within 90 days a permit application is submitted to the regulatory agency for a
permit modification to modify the operating practices.
DF.129. Land treatment facilities
must keep an operating record
that includes dates and rates of
application (40 CFR 265.279).
Verify that the operating record contains the dates and rates of applications.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF. 130. All land treatment
facilities are required to meet
specific closure and post-closure
plans (40 CFR 264.280).
Verify that during the closure period the following requirements are met:
- All operations are continued as necessary to maximize degradation, transformation,
or immobilization of hazardous constituents in the treatment zone
- Runoff is minimized
- Run-on and runoff management systems are maintained
- Wind dispersal of hazardous waste is controlled
- Compliance with food chain crop prohibitions is continued
- Unsaturated zone monitoring is continued except that soil-pore liquid monitoring
may be terminated 90 days after the last application of waste to the treatment zone
- A vegetative cover is established on the portion of the land treatment facility being
closed when the cover will not substantially impede degradation, transformation, or
immobilization of hazardous constituents.
Verify that when closure is completed, certification by an independent qualified soil
scientist or independent registered professional engineer was submitted to the
regulatory agency that the facility has been closed according to the specifications of
an approved closure plan.
Verify that during the post-closure period:
- Operations are continued to enhance degradation, transformation, and sustain
immobilization of hazardous constituents in the treatment zone
- A vegetative cover is maintained
- Run-on control systems are maintained
- Runoff management systems are maintained
- Wind dispersal of hazardous waste is controlled
- Food chain crop prohibitions are met
- Unsaturated zone monitoring is continued except that soil-pore liquid monitoring
may be terminated 90 days after the last application of waste to the treatment zone.
(NOTE: The TSDF may not be required to establish a vegetative cover or meet post-
closure requirements if the regulatory agency finds that the level of hazardous waste
constituents in the treatment soil zone does not exceed the background value of those
constituents by an amount that is statistically significant.)
DF.131. Hazardous wastes
F020 through F023, F026, and
F027 must not be placed in a
land treatment facility unless it is
done according to an approved
management plan for these
wastes (40 CFR 264.283).
Verify that these wastes are only place in a land treatment unit according to the
requirements of the approved waste management plan.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Hazardous Waste Landfills
DF.132. Permitted hazardous
waste landfills are required to
have a liner and a leachate
collection and removal system
(40 CFR 264.301(a) through
264.301(b)).
Determine if the TSDF disposes of hazardous wastes in an onsite landfill.
Verify that the landfill liner is:
- Designed, constructed, and installed to prevent any migration of waste out of the
landfill
- Placed on a properly supported base or foundation
- Installed to cover all surrounding earth likely to be in contact with the waste.
Verify that the leachate collection and removal system is immediately above the liner
and will operate to remove leachate from the landfill.
Verify that collected leachate is tested to determine correct disposal methodology.
(NOTE: The permit will contain specific design and operating conditions.)
DF.133. New landfills on which
construction started after
January 29, 1992, lateral
expansions which started
construction after July 29, 1992,
and each replacement of an
existing landfill that will start
reuse after July 29, 1992, are
required meet specific design
and operating standards (40
CFR 264.19, 264.301 (c) through
264.301 (f), 264.302, 264.304).
Determine if the TSDF has any landfills meeting the stated criteria.
Verify that the landfill has two or more liners and a leachate collection and removal
system above and between the liners or a waiver of double liner requirement has been
obtained from the regulatory agency.
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit.
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that the pumpable liquids in the leak detection system sumps are collected and
removed to minimize the head on the bottom liner.
Verify that surface impoundments subject to these landfill requirements meet the
action leakage rate set by the regulatory agency.
Verify that the TSDF has an approved response action plan before the receipt of
waste.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.133. (continued)
Verify that if the flow rate into the leak detection system exceeds the action leakage
rate for any sump:
- The regulatory agency is notified within seven days
- A written notification is submitted within 14 days
- To the extent practicable, the location, size and cause of any leak is determined
- A determination is made as to whether waste receipt should be stopped or
restricted
- The regulatory agency is notified of actions taken and actions to be taken within 30
days after discovery
- A monthly report is submitted to the regulatory agency as long as the flow rate in
the leak detection systems exceeds the action leakage rate.
(NOTE: These restrictions do not apply if the existing unit was constructed in
accordance with the design standards of section 3004(o)(1 )(A)(i) and (o)(5) of RCRA
and there is no reason to believe that the liner is not functioning as designed.)
DF.134. Hazardous waste
landfills are required to be
inspected (40 CFR 264.303).
Verify that liners were inspected during construction for overall integrity.
Verify that immediately after construction was completed, the following inspections
were performed:
- Synthetic liners and covers to ensure tight seams and joints and absence of tears
- Soil-based and admixed liners for imperfections that may increase impermeability
(e.g., cracks and root-holes).
Verify that while a landfill is in operation it is inspected weekly and after storms to
detect evidence of the following:
- Deterioration, malfunctions, or improper operations of run-on and runoff control
systems
- Proper functioning of wind dispersal control systems where present
- The presence of leachate in and proper functioning of the leachate collection
system.
Verify that the amount of liquid removed from each leak detection sump is recorded at
least once a week during the active life of the landfill and closure period.
Verify that after a final cover is installed, the amount of liquids removed from each leak
detection system sump is recorded at least monthly or:
- If the liquid level in the sump stays below the pump operating level for two
consecutive months, the liquid amounts are recorded quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, the liquid amounts are recorded semi-annually.
DF.135. TSDFs with permitted
hazardous waste landfills are
required to meet specific
standards for hazardous wastes
F020, F021, F022, F023, F026,
and F027 (40 CFR 264.317).
Determine whether or not these wastes are landfilled at the disposal facility.
Verify that if they are landfilled, the TSDF has a management plan for their disposal
that is approved by the regulatory agency.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Incinerators
DF.136. TSDFs with permitted
hazardous waste incinerators
must comply with certain
operating requirements (40 CFR
264.340 (a) through 264.340(c)
and 264.341 through
264.344(a), 264.345, and
264.347).
Determine if specific wastes (principal organic hazardous constituents (POHC)) are
specified in the permit.
Verify that only the wastes listed in the permit are burned, and only under the
operating conditions set forth in the permit.
Verify that sufficient waste analyses are conducted throughout normal operations to
ensure that waste feed is within the limits specified in the permit.
Verify that for each waste specified in the permit, the incinerator achieves a
destruction and removal efficiency (ORE) of 99.99 percent.
Verify that the ORE for all wastes incinerated is determined by the following equation:
(W -W )
^ in outjx100%
where:
Win = mass feed rate of one POHC in the waste stream feeding the incinerator
Wouf = mass emissions rate of the same POHC present in the exhaust
emissions.)
Verify that when EPA Hazardous Waste Numbers F020 through F023, F026, or F027
are incinerated a ORE of 99.9999 percent is achieved and the regulatory agency is
notified of the intent to burn.
DF.137. Permitted hazardous
waste incinerators are required
to meet specific emission
standards (40 CFR 264.343(b)
and 264.343(c)).
Determine if the incinerator produces stack emissions of hydrogen chloride (HCI).
Verify that if HCI emissions exceed 1.8 kg/hr (4 Ib/h), the emissions are controlled so
that the rate of emission is no greater than the larger of either 1.8 kg/hr (4 Ib/h) or 1
percent HCI in the stack gas prior to entering any pollution control equipment.
Verify that particulate matter no greater than 180 mg/dscm is emitted.
(NOTE: Compliance with operating requirements established in the permit will be
regarded as compliance with 40 CFR 262.343 (i.e., only the wastes listed in the permit
are burned, and only under the operating conditions set forth in the permit (see 40
CFR264.343(d))).)
DF.138. Operators of
incinerators must conduct
monitoring while incinerating
hazardous waste (40 CFR
264.347).
Verify that the operator monitors, at a minimum, the following at the indicated intervals:
- Waste feed rate, combustion temperature, specified indicator of combustion gas
velocity, CO (prior to release): continuously
- The incinerator and associated equipment for leaks, spills etc.: daily
- The emergency waste feed cutoff system and associated emergency cutoff alarms:
weekly.
Verify that any other monitoring required in the permit is conducted.
Verify that monitoring and inspection data are recorded and the records placed in the
operating log.
(NOTE: Upon request by the regulatory agency, sampling and analysis of the waste
and exhaust emissions must be conducted to verify that the operating requirements
established in the permit achieve the performance standards of 40 CFR 264.343 (see
40CFR264.347(a)(3)).)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.139. When permitted
hazardous waste incinerators
are closed all hazardous waste
and hazardous waste residues
must be removed (40 CFR
264.351).
Verify that all hazardous wastes and hazardous waste residues, including ash,
scrubber waters, and scrubber sludges, are removed from the incinerator site.
Miscellaneous Units
(NOTE: The open burning/open detonation (OB/OD) of waste explosives at permitted TSDFs is done under the
classification of miscellaneous unit. This is also sometimes referred to as a Subpart X Permit.)
DF.140. TSDFs that treat, store,
or dispose of hazardous wastes
in permitted miscellaneous units
must comply with specific
environmental performance
standard requirements (40 CFR
264.601).
Determine whether the TSDF treats, stores, or disposes of any hazardous waste in
miscellaneous units.
Verify that miscellaneous units are located, designed, constructed, operated,
maintained, and closed in a manner that will ensure protection of human health and
the environment, including:
- Prevention of any release due to migration in the surface water, wetlands, or the soil
surface, taking in to consideration:
— volume and physical and chemical characteristics of the waste in the unit
— the effectiveness of containing, confining, and collection systems and structures
in preventing migration
- the hydrologic characteristics of the unit and surrounding area, including the
topography of the land around the unit
— regional patterns of precipitation
- existing quality, quantity, and direction of groundwaterflow
- the proximity of the unit to surface waters
— the current and potential uses of nearby surface waters and any water quality
standards established for those surface waters
- the existing quality of surface waters and surface soils including other sources of
contamination and their cumulative impact
— regional pattern of land use
— potential health risks caused by human exposure to the waste
- potential for damage from exposure to domestic animals, wildlife, crops,
vegetation, and physical structures.
- Prevention of any release that may have adverse affects on human health or the
environment due to migration of waste constituents in the groundwater or
subsurface environment, taking in to consideration:
- volume, physical, and chemical characteristics of waste including its potential for
migration through soil, liners, or other containing structures
— the hydrological and geological characteristics of the unit and surrounding area
- existing quality of groundwater including other sources of contamination and their
cumulative impact on the groundwater
— the quantity and direction of groundwater flow
— proximity to and withdrawal rates of current and potential groundwater users
- regional pattern of land use
- potential for deposition or migration of waste into subsurface physical structures,
and the root zone of food-chain crops and other vegetation
— potential health risks caused by human exposure to the waste
- potential for damage from exposure to domestic animals, wildlife, crops,
vegetation, and physical structures
— regional pattern of precipitation.
Verify that miscellaneous units are designed and operated according to their permit
conditions.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
87
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.141. TSDFs that treat, store,
or dispose of hazardous wastes
in permitted miscellaneous units
must comply with monitoring,
analysis, inspection, responses,
reporting, and corrective action
regulations (40 CFR 264.602).
Determine if the TSDF:
- Follows the general inspection requirements of 40 CFR 264.15
- Tests and maintains equipment in compliance with 40 CFR 264.33
- Prepares a biennial report as specified in 40 CFR 264.75
- Prepares unmanifested waste reports and additional reports, if applicable, as
required in 40 CFR 264.76 through 264.77
- Takes corrective action to prevent releases as defined in 40 CFR 264.101.
DF.142. A permitted
miscellaneous unit that is a
disposal unit must be
maintained according to the
permit requirements during the
post-closure period (40 CFR
264.603).
Determine if the TSDF has a closed miscellaneous unit.
Verify that the post-closure requirements specified in the permit are being carried out.
Additional Requirements for Interim Status TSDFs
General
DF.143. Interim status TSDFs
are allowed to conduct OB/OD
of waste explosives under
specific conditions (40 CFR
265.382).
Determine if the TSDF is conducting OB/OD activities.
Verify that the OB/OD occurs at the distance from an adjoining property line indicated
in the following chart:
Lb. of waste explosive
or propellents
0 to 100
101 to 1,000
1,001 to 10,000
10,000 to 30,000
Minimum distance from OB/OD activity to the
property of others
204 m (670 ft.)
380m (1,250 ft.)
530m (1,730 ft.)
690m (2,260 ft.)
DF.144. TSDFs operating
surface impoundments, landfills,
or land treatment facilities are
required to have a groundwater
monitoring program that can
determine the impact of these
activities on the uppermost
aquifer (40 CFR 265.90(a)
through 265.90(c) and
265.90(e)).
Verify that, unless the TSDF has demonstrated in writing there is a low potential for
water migration or received a waiver, the TSDF has a groundwater monitoring
program.
Verify that the monitoring program is carried out throughout the active life of the
activity and during post-closure for disposal activities.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.145. The TSDF must gather
and analyze samples from the
groundwater monitoring system
according to a groundwater
sampling and analysis plan (40
CFR 265.92).
Verify that the plan includes procedures and techniques for the following:
- Sample collection
- Sample preservation and shipment
- Analytical procedures
- Chain of custody control.
Verify that the TSDF established initial background groundwater quality.
Verify that the concentrations and/or values are determined for the following
parameters and samples collected as indicated:
- Parameters characterizing the suitability of groundwater as drinking water as found
in Appendix III of 40 CFR 265
- Parameters of chloride, iron, manganese, phenols, sodium, sulfate: annually
- Parameters for pH, specific conductance, total organic carbon, total organic
halogen: semiannually.
(NOTE: The last two listed parameters are quarterly for the first year.)
Verify that the elevation of the groundwater surface is determined each time a sample
is obtained.
DF.146. Groundwater monitoring
systems are required to meet
specific standards (40 CFR
265.91).
Verify that the groundwater monitoring system is capable of yielding groundwater
samples for analysis.
Verify that groundwater monitoring systems consist of the following:
- Monitoring wells, at least three, installed hydraulically downgradient at the limit of
the waste management area
- Monitoring wells, at least one, installed hydraulically upgradient from the limit of the
waste management area
- An alternate hydraulically downgradient monitoring well location that has been
demonstrated in writing to be sufficient.
(NOTE: Separate monitoring systems are not required for each component of a waste
management system if the upgradient and downgradient sampling will detect any
discharge from the waste management area.)
DF.147. Facilities with interim
status TSDFs must have an
outline of a groundwater quality
assessment program (40 CFR
265.93(a)).
Determine if a groundwater quality assessment program outline has been developed.
Verify that the program is capable of determining:
- Whether or not hazardous waste or hazardous waste constituents have entered the
groundwater
- The rate and extent of migration of hazardous waste or hazardous waste
constituents in the groundwater
- The concentrations of hazardous waste or hazardous waste constituents in the
groundwater.
DF.148. When there is a
significant increase for pH,
specific conductance, total
organic carbon, or total organic
halogen (or pH decrease) in the
downgradient wells, the TSDF
must perform specific actions
(40CFR265.93(c)(2)and
265.93(d)(1) through
265.93(d)(4)).
Verify that additional samples are taken from the wells showing a significant change.
Verify that, if a significant increase (or pH decrease) is confirmed, written notice is
issued to the regulatory agency within 7 days of the confirmation.
Verify that, within 15 days after the notification was submitted, the TSDF submits a
groundwater quality assessment program.
Verify that the program is implemented.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.149. If a TSDF is required to
have a groundwater assessment
program, specific reports must
be submitted and actions taken
depending on the results of the
program (40 CFR 265.93(d)(5)
through 265.93(d)(7)).
Verify that the program was implemented as soon as possible and a written report
containing an assessment of the water was sent to the regulatory agency.
(NOTE: If the results of the first determination under the program show that no
hazardous waste or hazardous waste constituents have entered the groundwater, the
TSDF can return to its usual practices of monitoring.)
DF.150. Unless the groundwater
is being monitored to satisfy a
groundwater assessment
program, the TSDF is required
to meet specific reporting and
recordkeeping requirements (40
CFR265.94(a)).
Verify that records on analyses and groundwater elevations are kept throughout the
life of the site, and for disposal facilities through post-closure.
Verify that, during the first year of groundwater monitoring, the results of parameter
monitoring are submitted to the regulatory agency within 15 days after completing
each quarterly analysis.
Verify that, after the first year, concentrations and values for monitored parameters are
reported annually.
DF.151. When the groundwater
is being monitored to satisfy a
groundwater assessment
program, records have to be
maintained of the analyses and
annual reports submitted (40
CFR265.94(b)).
Verify that records of analyses and evaluations specified in the plan are maintained
throughout the active life of the site, and for disposal facilities throughout post-closure.
Verify that the results of the program are submitted annually to the regulatory agency
by 1 March of each calendar year.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Surface Impoundments
DF.152. New surface
impoundments that started
construction after January 29,
1992, lateral expansions of
surface impoundments which
started construction after July
29, 1992, and replacements of
existing surface impoundments
where reuse started after July
29, 1992 are required to meet
specific design and operating
criteria (40 CFR 265.19,
265.221(a) through 265.221 (e),
265.221 (h), 265.222, and
265.223).
Verify that the listed surface impoundments have two liners and a leachate collection
and removal system between the liners unless a waiver has been granted by the
regulatory agency.
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit.
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that the regulatory agency is notified 60 days prior to the receipt of wastes.
Verify that a TSDF submitting notice files a Part B application within six months of the
receipt of notice.
Verify that the TSDF is complying with the action leakage rate established by the
regulatory agency and if the rate is exceeded by flow into any sump:
- The regulatory agency is notified within seven days
- A written notification is submitted within 14 days
- The location, size and cause of any leak is determined to the extent practicable
- A determination is made as to whether waste receipt should be stopped or
restricted
- The regulatory agency is notified of actions taken and actions to be taken within 30
days after discovery of a leak
- A monthly report is submitted to the regulatory agency as long as the flow rate in
the leak detection system exceeds the action leakage rate.
Verify that the TSDF has an approved response action plan.
(NOTE: As of February 18, 1993, surface impoundments that are newly subject to
hazardous waste requirements because of new additions or characteristics for the
identification of hazardous waste are required to meet the standards outlined above
concerning having two or more liners and a leachate collection system.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
91
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.153. Interim status surface
impoundments are required to
meet specific operating and
containment standards (40 CFR
265.221 (f), 265.221(g), 265.223,
265.225, and 265.226).
Verify that there is enough freeboard to prevent any overtopping of the dike by
overfilling, wave actions, or a storm.
Verify that there is a freeboard of 60 cm (2 ft) unless written certification states that a
lesser freeboard is acceptable.
Verify that all earthen dikes have a protective cover such as grass, shale, or rock to
minimize wind and water erosion and preserve integrity.
Verify that the freeboard is inspected at least once each day.
Verify that the surface impoundment is inspected at least once a week for signs of
deterioration, leaks, or failure.
Verify that the amount of liquids removed from each leak detection system sump is
recorded at least:
- Once a week during the active life and closure period
- Monthly after the final cover is installed or:
-if the liquid level in the sump stays below the pump operating level of two
consecutive months, quarterly
— if the liquid level in the sump stays below the pump operating level for two
consecutive quarters, semi-annually.
DF.154. In specific
circumstances additional waste
analyses must be done (40 CFR
265.225).
Verify that additional waste analyses are done whenever:
- The surface impoundment is used to treat a substantially different hazardous waste
from what was previously treated
- A substantially different process is used to treat the waste.
DF.155. Specific procedures
must be followed during the
closure and post-closure periods
for an interim status surface
impoundment (40 CFR
265.228).
Verify that at closure all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated with
waste and leachate are removed or decontaminated.
Verify that post-closure care includes care equivalent to that for interim status landfills
and 40 CFR 265.310, including:
- Elimination of free liquids
- Stabilization of wastes to a bearing capacity sufficient to support the final cover
- Covering of surface impoundment
- Maintenance and monitoring of leak detection system.
Verify that if wastes, waste residues, or contaminated materials remain after closure:
- The integrity of the final cover is maintained
- A groundwater monitoring system is maintained that meets the requirements of 40
CFR 265.90 through 265.94
- Run-on and runoff are prevented from damaging or eroding the final cover
- Maintenance and monitoring of the groundwater monitoring system is provided by
the facility owner/operator.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Waste Piles
DF.156. Interim status waste
piles are required to meet
specific standards for wind
protection, waste analysis, and
containment (40 CFR 265.250,
265.251, and 265.253).
Determine if the TSDF operates an interim waste pile.
Verify that interim status waste piles are covered or otherwise managed to prevent
dispersal of the pile contents by the wind.
Verify that if the leachate or runoff from a pile is a hazardous waste, one of the
following is done:
- Option one:
— place the pile on an impermeable base that is compatible with the waste
— design, construct, operate, and maintain a run-on control system capable of
preventing flow onto the active portion of the pile during peak discharge from at
least a 25 year storm
— design, construct, operate, and maintain a runoff management system to collect
and control at least the water volume resulting for a 24 hour, 25 year storm
- empty and manage collection and holding facilities for the run-on and runoff
systems
- Option two:
— protect the pile from precipitation and run-on
- no liquids or wastes containing liquids are placed in the pile.
DF.157. New interim status piles
which start construction after
January 29, 1992, lateral
expansions of a waste pile unit
which started after July 29,
1992, and each such
replacement of an existing waste
pile unit for which reuse started
after July 29, 1992 must meet
specific design and operating
standards (40 CFR 265.19,
265.254, 265.255, 265.259, and
265.260).
Determine if the TSDF operates an interim status waste pile meeting the listed
description.
Verify that the waste pile has two or more liners and a leachate collection and removal
system.
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that waste piles subject to these requirements meet the action leakage rate set
by the regulatory agency.
Verify that the TSDF has an approved response action plan before receipt of waste.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.157. (continued)
Verify that if the flow rate into the leak detection system exceeds the action leakage
rate for any sump:
- The regulatory agency is notified within seven days
- A written notification is submitted within 14 days
- The location, size and cause of any leak is determined to the extent practicable
- A determination is made as to whether waste receipt should be stopped or
restricted
- The regulatory agency is notified of actions to be taken within 30 days after
discovery of a leak
- A monthly report is submitted to the regulatory agency as long as the flow rate in
the leak detection system exceeds the action leakage rate.
Verify that the amount of liquids removed from each leak detection sump is recorded
at least one a week during the active life and closure period.
DF.158. Except in specific
instances, TSDFs are required
to analyze a representative
sample from each incoming
waste before adding the waste
to an existing pile (40 CFR
265.252).
Verify that an analysis is performed unless one of the following occurs:
- The only wastes that the TSDF receives for piling are compatible
- The waste received is compatible with the pile in which it is to be placed.
DF.159. Interim status waste
piles must meet specific closure
and post closure requirements
(40 CFR 265.258).
Verify that at closure all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated with
waste and leachate are removed or decontaminated.
Verify that if all residues cannot be removed, the waste pile is closed and post-closure
care is carried out as for a landfill.
Land Treatment Units
DF.160. Interim status land
treatment units are required to
be operated according to
specific standards (40 CFR
265.270, 265.272, 265.273, and
265.279).
Determine if the TSDF operates an interim status land treatment unit.
Verify that the following standards are met at the land treatment unit:
- Hazardous wastes are not placed in or on a land treatment facility unless it can be
made less hazardous or nonhazardous by degradation, transformation, or
immobilization processes occurring in or on the soil
- Run-on control systems are operated to prevent flow onto the treatment zone during
peak discharge from at least a 25 year storm
- Runoff management systems are capable of controlling and collecting a water
volume at least equivalent to a 24 hour, 25 year storm
- Tanks and basins associated with the run-on and runoff control systems are
emptied or otherwise managed after storms
- Wind dispersal is controlled.
Verify that in addition to required waste analysis, prior to placing a hazardous waste in
or on a land treatment facility the owner or operator:
- Determines the concentrations in the waste of any substance which equals or
exceeds the maximum concentrations contained in Table 1 of 264.21
- Determines the concentration of any substance which caused the waste to be listed
as hazardous
- Determines the concentrations of arsenic, cadmium, lead, and mercury if food chain
crops are grown unless there is documentation present to prove that none of these
constituents exist.
Verify that hazardous waste application dates and rates are included in the operating
record.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.161. TSDFs are required to
operate interim status land
treatment facilities where food
chain crops are grown according
to specific standards (40 CFR
265.276).
Determine if the TSDF grows food chain crops on their land treatment facilities.
Verify that the TSDF notified the regulatory agency that food chain crops were being
grown.
Verify that food chain crops are not grown on the land treatment facility unless there is
proof that the crop will not be contaminated by arsenic, lead, mercury, or other harmful
constituents.
Verify that if the TSDF accepts waste that is contaminated with cadmium, the handling
practices outlined in 50 CFR 265.276(c) are followed.
DF.162. TSDFs with interim
status land treatment facilities
are required to have an
unsaturated zone monitoring
plan (40 CFR 265.278).
Verify that the TSDF has an unsaturated zone monitoring plan that includes:
- Soil monitoring using soil cores
- Soil-pore water monitoring using devices such as lysimeters
- Depth and number of samples to be taken.
Verify that the TSDF is following the plan.
DF.163. TSDFs with interim
status land treatment facilities
are required to meet specific
requirements concerning closure
and post-closure (40 CFR
265.280).
Verify that in the closure plan, the TSDF has addressed the following issues for interim
status land treatment facilities:
- Control of migration of wastes
- Control of the release of contaminated runoff into surface water
- Control of the release of airborne particulates
- Compliance with food chain crop restrictions.
Verify that during closure:
- Unsaturated zone monitoring is continued
- The run-on control system is maintained
- The runoff management system is maintained
- There is continued control of wind dispersal of particulate matter.
Verify that when closure was completed, the TSDF notified the regulatory agency.
Verify that during post-closure the following is done:
- Soil-core monitoring is continued as specified in the post closure plan
- Access to the unit is restricted as appropriate
- Growth of food chain crops complies with restrictions
- Wind dispersal of hazardous wastes is controlled.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Hazardous Waste Landfills
DF.164. New interim status
landfill units which started
construction after January 29,
1992, each lateral expansion of
a landfill unit that started
construction after July 29, 1992,
and each replacement of an
existing landfill that will begin
reuse after July 29, 1992, is
required to meet specific design
and operating standards (40
CFR 265.19, 265.301(a) through
265.301(e) and 265.302 through
265.304).
Determine if the TSDF has any interim status landfills meeting the stated criteria.
Verify that the landfill has two or more liners and a leachate collection system above
and between the liners or that a waiver of the double liner requirement has been
obtained from the regulatory agency.
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit.
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following:
- Identification of applicable units and a description of how they will be constructed
- Identification of key personnel
- A description of sampling and inspection activities.
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the regulatory agency.
Verify that documentation supporting construction quality assurance certification can
be provided upon request.
Verify that the TSDF notifies the regulatory agency at least 60 days prior to receiving
waste and files a Part B application within six months of the receipt of notice.
Verify that landfills subject to these requirements meet the action leakage rate set by
the regulatory agency.
Verify that the TSDF has an approved response action plan before the receipt of
waste.
Verify that if the flow rate into the leak detection system exceed the action leakage rate
for any sump:
- The regulatory agency is notified within seven days
- A written notification is submitted within 14 days
- To the extent practicable, the location, size and cause of any leak is determined
- A determination is made as to whether waste receipt should be stopped or
restricted
- The regulatory agency is notified of actions taken and actions to be taken within 30
days after discovery
- A monthly report is submitted to the regulatory agency as long as the flow rate is the
leak detection system exceeds the action leakage rate.
Verify that after a final cover is installed, the amount of liquids removed from each leak
detection system sump is recorded at least monthly or:
- If the liquid level in the sump stays below the pump operating level for two
consecutive months, quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, semiannually.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Incinerators
DF.165. TSDFs with interim
status that use incinerators for
hazardous waste must
sufficiently analyze all wastes
burned (40 CFR 265.340 and 40
CFR 265.341).
Determine if the TSDF incinerates hazardous wastes.
Determine if the results of each waste analysis are kept on file in the operating record.
Verify that for each waste not previously burned at the site, a waste analysis is
conducted to establish steady state (normal) operating conditions including:
- Waste fuel feed
- Auxiliary fuel feed
- Air flow
- Type of pollutants that might be emitted
- At a minimum, the waste analysis must determine:
— heating value
- halogen content
- sulfur content
— lead concentration level
— mercury concentration level.
(NOTE: TSDFs with interim status may be exempt from all the requirements for
hazardous waste incinerators (except closure) under certain conditions:
- The TSDF has written documentation that the wastes they incinerate do not contain
any hazardous constituents listed in 40 CFR 261 appendix VIII (see Appendix B of
this protocol)
- The documentation is retained at the TSDF
- The wastes are listed as hazardous solely because of their ignitable (Hazard Code
I) or corrosive (Hazard Code C) properties, or both, as listed and determined in 40
CFR 261, part C or D
- The wastes are listed as reactive (Hazard Code R) for characteristics other than
those listed in 40 CFR 261.23(a)(4) and (5) and will not be burned when other
hazardous wastes are present in the combustion zone
- The wastes are hazardous wastes solely because they possess the characteristics
of ignitability, corrosivity, or both, as determined by the tests for characteristics of
hazardous waste
- The wastes are hazardous wastes solely because they possess the reactivity
characteristics described in 40 CFR 261.23(a)(1), (2), (3), (6), (7) and (8) and will
not be burned when other hazardous wastes are present in the combustion zone.)
DF.166. TSDFs with interim
status may burn F020 through
F023, F026, F027 if they have
proper certification (40 CFR
265.352).
Determine if the TSDF burns EPA hazardous waste numbers F020 through F023,
F026, or F027.
Verify that the TSDF has received certification from the regulatory agency if such
wastes are burned at the site.
DF.167. TSDFs with interim
status that incinerate hazardous
waste must not feed hazardous
waste unless the incinerator is at
a steady state (40 CFR
265.345).
Observe the incinerator during startup and shutdown to verify that the waste is not fed
until steady state conditions are reached.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.168. An interim status TSDF
that incinerates hazardous
waste must conduct monitoring
and inspections (40 CFR
265.347).
Verify that the following monitoring and inspection procedures are followed:
- Existing instruments related to combustion and emission control are monitored
every 15 minutes including the instruments that control:
- waste feed
— auxiliary fuel feed
— airflow
- incinerator temperature
- scrubber flow
— scrubber pH
- The complete incinerator and associated equipment are inspected at least daily for
leaks, spills, and fugitive emissions, including:
- pumps
— valves
— conveyors
- pipes
- emergency shutdown controls and system alarms are checked at least daily to
assure proper operation.
DF.169. At closure of an interim
status incinerator, all hazardous
waste and hazardous waste
residues must be removed (40
CFR 265.351).
Verify that when an interim status hazardous waste incinerator is closed, the wastes
and residues are removed.
Thermal Treatment
DF.170. TSDFs with interim
status thermal treatment
facilities must meet specific
requirements (40 CFR 265.370,
265.373, 265.375, 265.381, and
265.383).
Determine if the TSDF operates an interim status thermal treatment facility (other than
enclosed devices using controlled flame combustion).
Verify that the following requirements are met:
- The thermal treatment process is operating at steady state (normal) conditions,
including temperature, before adding hazardous waste (unless the process is a
noncontinuous (batch) process that requires a complete thermal cycle to treat the
waste)
- Waste analysis is performed on waste not previously treated at the thermal
treatment facility that includes:
— establishing steady state (normal) operating condition
— types of pollutants which might be emitted
- heating value
- halogen and sulfur content
— concentrations of lead and mercury.
(NOTE: The open burning of hazardous waste is prohibited except for the open
burning and detonation of waste explosives.)
Verify that if open burning or detonation of waste explosives is conducted, the
following standards are met:
- Pounds of waste explosives or propellents determines the minimum distance from
open burning or detonation to property of others as shown below:
- 0-100 Ib.: 204m (670 ft.)
- 101-1,000 Ib.: 380m (1250 ft.)
- 1001-10,000 Ib.: 530m (1730 ft.)
- 10,001-30,000 Ib.: 690 m (2260 ft.).
Verify that at closure all wastes and residues are removed.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.171. Interim status thermal
treatment facilities must be
certified, it they treat certain
wastes (40 CFR 265.383).
Determine if the TSDF thermally treats EPA waste numbers F020 through F023, F026,
or F027.
Verify that the TSDF has received certification from the regulatory agency to burn such
wastes.
DF.172. Operators of interim
status thermal treatment
facilities must conduct
monitoring and inspections while
thermally treating hazardous
waste (40 CFR 265.377).
Determine if the operator conducts at a minimum the following monitoring while
thermally treating hazardous wastes:
- Every 15 min, the following instrumentation for temperature and emission controls
are monitored and appropriate corrections are made immediately:
— waste feed rate
- auxiliary fuel rate
- treatment process temperature
— relevant process flow and level controls
— every hour, stack emissions are visually checked for normal appearance (color
and opacity)
- Every day, the complete thermal treatment process and associated equipment are
checked including:
— pumps, valves, conveyors, pipes, etc. inspected for leaks, spills, and fugitive
emissions
- emergency shutdown controls and systems alarms are checked for proper
operation.
Chemical/Physical/Biological Treatment
DF.173. TSDFs with interim
status chemical, physical, and
biological treatment facilities
must meet certain requirements
(40 CFR 265.400 through
265.402, and 265.404).
Determine if the TSDF operates a chemical, physical, or biological treatment facility to
treat hazardous wastes.
(NOTE: These requirements do not apply to TSDFs which treat hazardous wastes by
chemical, physical, biological methods in other than tanks, surface impoundments,
and land treatment units.)
Verify that the following criteria are met:
- Wastes or treatment reagents are not placed in treatment process or equipment if
they could cause ruptures, leaks, corrosion or other failures
- In addition to the analyses required by 40 CFR 265.13, continuously fed systems
are equipped with waste feed cutoff or bypass system
- Waste analyses and treatment tests (e.g., bench scale or pilot plant tests) are
performed, or written, documented information is obtained whenever a substantially
different waste is treated or a substantially different treatment process is used.
Verify that at closure all wastes and residues are removed.
DF.174. TSDFs with chemical,
physical, and biological
treatment facilities must conduct
regular inspections (40 CFR
265.403).
Determine if the chemical, physical, and biological treatment facility is inspected in
accordance with the following:
- At least daily, discharge control and safety equipment (e.g., waste feed cutoff
system, bypass system, drainage systems, and pressure relief systems) to ensure
good working order
- At least daily, data from monitoring equipment is checked to ensure process is
operated in accordance with its design
- At least weekly, construction materials of the treatment process or equipment is
inspected to detect corrosion, leaks, etc.
- At least weekly, construction materials of and the area surrounding dikes or other
discharge confinement structures are inspected to detect erosion or signs of
leakage (dead vegetation, wet spots, etc.).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.175. TSDFs with interim
status may not place ignitable,
reactive, or incompatible waste
in a treatment process or
equipment unless certain
requirements are met (40 CFR
265.405 through 265.406 and
265.17(b)).
Determine whether the TSDF treats any of these wastes.
Verify that any ignitable or reactive waste is treated or mixed in such a way before or
immediately after placement in the treatment process so that the resultant material no
longer meets the definition for ignitable or reactive wastes and is treated in such a way
that it is not exposed to conditions that may cause it to react or ignite.
Verify that incompatible wastes are not placed in the same treatment process,
equipment, or in unwashed equipment that previously held incompatible waste.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Export/Import of Hazardous Waste
Exports of Hazardous Waste for Recovery within the OECD Member Countries
DF.176. A U.S. Notifierthat
exports amber list or red list
hazardous waste (see 40 CFR
262.89 and 262.82) destined for
recovery operations (see 40
CFR262.81(k))inanOECD
member country (40 CFR
262.58(a)) must comply with
notification requirements (40
CFR 262.83).
Determine whether the importing country is an Organization for Economic
Coordination and Development (OECD) member country [Australia, Austria, Belgium,
Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Japan,
Luxembourg, Netherlands, New Zealand, Norway, Portugal, Spain, Sweden,
Switzerland, Turkey, United Kingdom, and United States].
(NOTE: The following countries have become OECD member countries since EPA
promulgated its OECD regulations in 1996: South Korea, Czech Republic, Poland, and
Hungary. EPA plans to amend its regulations to reflect these new OECD countries. In
the interim, EPA strongly recommends that U.S. exports to these new OECD countries
comply with the applicable OECD regulations, since these countries would expect
compliance with OECD requirements for shipments they receive from the U.S.)
Determine whether the waste is destined for recovery operations, including resource
recovery, recycling, reclamation, direct re-use or alternative uses.
Verify that 45 days prior to shipment of hazardous waste, the facility has notified EPA
(in writing) of the following:
- Serial number or other accepted identifier of the notification form
- Name, address, telephone and telefax numbers, and EPA ID number of the notifier
- Name, address, telephone and telefax numbers of any consignee (other than the
owner or operator of the recovery facility) and whether the consignee will exchange
or store the waste before delivery to the final recovery facility
- Intended transporters and any agents
- Country of export and point of departure
- Countries of transit, relevant competent authority, and point of entry and departure
- Country of import, relevant competent authority, and point of entry
- Statement of whether the notification is for a single or multiple shipments and, for
multiple shipments, period of validity requested
- Date foreseen for shipments to begin
- Designation of waste types from the appropriate list (amber or red and waste list
code), descriptions of each waste type, estimated total quantity of each, RCRA
waste code, and United Nations number for each waste type and
- Signed certification that states the following:
"I certify that the above information is complete and correct to the best of my
knowledge. I also certify that legally-enforceable written contractual obligations
have been entered into, and that any applicable insurance or other financial
guarantees are or shall be in force covering the transfrontier movement."
(NOTE: The U.S. does not currently require financial assurance; however, U.S.
exporters may be asked by other governments to provide and certify to such
assurance as a condition of obtaining consent to a proposed movement.)
(NOTE: If wastes with similar physical and chemical characteristics, the same United
Nations classification, and the same RCRA waste codes are to be sent to the same
recovery facility by the same notifier, the notifier may submit one notification of intent
to export these wastes in multiple shipments during a period of up to one year.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.176. (continued)
(NOTE: For amber list wastes to be shipped to a recovery facility pre-approved by the
competent authority of the receiving country, the notifier must provide the above
information to EPA at least 10 days prior to shipment. Waste may be shipped as soon
as the notification has been received by the competent authorities in the exporting,
importing, and transit countries unless the notifier receives information indicating that
any country objects to the shipment.)
For amber list wastes, verify that either (1) no objection was lodged by any exporting,
importing, or transit countries within 30 days after issuance of the Acknowledgment of
Receipt of notification by the competent authority of the importing country or (2) the
competent authorities of all importing and transit countries provided written consent
within 30 days.
For red list wastes, verify that written consent was received from the importing country
and any transit countries prior to export.
DF.177. A U.S. notifier must
execute a valid written contract
or chain of contracts with the
recovery facility that specifies
the responsibilities of each (40
CFR 262.85).
Verify that contracts specify the name and EPA ID number, where available, of:
- The generator of each type of waste
- Each person who will have physical custody of the waste
- Each person who will have legal control of the waste and
- The recovery facility.
Verify that contracts specify:
- Which party will assume responsibility for alternate management of the wastes if it
cannot be carried out as described in the notification of intent to export
- That the person with actual possession or physical control over the waste will
immediately notify the notifier and the competent authorities of the exporting and
importing countries and transit country if wastes are located in a country of transit
- The person specified in the contract who will assume responsibility for the adequate
management of the wastes including, if necessary, arranging for their return to the
original country of export
- Notification prior to re-export to a third country and
- Provisions for financial guarantees.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.178. A U.S. notifier must
ensure that a tracking document
accompanies each shipment of
amber or red list wastes until it
reaches the final recovery facility
(40 CFR 262.84).
Verify that a copy of the tracking document is attached to the shipment.
Verify that the tracking document includes all information contained in the notification
and the following:
- The date shipment commenced
- Name, address, telephone and telefax numbers of primary exporter, if different than
the notifier
- Name and EPA ID number of all transporters
- Any special precautions to be taken by transporters
- Signed certification that states the following:
"I certify that the above information is complete and correct to the best of my
knowledge. I also certify that legally-enforceable written contractual obligations
have been entered into, and that any applicable insurance or other financial
guarantees are or shall be in force covering the transfrontier movement, and that:
1. All necessary consents have been received; OR
2. The shipment is directed at a recovery facility within the OECD area and no
objection has been received from any of the concerned countries within the 30 day
tacit consent period; OR
3. The shipment is directed at a recovery facility pre-authorized for that type of
waste within the OECD area; such an authorization has not been revoked, and no
objection has been received from any of the concerned countries."
(NOTE: The notifier may delete sentences that are not applicable.)
and
- Appropriate signatures for each custody transfer.
DF.179. A U.S. notifier must
comply with special manifest
requirements (40 CFR 262.84(c)
and 262.54(a), (b), (c), (e), and
(i))-
Verify that the tracking documents contain the following:
- The name and address of the foreign consignee (and any alternate consignee) in
place of the designated facility's name, address, and EPA ID number and
- The point of departure from the United States indicated in the Special Handling
Instructions and Additional Information section.
Verify that a copy of the manifest is provided for delivery to the U.S. Customs official at
the point of departure from the U.S.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.180. A primary exporter
must file an annual report with
EPA by March 1 of each year
regarding hazardous waste
exported for recovery during the
previous year (40 CFR
262.87(a)).
Verify that an annual report has been submitted by March 1 of every year for
hazardous waste exported for recovery during the previous calendar year.
Randomly check several annual reports to determine whether they contain the
following information for all hazardous waste exported for recovery during the previous
year:
- The EPA ID number, name, mailing and site address of the notifier filing the report
- Calendar year covered by the report
- The name and address of each final recovery facility
- For each final recovery facility and each waste exported: a description of the waste,
the EPA hazardous waste number, the OECD waste type and code, the DOT
hazard class, the EPA ID number for each transporter used, the total amount of
waste shipped, and the number of shipments
- Under certain circumstances, the efforts used to reduce the volume and toxicity of
the waste and the change achieved during the previous year in comparison to
earlier years and
- Certification signed by the primary exporter that states the following:
"I certify under penalty of law that I have personally examined and am familiar with
the information submitted in this and all attached documents, and that based on my
inquiry of those individuals immediately responsible for obtaining the information, I
believe that the submitted information is true, accurate, and complete. I am aware
that there are significant penalties for submitting false information including the
possibility of fine and imprisonment."
DF.181. A primary exporter
must file an exception report
with EPA under certain
circumstances (40 CFR
262.87(b)).
Verify that an exception report is filed with EPA each time any of the following occurs:
- The notifier does not receive a copy of the tracking document signed by the
transporter stating point of departure from the U.S. within 45 days of acceptance by
the initial transporter
- Within 90 days from the date the waste was accepted by the initial transporter, the
notifier does not receive written confirmation from the recovery facility that the waste
was received or
- The waste is returned to the U.S.
DF.182. A primary exporter
must maintain records that
relate to export activities (40
CFR262.87(c)).
Verify that the following records are kept for the appropriate period of time:
- Each notification of intent to export and all written consents obtained (at least three
years from the date the hazardous waste was accepted by the initial transporter)
- Each annual report (at least 3 years from the due date of the report), and
- Any exception reports and each confirmation of delivery received from the recovery
facility (at least 3 years from the date the initial waste was received from the
recovery facility).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Exports of Hazardous Waste (Except to the OECD Member Countries) for Recovery
DF.183. A primary exporter of
hazardous waste must comply
with notification requirements
(40CFR262.53(a)and
262.53(b)).
Determine if the facility imports/exports hazardous waste.
Verify that 60 days prior to the initial shipment of hazardous waste to each country in
each calendar year, the facility has notified the EPA (in writing) of the following:
- Name, mailing address, telephone number, and EPA identification number of the
primary exporter
- By consignee, for each hazardous waste type:
- identification of the hazardous waste shipped by EPA identification number
— DOT shipping name, hazard class, and importer for the waste
— estimated frequency/rate at which such wastes(s) is to be exported
- estimated total quantity (in units)
- all points of entry to and departure from each foreign country the waste will pass
through
— a description of the approximate length of time the waste will remain in each
country, and how it will be handled there
- the mode of transportation used to transport the waste and type(s) of
containers used
— description of the treatment, storage, or disposal method to be used in the
receiving country
- name and address of the foreign consignee.
DF.184. The primary exporter
must attach a copy of an EPA
Acknowledgment of Consent
(that confirms the consent of the
foreign country to receive the
waste) to the shipment of
hazardous waste to a foreign
country (40 CFR 262.52(c),
262.53(f) and 262.54(h)).
Verify that a copy of the EPA Acknowledgment of Consent is on file by checking the
records.
Verify that a copy of this document was attached to the shipment.
DF.185. Primary exporters of
hazardous waste must require
confirmation of the delivery of
the hazardous waste and a
description of any significant
discrepancies between the
manifest and the shipment (40
CFR262.54(f)).
Verify that the facility has been receiving confirmation of delivery.
Determine if there are any notations of discrepancies.
DF.186. Primary exporters of
hazardous waste are required to
comply with general manifest
requirements with certain
modifications (40 CFR 262.54(a)
through 262.54(e) and
262.54(i)).
Verify that the manifest copies comply with the general manifest requirements of 40
CFR 262.20 through 262.23.
Determine if the following modifications are made by reviewing the manifest copies:
- The name and address of the foreign consignee (and any alternate consignee) is
put in the place of the designated facility's name, address, and EPA number.
- The point of departure from the United States is indicated in the Special Instructions
and Additional Information sections.
- This statement, "and conform to the terms of the attached EPA Acknowledgment of
Consent," is added to the end of the first sentence of the certification in Item 16.
Verify that a copy of the manifest is provided for delivery to the U.S. Customs official at
the U.S. point of departure.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.187. Primary exporters of
hazardous waste are required to
follow specific procedures when
a shipment cannot be delivered
to the designated or alternate
consignee (40 CFR 262.54(g)).
Verify that when a shipment cannot be delivered, the primary exporter does one of the
following:
- Notifies the EPA of a change in the conditions of the original notification to allow
shipment to a new consignee and obtains an EPA Acknowledgment of Consent
prior to delivery, or
- Instructs the transporter to return the waste to the primary exporter in the United
States or designates another facility within the United States.
Verify that the facility instructs the transporter to revise the manifest to reflect changes
made.
DF.188. Primary exporters of
hazardous waste are required to
file an exception report under
certain conditions (40 CFR
262.55).
Verify that an exception report was filed if:
- A signed copy of the manifest from the transporter containing the following
information was not received within 45 days from the day it was accepted by the
initial transporter:
- date of departure of the waste from the United States
- place of departure of the waste from the United States
- Within 90 days from the date the waste was accepted by the initial transporter, the
facility has not received a written confirmation from the foreign consignee stating
that the hazardous waste was received
- The waste is returned to the United States.
DF.189. The primary exporter
must file an Annual Report with
the regulatory agency by March
1 of each year regarding
hazardous waste exported
during the previous year (40
CFR 262.56).
Verify that an Annual Report has been submitted by March 1 of every calendar year.
Verify that the Annual Reprts contain the following information for all hazardous waste
exported during the previous calendar year:
- Type, EPA hazardous waste number, DOT hazard class and name for each
hazardous waste(s) exported
- EPA identification number for each transporter (where applicable)
- Quantity of hazardous waste(s) exported
- Frequency (dates) of hazardous waste(s) exported
- Ultimate destination for all hazardous waste(s) exported
- Efforts used to reduce the volume and toxicity of the waste (and the changes
achieved during the year in comparison to previous years)
- A certification signed by the primary exporter that states:
"I certify under penalty of law that I have personally examined and am familiar with
the information submitted in this and all attached documents, and that based on my
inquiry of those individuals immediately responsible for obtaining the information, I
believe that the submitted information is true, accurate, and complete. I am aware
that there are significant penalties for submitting false information including the
possibility of fine and imprisonment."
DF.190. Primary exporters of
hazardous wastes must
maintain additional records that
relate to their export activities
(40 CFR 262.57).
Verify that the following are kept for at least three years:
- A copy of each notification of intent to export
- A copy of each EPA Acknowledgment of Consent
- A copy of each confirmation of delivery (signed manifests) of the waste
- Annual reports.
(NOTE: Periods of retention are automatically extended during the course of any
unresolved enforcement action.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
Imports of Hazardous Waste for Recovery Within the OECD Member Countries
DF.191. A U.S. importer of
amber list or red list hazardous
waste (see 40 CFR 262.89 and
262.82) destined for recovery
operations (see 40 CFR
262.81 (k)) from an OECD
member country (40 CFR
262.58(a)) must execute a valid
written contract or chain of
contracts with the recovery
facility that specifies the
responsibilities of each (40 CFR
262.85).
Determine whether the exporting country is an OECD member country [Australia,
Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy,
Japan, Luxembourg, Netherlands, New Zealand, Norway, Portugal, Spain, Sweden,
Switzerland, Turkey, United Kingdom, and United States].
(NOTE: The following countries have become OECD member countries since EPA
promulgated its regulations in 1996: South Korea, Czech Republic, Poland, and
Hungary. EPA plans to amend its regulations to reflect these new OECD countries. In
the interim, EPA strongly recommends that exports to these new OECD countries
comply with applicable OECD regulations, since these countries would expect
compliance with OECD requirements for shipments they receive from the U.S.)
Determine whether the waste is for recovery operations, including resource recovery,
recycling, reclamation, direct re-use or alternative uses.
Verify that contracts specify the name and EPA ID number, where available, of:
- The generator of each type of waste
- Each person who will have physical custody of the waste
- Each person who will have legal control of the waste and
- The recovery facility.
Verify that contracts specify:
- Which party will assume responsibility for alternate management of the wastes if it
cannot be carried out as described in the notification of intent to export
- That the person with actual possession or physical control over the waste will
immediately notify the notifier and the competent authorities of the exporting and
importing countries and transit country if wastes are located in a country of transit
- That the person specified in the contract will assume responsibility for the adequate
management of the wastes including, if necessary, arranging their return to the
original country of export
- Notification prior to re-export to a third country and
- Provisions for financial guarantees.
DF.192. A U.S. importer must
ensure that a tracking document
accompanies each shipment of
amber or red list wastes until it
reaches the final recovery facility
(40 CFR 262.84).
Verify that a copy of the tracking document was attached to the shipment.
Verify that the tracking document included all information contained in the notification
and the following:
- The date shipment commenced
- Name, address, telephone and telefax numbers of primary exporter, if different than
the notifier
- Name and EPA ID number of all transporters
- Identification of means of transport, including types of packaging
- Any special precautions to be taken by transporters
- Signed certification required by 40 CFR 262.84(b)(6) and
- Appropriate signatures for each custody transfer.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Compliance Category:
Hazardous Waste Management
Regulatory Requirement or
Management Practice:
Reviewer Checks:
DF.193. A consignee must
comply with general manifest
requirements with certain
modifications (40 CFR 262.84(c)
and 262.60).
Verify that the manifest copies comply with the general manifest requirements of 40
CFR 262.20.
Determine if the following modifications are made by reviewing the manifest copies:
- The name and address of the foreign generator and the importer's name, address
and EPA identification number are put in place of the generator's name, address
and EPA identification number and
- The U.S. importer (or his agent) must sign and date the certification statement in
place of the generator's signature and obtain the signature of the initial transporter.
DF.194. Each person in the
U.S. that has physical custody of
the waste until it arrives at the
recovery facility must sign the
tracking document (40 CFR
262.84(d)).
Verify that the U.S. transporter, consignee, and owner or operator of the recovery
facility have signed the manifest.
DF.195. An owner/operator of a
U.S. recovery facility must send
signed copies of the tracking
document to the notifier, to EPA,
and to the competent authorities
of the exporting and transit
countries within three days of
receipt of imports (40 CFR
262.84(e)).
Verify that the facility sends signed copies of the tracking document to the notifier, to
EPA, and to the competent authorities of the exporting and transit countries within the
three days.
DF.196. A facility that has
arranged to receive hazardous
waste from a foreign source
must notify EPA (40 CFR
264.12(a)(1)and265.12(a)(1)).
Verify that the facility notifies the appropriate EPA Regional Administrator in writing at
least four weeks prior to the date the waste is expected to arrive at the facility.
(NOTE: Notice of subsequent shipments of the same waste from the same foreign
source is not required.)
Imports of Hazardous Waste (Except from the OECD Member Countries) for Recovery
DF.197. Any person who
imports hazardous waste must
comply with general manifest
requirements with certain
modifications (40 CFR 262.60).
Verify that the manifest copies comply with the general manifest requirements of 40
CFR 262.20.
Determine if the following modifications are made by reviewing the manifest copies:
- The name and address of the foreign generator and the importer's name, address
and EPA identification number are put in place of the generator's name, address
and EPA identification number and
- The U.S. importer (or his agent) must sign and date the certification statement in
place of the generator's signature and obtain the signature of the initial transporter.
DF.198. A facility that has
arranged to receive hazardous
waste from a foreign source
must notify EPA (40 CFR
264.12(a)(1)and265.12(a)(1)).
Verify that the facility notifies the appropriate EPA Regional Administrator in writing at
least four weeks prior to the date the waste is expected to arrive at the facility.
(NOTE: Notice of subsequent shipments of the same waste from the same foreign
source is not required.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of
Treatment, Storage and Disposal Facilities under the Resource
Conservation and Recovery Act
Appendix A:
Identification and Listing of Hazardous Waste
(40 CFR 261.30 through 261.31)
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Table 1 - Hazardous Waste from Nonspecific Sources
Industry and
USEPA Hazardous
Waste Number
F001
F002
F003
F004
F005
F006
F007
F008
F009
F010
F011
F012
F019
F020
Hazardous Waste
The spent halogenated solvents used in degreasing. Trichloroethylene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, and the chlorinated fluorocarbons; all spent solvent mixtures
or blends used in degreasing containing before use, a total often percent or more (by volume) of
one or more of the above halogenated solvents listed in F002, F004, F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
The following spent halogenated solvents: tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, l,l,2-trichloro-l,l,2-trifluoroethane,
ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent
mixtures or blends containing, before use, a total often percent or more by volume, of one or more
of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
The spent nonhalogenated solvents, xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether,
methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; and the still bottoms from
the recovery of these solvents and spent solvent mixtures.
The spent nonhalogenated solvents, cresols and cresylic acid, and nitrobenzene; and the still
bottoms from the recovery of these solvents.
The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbons disulfide,
isobutanol, pyridine, benzene, 2-ethoxylethanol, and 2-nitropropane; all spent solvent mixtures or
blends containing, before use, a total often percent or more by volume of one or more of the above
nonhalogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the
recovery of these solvents.
Wastewater treatment sludges from electroplating operations except from the following processes:
(1) sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated
basis) on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning
stripping associated with tin, zinc and aluminum plating on carbon steel; and (6) chemical etching
and milling of aluminum.
Spent cyanide plating bath solution from electroplating operations.
Plating bath residues from the bottom of plating baths from electroplating operations where
cyanides are used in the process.
Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used
in the process.
Quenching bath residues from oil baths from metal heat treating operations where cyanides are
used in the process.
Spent cyanide solutions from salt bath pot cleaning from metal heat treating operations.
Quenching wastewater treatment sludges from metal heat treating operations where cyanides are
used in the process.
Wastewater treatment sludges from the chemical conversion coating of aluminum except from
zirconium phosphating in aluminum can washing when such phosphating is an exclusive
conversion coating process.
Wastes from use of tri-, or tetrachlorophenol, or intermediates used to produce its pesticide
derivatives. **
Hazard
Code*
(t)
(t)
(i)
(t)
(U)
(t)
(r,t)
(r,t)
(r,t)
(r,t)
(r,t)
(t)
(t)
(h)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A1
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Industry and
US1PA Hazardous
Waste Number
F021
F022
F023
F024
F025
F026
F027
F028
F032
F034
F035
F037
Hazardous Waste
Wastes of pentachlorophenol, or intermediates used to produce its derivatives. **
Wastes, of tetra-, penta-, or hexachlorobenzenes under alkaline conditions. **
Wastes, of tri- and tetrachlorophenols. **
Wastes, including but not limited to distillation residues, heavy ends, tars and reactor cleanout
wastes from the production of chlorinated aliphatic hydrocarbons, utilizing free radical catalyzed
processes having carbon chain lengths from one to five, (Omits light ends, spent filters and filter
aids, spent desiccants, wastewater, wastewater treatment sludges, spent catalysts and wastes listed
in 40 CFR 261. 32).
Condensed light ends, spent filters aids, and spent desiccant wastes from the production of certain
chlorinated aliphatic hydrocarbons, by free radical catalyzed processes. These chlorinated aliphatic
hydrocarbons are those having carbon chain lengths ranging from one to and including five, with
varying amounts and positions of chlorine substitution.
Wastes of tetra-, penta-, or hexachlorobenzene under alkaline conditions.
Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused
formulations containing compounds derived from these chlorophenols (does not include
hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.
Residues from incineration or thermal treatment of soil contaminated with EPA hazardous waste
Nos. F020, F021, F022, F023, F026 and F027.
Wastewaters (except those that have not come into contact with process contaminants), process
residue, preservative drippage, and spent formulations from wood preserving processes generated
at plants that currently use of have previously used chlorophenolic formulations (except potentially
cross-contaminated wastes that have had the F032 waste code deleted in accordance with 261.35
and where the generator does not resume or initiate use of chlorophenolic formulations). This
listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood
preserving processes that use creosote and/or pentachlorophenol.
Wastewaters (except those that have come into contact w/ process contaminants), process residuals,
preservative drippage, and spent formulations from wood preserving processes generated at plants
that use creosote formulations. This listing does not include K001 bottom sludge from the
treatment of wastewater from wood preserving processes that use creosote and or
pentachlorophenol .
Wastewaters (except those that have come into contact w/ process contaminants), process residuals,
preservative drippage, and spent formulations from wood preserving processes generated at plants
that use inorganic preservatives containing arsenic or chromium. This listing does not include
K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes
that use creosote and/or pentachlorophenol.
Petroleum refinery primary oil/water/solids separation sludge- Any sludge generated from the
gravitational separation of oil/water/solids during the storage or treatment of process Wastewaters
and oily cooling Wastewaters from petroleum refiners. This includes, but is not limited to, sludges
generated in: oil/water/solids separators; tanks and impoundments; ditches and other conveyances;
sumps; and stormwater units receiving dry weather flow.
Sludges generated in stormwater units that do not receive dry weather flow, sludges generated from
non-contact once through cooling waters segregated for treatment from other process or oily
cooling waters, sludges generated in aggressive biological treatment units*** (including sludges
generated in one or more additional units after Wastewaters have been treated in aggressive
biological treatment units) and K051 wastes are not included in this listing.
Hazard
Code*
(h)
(h)
(t)
(t)
(t)
(h)
(h)
(t)
(t)
(t)
(t)
(t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Industry and
US1PA Hazardous
Waste Number
Hazardous Waste
Hazard
Code*
F038
Petroleum refinery secondary (emulsified) oil/water/solids separation sludge—Any sludge and/or
float generated from the physical and/or chemical separation of oil/water/solids in process
wastewaters and oily cooling wastewaters from petroleum refineries.
Such wastes include, but are not limited to, all sludges and floats generated in: induced air flotation
(IAF) units, tanks and impoundments, and all sludges generated in DAF units. Sludges generated
in stormwater units that do not receive dry weather flow, sludges generated from non-contact once-
through cooling waters segregated for treatment from other process or oily cooling waters, sludges
and floats generated in aggressive biological treatment units*** (including sludges and floats
generated in one or more additional units after wastewaters have been treated in aggressive
biological treatment units) and F037, K048, and K051 wastes are not included in this listing.
(t)
F039
Leachate (liquids that have percolated through land disposed wastes) resulting from the disposal of
more than one restricted waste classified as hazardous under 40 CFR 261 Subpart D.
(Leachate resulting from the management of one or more of the following wastes and no other
hazardous waste retains its hazardous waste number(s): F020, F021, F022, F023, F026, F027,
and/or F028.)
NOTE: The listing of wastewaters that have not come into contact with process contaminants is stayed administratively. The listing for
plants that have previously used chlorophenolic formulations is administratively stayed whenever these wastes are covered by the F034 or
F035 listings. These stays will remain in effect until further administrative action is taken.
! Hazard Codes:
t = toxic waste
i = ignitable waste
r = reactive waste
h = acute hazardous waste
c = corrosive waste
e = toxicity characteristic waste
** (except wastewater and spent carbon from hydrogen chloride purification) the manufacturing or production use: as a reactant, chemical
intermediate, or component in a formulating process. The listing for F020 and F023 does not include wastes from the production of
Hexachlorophene from highly purified 2,4,5- trichlorophenol.
*** Aggressive biological treatment units are defined as units which employ one of the following treatment methods: activated sludge;
trickling filter; rotating biological contactor for the continuous accelerated biological oxidation of wastewaters; or high-rate aeration.
Ffigh-rate aeration is a system of surface impoundments or tanks in which intense mechanical aeration is used to completely mix the wastes,
enhance biological activity, and (A) the units employs a minimum of 6 hp per million gallons of treatment volume; and either (B) the
hydraulic retention time of the unit is no longer than 5 days; or (C) the hydraulic retention time is no longer than 30 days and the unit does
not generate a sludge that is a hazardous waste by the Toxicity Characteristic.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Table 2 - Hazardous Waste from Organic and Inorganic Chemical Industries
Industry and
EPA Hazardous
Waste Number^^
Hazardous Waste
Hazard
Code*
Organic Chemicals
K009
K010
K011
K013
K014
K015
K016
K017
K018
K019
K020
K021
K022
K023
K024
K025
K026
K027
K028
K029
K030
K083
K085
K103
Distillation bottoms from the production of acetaldehyde from ethylene.
Distillation side cuts from the production of acetaldehyde from ethylene.
Bottom stream from the wastewater stripper in the production of acrylonitrile.
Bottom stream from the acetonitrile column in the production of acrylonitrile.
Bottoms from the acetonitrile purification column in the production of acrylonitrile.
Still bottoms from the distillation of benzyl chloride.
Heavy ends or distillation residues from the production of carbon tetrachloride.
Heavy ends (still bottoms) from the purification column in the production of
epichlorohydrin.
Heavy ends from fractionation in ethyl chloride production.
Heavy ends from the distillation of ethylene dichloride in ethylene dichloride
production.
Heavy ends from the distillation of vinyl chloride in vinyl chloride monomer production.
Aqueous spent antimony catalyst waste from fluoromethanes production.
Distillation bottom tars from the production of phenol/acetone from cumene.
Distillation light ends from the production of phthalic anhydride from naphthalene.
Distillation bottoms from the production of phthalic anhydride from naphthalene.
Distillation bottoms from the production of nitrobenzene by the nitration of benzene.
Stripping still tails from the production of methyl ethyl pyridines.
Centrifuge residue from toluene diisocyanate production.
Spent catalyst from the hydrochlorinator reactor in the production of 1 , 1 , 1 -
trichloroethane.
Waste from the product stream stripper in the production of 1,1,1 -trichloroethane.
Column bottoms or heavy ends from the combined production of trichloroethylene and
perchloroethylene.
Distillation bottoms from aniline production.
Distillation of fractionation column bottoms from the production of chlorobenzene.
Process residues from aniline extraction from the production of aniline.
(t)
(t)
(U)
(U)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(U)
(t)
(t)
(t)
(t)
(t)
(t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A4
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Industry and
EPA Hazardous
Waste Number
K104
K105
K107
K108
K109
K110
K093
K094
K095
K096
Kill
K112
K113
K114
K115
K116
Hazardous Waste
Combined wastewater streams generated from nitrobenzene or aniline production.
Separated aqueous stream from the reactor product washing step in the production of
chlorobenzenes.
Column bottoms from product separation from the production of 1 , 1 -dimethylhydrazine
(UDMH) from carboxylic acid
Condensed Column overheads from product separation and condensed reactor vent
gases from the production of 1 , 1 -dimethylhydrazine (UDMH) from carboxylic acid
hydrazides
Spent filter cartridges from product purification from production of 1 ,1 -
dimethylhydrazine (UDMH) from carboxylic acid hydrazides
Condensed column overheads from intermediate separation from the production of 1 , 1 -
dimethylhydrazine (UDMH) from carboxylic acid hydrazides
Distillation light ends from the production of phthalic anhydride from erthoxylene.
Distillation bottoms from the production of phthalic anhydride from orthozylene.
Distillation bottoms from the production of 1,1,1-trichloroethane.
Heavy ends from the heavy ends column from the production of 1,1,1-trichloroethane.
Product washwaters from the production of dinitrotoluene via nitration of toluene.
Reaction byproduct water from the drying column in the production of toluenediamine
via hydrogenation of dinitrotoluene.
Condensed liquid light ennation of dinitrotoluene.
Vicinals from the purification of toluenediamine in the production of toluenediamine.
Heavy ends from the purification of toluenediamine in the production of toluenediamine
via hydrogenation of dinitrotoluene.
Organic condensate from the solvent recovery column in the production of toluene
diisocyanate via phosgenation of toluenediamine.
Hazard
Code*
(t)
(t)
(M)
(U)
(t)
(t)
(t)
(t)
(t)
(t)
(M)
(t)
(t)
(t)
(t)
(t)
Inorganic Chemicals
K118
K136
K071
K073
Spent adsorbent solids from purification of ethylene dibromide in the production of
ethylene dibromide via bromination of ethene.
Still bottoms from the purification of ethylene dibromide in the production of ethylene
dibromide via bromination of ethene.
Brine purification muds from the mercury cell process in chlorine production, where
separately prepurified brine is not used.
Chlorinated hydrocarbon waste from the purification step of the diaphragm cell process
using graphite anodes in chlorine production.
(t)
(t)
(t)
(t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A5
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Industry and
EPA Hazardous
Waste Number
K106
Hazardous Waste
Wastewater treatment sludge from the mercury cell process in chlorine production.
Hazard
Code*
(t)
Hazardous Waste from Explosives Manufacturing
K044
K045
K046
K047
Wastewater treatment sludge from the manufacturing and processing of explosives.
Spent carbon from the treatment of wastewater containing explosives.
Wastewater treatment sludges from the manufacturing, formulation and loading of lead-
based initiating compounds.
Pink/red water from TNT operations.
(r)
(r)
(t)
(t)
! Hazard Codes:
t = toxic waste
i = ignitable waste
r = reactive waste
c = corrosive waste
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A6
-------
Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
and Recovery Act
Appendix B:
Identification of Hazardous Waste Hazardous Constituents
(40 CFR 261, Appendix VIM)
-------
THIS PAGE INTENTIONALLY LEFT BLANK
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Acetonitrile
Acetophenone
2-Acetylaminefluarone
Acetyl chloride
1 -Acetyl-2-thiourea
Acrolein
Acrylamide
Acrylonitrile
Aflatoxins
Aldicarb
Aldrin
Allyl alcohol
Allyl chloride
Aluminum phosphide
4-Aminobiphenyl
5-(Aminomethyl)-3-isoxazolol
4-Aminopyridine
Amitrole
Ammonium vanadate
Aniline
Antimony
Antimony compounds, N.O.S.1
Aramite
Arsenic
Arsenic compounds, N.O.S.1
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Auramine
Chemical Abstracts Name
Same
Ethanone, 1-phenyl-
Acetamide, N-9H-fluoren-2-yl
Same
Acetamide, N-(aminothioxomethyl)-
2-Propenal
2-Propenamide
2-Propenenitrile
Same
Propanal, 2-methyl-2-(mehtylthio)-, O-
[(methylamino)carbonyl]oxime.
1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-10-
hexachloro- l,4,4a,5,8,8a-hexahydro-, (1 alpha, 4alpha,
4abeta, Salpha, Salpha, Sabeta)-.
2-Propen-l-ol
1 -Propane, 3-chloro
Same
[1,1 '-Biphenyl]-4-amine
3(2H)-Isoxazolone, 5-(aminomethyl)-
4-Pyridinamine
1H- 1 ,2,4-Triazol-3-amine
Vanadic acid, ammonium salt
Benzenamine
Same
Sulfurous acid, 2-chloroethyl 2-[4-(l,l-
dimethylethyl)phenoxy]-l-methylethyl ester.
Same
Arsenic acid H3AsO4
Arsenic oxide As2O5
Arsenic oxide As2O3
Benzenamine, 4,4'-carbonimidoylbis[N,N-dimethyl
Chemical
Abstract No.
75-05-8
98-86-2
53-96-3
75-36-5
591-08-2
107-02-8
79-06-1
107-13-1
1402-68-2
116-06-3
309-00-2
107-18-6
107-18-6
20859-73-8
92-67-1
2763-96-4
504-24-5
61-82-5
7803-55-6
62-53-3
7440-36-0
140-57-8
7440-38-2
7778-39-4
1303-28-2
1327-53-3
492-80-8
Hazardous
Waste No.
U003
U004
U005
U006
P002
POOS
U007
U009
P070
P004
POOS
P006
P007
POOS
U011
P119
U012
P010
P011
P012
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B1
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Azaserine
Barium
Barium compounds, N.O.S.1
Barium cyanide
Benz[c]acridine
Benz[a]anthracene
Benzal chloride
Benzene
Benzenearsonic acid
Benzidine
Benzo[b]flouoranthene
Benzo[j]fluoranthene
Benzo(k)fluoranthene
Benzo[a]pyrene
p-Benzoquinone
Benzotrichloride
Benzyl chloride
Beryllium powder
Beryllium coumpounds, N.O.S.1
Bromoacetone
Bromoform
4-Bromophenyl phenyl ether
Brucine
Butyl benzyl phthalate
Cacodylic acid
Cadmium
Cadmium compounds, N.O.S.1
Calcium chromate
Calcium cyanide
Carbon disulfide
Carbon oxyfluoride
Chemical Abstracts Name
L-Serine, diazoacetate (ester)
Same
Same
Same
Same
Benzene, (dichloromethyl)-
Same
Arsonic acid, phenyl-
[l,l'-Biphenyl]-4,4 1 -diamine
Benz[e]acehpenanthrylene
Same
Same
Same
2,5-Cyclohexadiene- 1 ,4-dione
Benzene, (trichloromethyl)-
Benzene, (chloromethyl)-
Same
2-Propanone, 1-bromo-
Methane, tribromo-
Benzene, l-bromo-4phenoxy-
Strychnidin-10-one, 2,3-dimethoxy-
1,2-Benzenedicarboxylic acid, butyl phenyl-methyl ester.
Arsinic acid, dimethyl-
Same
Chromic acid H2CrO4, calcium salt
Calcium cyanide Ca(CN)2
Same
Carbonic difluoride
Chemical
Abstract No.
115-02-6
7440-39-3
542-62-1
225-51-4
56-55-3
98-87-3
71-43-2
98-05-5
92-87-5
205-99-2
205-82-3
207-08-9
50-32-8
106-51-4
98-07-7
100-44-7
7440-41-7
598-31-2
75-25-2
101-55-3
357-57-3
85-68-7
75-60-5
7440-43-9
13765-19-0
592-0108
75-15-0
353-50-4
Hazardous
Waste No.
U015
P013
U016
U018
U017
U019
U021
U022
U197
U023
P028
P015
P017
U225
U030
P018
U136
U032
P021
P022
U033
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B2
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Carbon tetrachloride
Chloral
Chlorambucil
Chlordane
Chlordane (alpha and gamma
isomers)
Chlorinated benzenes, N.O.S.1
Chlorinated ethane, N.O.S.1
Chlorinated fluorocarbons, N.O.S.1
Chlorinated naphthalene, N.O.S.1
Chlorinated phenol, N.O.S.1
Chlomaphazin
Chloroacetaldehyde
Chloroalkyl ethers, N.O.S.1
p-Chloroaniline
Chlorobenzene
Chlorobenzilate
p-Chloro-m-cresol
2-Chloroethyl vinyl ether
Chloroform
Chloromethyl methyl ether
beta-Chloronaphthalene
o-Chlorophenol
1 -(o-Chlorophenyl)thiourea
Chloroprene
3-Chloropropionitrile
Chromium
Chromium compounds, N.O.S.1
Chrysene
Citrus red no. 2
Chemical Abstracts Name
Methane, tetrachloro-
Acetaldehyde, trichloro-
Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino]-.
4,7-Methano-lH-indene, 1, 2,4,5,6 ,7,8,8-oc-tachloro-
2,3,3a,4,7,7a-hexahydro-.
Naphthalenamine, N,N-bis(2-chloroethyl)-
Acetaldehyde, chloro-
Benzenamine, 4-chloro-
Benzene, chloro-
Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-
alpha-hydroxy-,ethyl ester.
Phenol, 4-chloro-3-methyl-
Ethene, (2-chloroethoxy)-
Methane, trichloro-
Methane, chloromethoxy-
Naphthalene, 2-chloro-
Phenol, 2-chloro-
Thiourea, (2-chlorophenyl)-
1,3-Butadiene, 2-chloro
Propanenitrile, 3-chloro-
Same
Same
2-Naphthalenol, l-[(2,5-dimethoxphenyl)azo]-.
Chemical
Abstract No.
56-23-5
75-87-6
305-03-3
57-74-9
494-03-1
107-20-0
106-47-8
108-90-7
510-15-6
59-50-7
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
5344-82-1
126-99-8
542-76-7
7440-47-3
218-01-9
6358-53-8
Hazardous
Waste No.
U211
U034
U035
U036
U026
P023
P024
U037
U038
U039
U042
U044
U046
U047
U048
P026
P027
U050
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B3
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Coal tar creosote
Copper cyanide
Creosote
Cresol (Cresylic acid)
Crotonaldehyde
Cyanides (soluble salts and
complexes) N.O.S.1
Cyanogen
Cyanogen bromide
Cyanogen chloride
Cycasin
2-Cyclohexyl-4,6-dinitrophenol
Cyclophosphamide
2,4-D
2,4-D, salts, esters
Daunomycin
DDD
DDE
DDT
Diallate
Dibenz[a,h]acridine
Dibenz[aj]acridine
Dibenz [a,h] anthracene
7H-Dibenzo[c,g]carbazole
Dibenzo [a,e] py rene
Dibenzo[a,h]pyrene
Dibenzo[a,i]pyrene
1 ,2-Dibromo-3-chloropropane
Dibutyl phthalate
Chemical Abstracts Name
Same
Copper cyanide CuCN
Same
Phenol, methyl-
2-Butenal
Ethanedinitrile
Cyanogen bromide (CN)Br
Cyanogen chloride (CN)C1
beta-D-Glucopyranoside, (methyl-ONN-azoxy)methyl .
Phenol, 2-cyclohexyl-4,6-dinitro-
2H- 1 ,3,2-Oxazaphosphorin-2-amine, N,N-bis(2-
chloroethyl)tetrahydro-, 2-oxide.
Acetic acid, (2,4-dichlorophenoxy)-
5,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-
trideoxy-alpha-L-lyxo-hexopyranosyl)oxy]-7,8,9,10-
tetrahydro-6,8,1 1-trihydroxy-l-methoxy-, (8S-cis)-.
Benzene, l,l'-(2,2-dichloroethylidene)bis[4-chloro-.
Benzene, l,l'-(dichloroethenylidene)bis[4-chloro-.
Benzene, l,l'-(2.2.2 trichloroethylideneObis[4-chloro-.
Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-dichloro-2-
propenyl) ester.
Same
Same
Same
Same
Naphtho[l ,2,3,4-def]chrysene
Dibenzo [b,dif]chrysene
Benzo[rst]pentaphene
Propane, l,2-dibromo-3-chloro-
1,2-Benzenedicarboxylic acid, dibutyl ester
Chemical
Abstract No.
8007-45-2
544-92-3
1319-77-3
4170-30-3
460-19-5
506-68-3
506-77-4
14901-08-7
131-89-5
50-18-0
94-75-7
20830-81-3
72-54-8
72-55-9
50-29-3
2303-16-4
226-36-8
224-42-0
53-70-3
194-59-2
192-65-4
189-64-0
189-55-9
96-12-8
84-74-2
Hazardous
Waste No.
P029
U051
U052
U053
P030
P031
U246
P033
P034
U058
U240
U240
U059
U060
U061
U062
U063
U064
U066
U069
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B4
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
Dichlororbenzene, N.O.S.1
3,3'-Dichlorobenzidine
1 ,4-Dichloro-2-butene
Dichlorodifluoromethane
Dichloroethylene, N.O.S.1
1 , 1 -Dichloroethylene
1 ,2-Dichloroethylene
Dichloroethyl ether
Dichloroisopropyl ether
Dichloromethoxy ethane
Dichloromethyl ether
2,4-Dichlorophenol
2,6-Dichlorophenol
Dichlorophenylarsine
Dichloropropane, N.O.S.1
Dichloropropanol, N.O.S.1
Dichloropropene, N.O.S.1
1 ,3-Dichloropropene
Dieldrin
1 ,2: 3 ,4-Diepoxybutane
Diethylarsine
1 ,4-Diethyleneoxide
Diethylhexyl phthalate
N,N-Diethylhydrazine
O,O-Diethyl S-methyl
dithiophosphate
Diethyl-p-nitrohpenyl phosphate
Chemical Abstracts Name
Benzene, 1,2-dichloro-
Benzene, 1,3-dichloro-
Benzene, 1,4-dichloro-
Benzene, dichloro-
[l,l'-Biphenyl]-4,4'-diamine, 3,3'-dichloro-
2-Butene, 1,4-dichloro
Methane, dichlorodifluoro-
Dichloroethylene
Ethene, 1,1-dichloro
Ethene, 1,2-dichlrol-, (E)
Ethane, l,l'oxybis[2-chloro-
Propane, 2,2'-oxybis[2-chloro
Ethane, 1,1'- [methylenebis(oxy)bix[2-chloro- .
Methane, oxybis[chloro-
Phenol, 2,4-dichloro-
Phenol, 1 ,6-dichloro-
Arsonous dichloride, phenyl-
Propane, dichloro-
Propanol, dichloro-
1-Propene, dichloro-
1-Propene, 1,3-dichloro-
2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a-octahydro-,
(laalpha,2beta,2aalpha,3beta,6beta,
6aalpha,7beta,7aalpha)- .
2,2'-Bioxirane
Arsine, diethyl-
l,4Dioxane
1,2-Benzenedicarboxylic acid, bis(2-ethyl-hexyl) ester.
Hydrazine, 1,2-diethyl-
Phosphorodithioic acid, O,O-diethyl S-methyl
Phosphoric acid, diethyl 4-nitrophenyl ester
Chemical
Abstract No.
95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
764-41-0
75-71-8
25323-30-2
75-35-4
156-60-5
111-44-4
108-60-1
111-91-1
542-88-1
120-83-2
87-65-0
696-28-6
26638-19-7
26545-73-3
26952-23-8
542-75-6
60-57-1
1464-53-5
692-42-2
123-91-1
117-81-7
1615-80-1
3288-58-2
311-45-5
Hazardous
Waste No.
U070
U071
U072
U073
U074
U075
U078
U079
U025
U027
U024
P016
U081
U082
P036
U084
P037
U085
P038
U108
U028
U086
U087
P041
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B5
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Diethyl phthalate
O,O-Diethyl O-pyrazinyl
phosphoro-thioate
Diethylstilbesterol
Dihydrosafrole
Diisopropylfluorophosphate (DFP)
Dimethoate
3,3'-Dimethoxybenzidine
p-Dimethylaminoazobenzene
7,12-Dimethylbenz[a]anthracene
3,3'-Dimethylbenzidine
Dimethylcarbamoyl chloride
1 , 1 -Dimethylhydrazine
1 ,2-Dimethylhydrazine
alpha,alpha-
Dimethylphenethylamine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
Dinitrobenzene, N.O.S.1
4,6-Dinitro-o-cresol
4,6-Dinitro-o-cresol salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinoseb
Di-n-octyl phthalate
Diphenylamine
1 ,2-Diphenylhydrazine
Di-n-propylnitrosamine
Disulfoton
Chemical Abstracts Name
1,2-Benzenedicarboxylic acid, diethyl ester
Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester.
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediylObis-,(E)-.
1,3-Benzodioxole, 5-propyl-
Phosphorofluoridic, bis(l-mthylethyl) ester.
Phosphorodithioic acid, O,O-dimethyl S-[2-(methylamino)-
2-oxoethyl] ester.
[l,l'-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
Benzenamine, N,N-dimethyl-4-(phenylazo)-
Benz[a]anthracene, 7,12-dimethyl-
[l,l'-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
Carbamic chloride, dimethyl-
Hydrazine, 1,1-dimethyl-
Hydrazine, 1,2-dimethyl-
Benzeneethanamine, alpha,alpha-dimethyl
Phenol, 2,4-dimethyl-
1,2-Benzenedicarboxylic acid, dimethyl ester
Sulfuric acid, dimethyl ester
Benzene, dinitro-
Phenol, 2-methyl-4,6-dinitro-
Phenol, 2-methyl-4,6-dinitro-
Benzene, l-methyl-2,4-dinitro-
Benzene, 2-methyl-l,3-dinitro-
Phenol, 2-(l-methylpropyl)-4,6-dinitro-
1,2-Benzenedicarboxylic acid, dioctyl ester
Benzenamine, N-phenyl-
Hydrazine, 1,2-diphenyl-
1 -Propanamine, N-nitroso-N-propyl-
Phosphorodithioic acid, O,O-diethyl S-[2-
(ethylthio)ethyl]ester.
Chemical
Abstract No.
84-66-2
297-97-2
56-53-1
94-58-6
55-91-4
60-51-5
119-90-4
60-11-7
57-97-6
119-90-4
79-44-7
57-14-7
540-73-8
122-09-8
105-67-9
131-11-3
77-78-1
25154-54-5
534-52-1
51-28-5
121-14-2
606-20-2
88-85-7
117-84-0
122-39-4
122-66-7
621-64-7
298-04-4
Hazardous
Waste No.
U088
P040
U089
U090
P043
P044
U091
U093
U094
U095
U097
U098
U099
P046
U101
U102
U103
P047
P047
P048
U105
U106
P020
U017
U109
Ulll
P039
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B6
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Dithiobiuret
Endothall
Endrin
Endrin metabolites
Epichlorohydrin
Epinephrine
Ethyl carbamate (urethane)
Ethyl cyanide
Ethylenebisdithiocarbamic acid
Ethylenebisdithiocarbamic acid,
salts and esters.
Ethylene dibromide
Ethylene dichloride
Ethylene glycol monoethyl ether
Ethyleneimine
Ethylene oxide
Ethylenethiourea
Ethylidene dichloride
Ethyl methacrylate
Ethyl methanesulfonate
Famphur
Fluoranthene
Fluorine
Fluoroacetamide
Formaldehyde
Formic acid
Glycidylaldehyde
Halomethanes, N.O.S.1
Chemical Abstracts Name
Thioimidodicarbonic diamide [(H3N)C(S)]2NH
7-Oxabicyclo[2.2.1]heptane-2,3-dicarboxylic
2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a- octa-hydro-,
( 1 aalpha,2beta,2abeta,3alpha,6alpha,
6abeta,7beta,7aalpha)- .
Oxirane, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy-2-(methylamino)ethyl]-,
(R)-.
Carbamic acid, ethyl ester
Propanenitrile
Carbamodithioic acid, 1,2-ethanediylbis-
Ethane, 1,2-dibromo-
Ethane, 1,2-dichloro-
Ethanol, 2-ethoxy-
Aziridine
Oxirane
2-Imidazolidinethione
Ethane, 1,1-dichloro-
2-Propenoic acid, 2-methyl-, ethyl ester
Methanesulfonic acid, ethyl ester
Phosphorothioic acid, 0-[4-
[(dimethylamino)sulfonyl]phenyl] O,O-di-methyl ester
Same
Same
Acetamide, 2-fluoro-, sodium salt
Same
Same
Oxiranecarboxy aldehyde
Chemical
Abstract No.
541-53-7
145-73-3
72-20-8
106-89-8
51-43-4
51-79-6
107-12-0
111-54-6
106-93-4
107-06-2
110-80-5
151-56-4
75-21-8
96-45-7
75-34-3
97-63-2
65-50-0
52-85-7
206-44-0
7782-41-4
62-74-8
50-00-0
64-18-6
765-34-4
Hazardous
Waste No.
P049
P088
P051
P051
U041
P042
U238
P101
U114
U114
U067
U077
U359
P054
U115
U116
U076
U118
U119
P097
U120
P056
P058
U122
U123
U126
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B7
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Heptachlor
Heptachlor epoxide
Heptachlor epoxide (alpha, beta, and
gamma isomers).
Heptachlorodibenzofurans
Heptachlorodibenzo-p-dioxins
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexchlorodibenzo-p-dioxins
Hexchlorodibenzofurans
Hexachloroethane
Hexachlorophene
Hexachloropropene
Hexaethyl tetraphosphate
Hydrazine
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
Indeno[l,2,3-cd]pyrene
Isobutyl alcohol
Isodrin
Isosafrole
Kepone
Lasiocarpine
Lead
Chemical Abstracts Name
4,7-Methano- IH-indene, 1 ,4,5,6,7,8,8-hep-tachloro-
3a,4,7,7a-tetrahydro-.
2,5-Methano-2H-indeno[l,2-b]oxirene, 2,3,4,5,6,7 ,7-
heptachloro-la,lb,5,5a,6,6a-hexa- hydro-, laalpha, Ibbeta,
2alpha, Salpha, Sabeta, 6beta, 6aalpha)-.
Benzene, hexachloro-
1 ,3-Butadiene, 1 , 1 ,2,3 ,4,4-hexachloro-
1,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro-
Ethane, hexachloro-
Phenol,2,2'-methylenebis[3,4,6-trichloro-
1 -Propene, 1 , 1 ,2,3 ,3,3-hexachloro-
Tetraphosphoric acid, hexaethyl ester
Same
Hydrocyanic acid
Hydrofluoric acid
Hydrogen sulfide H2S
Same
1-Propanol, 2-methyl-
1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-
l,4,4a,5,8,8a-hexahydro-,
( 1 alpha,4alpha,4abeta,5beta,8beta,8abeta)- .
1,3-Benzodioxole, S-(l-propenyl)-
l,3,4-Methano-2H-cyclobuta[cd]pentalen-2-one,
l,la,3,3a,4,5,5,5a,5b,6-decachlorooctahydro-.
2-Butenoic acid, 2-methyl-, 7-[[2,3-dihydroxy-2-(l-
methoxyethyl)-3-methyl-l-oxobutoxy]methyl]-2,3,5,7a-
tetrahydro-lH-pyrrolizin-1-yl ester, [S-
[lalpha(Z),7(2S*,3R*),7aalpha]]-
Same
Chemical
Abstract No.
76-44-8
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
757-58-4
302-01-2
74-90-8
7654-39-3
7738-06-4
193-39-3
78-83-1
465-73-6
120-58-1
143-50-0
303-34-1
7439-92-1
Hazardous
Waste No.
P059
U127
U128
U130
U131
U132
U243
P062
U133
P063
U134
U135
U134
U140
P060
U141
U142
4143
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B8
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Lead xompounds, N.O.S.1
Lead acetate
Lead phosphate
Lead subacetate
Lindane
Maleic anhydride
Maleic hydrazide
Malononitrile
Melphalan
Mercury
Mercury compounds, N.O.S.1
Mercury fulminate
Methacrylonitrile
Methapyrilene
Methomyl
Methoxychlor
Methyl bromide
Methyl chloride
Methyl chlorocarbonate
Methyl chloroform
3-Methylcholanthrene
4,4'-Methylenebis(2-chloroaniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK)
Methyl ethyl ketone peroxide
Methyl hydrazine
Methyl iodide
Methyl isocyanate
Chemical Abstracts Name
Acetic acid, lead(2+) salt
Phosphoric acid, lead(2+) salt (2:3)
Lead, bus(acetato-O)tetrahydroxytri-
Cyciohexane, 1 ,2,3,4,5,6-hexachloro-
,( 1 alpha,2alpha,3beta,4alpha,5alpha,6beta)- .
2,5-Furandione
3,6-Pyridazinedione, 1,2-dihydro-
Propanedinitrile
L-Phenylalanine, 4-[bis(2-chloroethyl)aminol]-.
Same
Fulminic acid, mercury(2+) salt
2Propenenitrile, 2-methyl-
1 ,2-Ethanediamine, NN-dimethyl-N'-2-pyridinyl-N'-(2-
thienylmethyl)-.
Ethanimidothioic acid, N-[[(methylamino)carbonyl]oxy]-,
methyl ester.
Benzene, l,l'-(2,2,2-trichloroethylidene)bis[4-methoxy-.
Methane, bromo-
Methane, chloro-
Carbonochloridic acid, methyl ester
Ethane, 1,1,1-trichloro-
Benz[j]aceanthrylene, l,2-dihydro-3-methyl
Benzenamine, 4,4'-methylenebis[2-chloro-
Methane, dibromo-
Methane, dichloro-
2-Butanone
2-Butanone, peroxide
Hydrazine, methyl-
Methane, iodo-
Methane, isocyanato-
Chemical
Abstract No.
301-04-2
7446-27-7
1335-32-6
58-89-9
108-31-6
123-33-1
109-77-3
148-82-3
7439-97-6
628-86-4
126-98-7
91-80-5
16752-77-5
72-43-5
74-83-9
74-87-3
79-22-1
71-55-6
56-49-5
101-14-4
74-95-3
75-09-2
78-93-3
1338-23-4
60-34-4
74-88-4
624-83-9
Hazardous
Waste No.
U144
U145
U146
U129
U147
U148
U149
U150
U151
P065
U152
U155
P066
U247
U029
U045
U158
U226
U157
U158
U068
U080
U159
U160
P068
U138
P064
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B9
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
2-Methyllactonitrile
Methyl methacrylate
Methyl methanesulfonate
Methyl parathion
Methylthiouracil
Mitomycin C
MNNG
Mustard gas
Naphthalene
1 ,4-Naphthoquinone
alpha-Naphthylamine
beta-Naphthylamine
alpha-Naphthylthiourea
Nickel
Nickel compounds, NO. S.1
Nickel carbonyl
Nickel cyanide
Nicotine
Nicotine salts
Nitric oxide
p-Nitroaniline
Nitrobenzene
Nitrogen dioxide
Nitrogen mustard
Nitrogen mustard, N-oxide, hydro-
chloride salt.
Nitroglycerin
p-Nitrophenol
2-Nitropropane
Chemical Abstracts Name
Propanenitrile, 2-hydroxy-2-methyl-
2-Propenoic acid, 2-methyl-methyl ester
Methanesulfonic acid, methyl ester
Phosphorothioic acid, O,O-dimethyl O-(4-nitrophenyl)
ester.
4(lH)-Pyrimidinone, 2,3-dihydro-6-methyl-2-thioxo-.
Azirino[2',3':3,4]pyrrolo[l,2-a]indole-4,7-dione, 6-amino-
8-[[(aminocarbonyl)oxy]methyl]-l,la,2,8,8a,8b-
hexahydro-8a-methoxy-5-methyl-, [laS-
laalpha,8beta,8aalpha,8balpha)]-.
Guanidine, N-methyl-N-nitro-N-nitroso-
Ethane, l,l'-thiobis[2-chloro-
Same
1 ,4-Naphthalenedione
1-Naphthalenamine
2-Naphthalenamine
Thiourea, 1-naphthalenyl-
Same
Nickel carbonyl Ni(CO)4, (T-4)-
Nickel cyanide Ni(CN)2
Pyridine, 3-(l-methyl-2-pyrrolidinyl)-, (S)-
Nitrogen oxide NO
Benzeneamine, 4-nitro-
Benzene, nitro-
Nitrogen dioxide NO2
Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl-, N-
oxide.
1,2,3-Propanetriol, trinitrate
Phenol, 4-nitro-
Propane, 2-nitro-
Chemical
Abstract No.
75-86-5
80-62-6
66-27-3
298-00-0
56-04-2
50-07-7
70-25-7
505-60-2
91-20-3
130-15-4
134-32-7
91-59-8
86-88-4
7440-02-0
13463-39-3
557-19-7
54-11-5
10102-43-9
100-01-6
98-95-3
10102-44-0
51-75-2
55-63-0
100-02-7
79-46-9
Hazardous
Waste No.
P069
U162
P071
U164
U010
U163
U165
U166
U167
U168
P072
P073
P074
P075
P075
P076
P077
U169
P078
P081
U170
U171
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B10
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Nitrosamines, N.O.S.1
N-Nitosodi-n-butylamine
N-Nitrosodiethanolamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitroso-N-ethylurea
N-Nitrosomethylethylamine
N-Nitroso-N-methylurea
N-Nitroso-N-methylurethane
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonomicotine
N-Nitrosopiperidine
N-Nitrosopyrolidine
N-Nitrososarcosine
5-Nitro-o-toluidine
Octamethylpyrophosphoramide
Osmium tetroxide
Paraldehyde
Parathion
Pentachlorobenzene
Pentachlorodibenzo-p-dioxins
Pentachlorodibenzofurans
Pentachloroethane
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
Phenacetin
Phenol
Phenylenediamine
Phenylmercury acetate
Chemical Abstracts Name
1-Butamine, N-butyl-N-nitroso
Ethanol, 2,2'-(nitrosoimino)bis-
Ethanamine, N-ethyl-N-nitroso-
Methanamine, N-methyl-N-nitroso-
Urea, N-ethyl-N-nitroso-
Ethanamine, N-methyl-N-nitoso-
Urea, N-methyl-N-nitroso-
Carbamic acid, methylnitroso, ethyl ester
Vinylamine, N-methyl-N-niroso-
Morpholine, 4-nitroso-
Pyridine, 3-(l-nitroso-2-pyrrolidinyl)-, (S)
Piperidine, 1-nitroso-
Pyrrolidine, 1-nitroso-
Glycine, N-methyl-N-nitroso-
Benzenamine, 2-methyl-5-nitro-
Diphosphoramide, octamethyl-
Osmium oxide OsO4 (T-4)-
1,3,5-Trioxane, 2,4,6-trimethyl-
Phosphorothioic acid, O,O-diethyl O-(4-nitro-phenyl)
ester.
Benzene, pentachloro-
Ethane, pentachloro-
Benzene, pentachloronitro-
Phenol, pentachloro-
Acetamide, N-(4-ethoxyphenyl)-
Same
Benzenediamine
Mercury, (acetato-O)phenyl-
Chemical
Abstract No.
35576-91-1D
924-16-3
1116-54-7
55-18-5
62-75-9
759-73-9
10595-95-6
684-93-5
615-53-2
4549-40-0
59-89-2
16543-55-8
100-75-4
930-55-2
13256-22-9
99-55-8
152-16-9
20816-12-0
123-63-7
56-38-2
608-93-5
76-01-7
82-68-8
87-86-5
62-44-2
108-95-2
25265-76-3
62-38-4
Hazardous
Waste No.
U172
U173
U174
P082
U176
U177
U178
P084
U179
U180
U181
P085
P087
U182
P089
U183
U184
U185
See F027
U187
U188
P092
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B11
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Phenylthiourea
Phosgene
Phosphine
Phorate
Phthalic acid esters, N.O.S.1
Phthalic anhydride
2-Picoline
Polychlorinated biphenyls, N.O.S.1
Potassium cyanide
Potassium silver cyanide
Pronamide
1,3-Propane sultone
n-Propylamine
Propargyl alcohol
Propylene dichloride
1 ,2-Propy lenimine
Propylthiouracil
Pyridine
Reserpine
Resorcinol
Saccharin
Saccharin salts
Safrole
Selenium
Selenium compounds, N.O.S.1
Selenium dioxide
Selenium sulfide
Selenourea
Silver
Silver compounds, N.O.S.1
Chemical Abstracts Name
Thiourea, phenyl-
Carbonic dichloride
Same
Phosphorodithioic, O,O-diethyl S-[(ethylthio)methyl] ester.
1 ,3-Isobenzofurandione
Pyridine, 2-methyl-
Potassium cyanide K(CN)
Argentate(l-), bis(cyano-C)-, potassium
Benzamide, 3,5-dichloro-N-( 1 , 1 -dimethyl-2-propynyl)- .
1,2-Oxathiolane, 2,2-dioxide
1-Propanamine
2-Propyn-l-ol
Propane, 1,2-dichloro-
Aziridine, 2-methyl-
4(lH)-Pyrimidinone, 2,3-dihydro-6-propyl-2 thioxo-.
Same
Yohimban-16-carboxylic acid, ll,17-dimeth-oxy-18-
[(3,4,5-trimethoxybenzoyl)oxy]-smethyl ester,
(Sbeta, 1 6beta, 1 Valpha, 1 8beta,20alpha> .
1,3-Benzenediol
1 ,2-Benzisothiazol-3(2H)-one, 1 ,1 -dioxide
1,3-Benzodioxole, 5-(2-propenyl)-
Same
Selenious acid
Selenium sulfide SeS2
Same
Same
Chemical
Abstract No.
103-85-5
75-44-5
7803-51-2
298-02-2
85-44-9
109-06-8
151-50-8
506-61-6
23950-58-5
1120-71-4
107-10-8
107-19-7
78-87-5
75-55-8
51-52-5
110-86-1
50-55-5
108-46-3
81-07-2
94-59-7
7782-49-2
7783-00-8
7488-56-4
630-10-4
7440-22-4
Hazardous
Waste No.
P093
P095
P096
P094
U190
U191
P098
P099
U192
U193
U194
P102
U083
P067
U196
U200
U201
U202
U202
U203
U204
U205
P103
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B12
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Silver cyanide
Silvex (2,4,5-TP)
Sodium cyanide
Streptozotocin
Strychnine
Strychnine salts
TCDD
1,2,4,5-Tetrachlorobenzene
Tetrachlorodibenzo-p-dioxins
Tetracholodibenzofurans
Tetrachloroethane, N.O.S.1
1,1,1 ,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
2,3,4,6-Tetrachlorophenol
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethyl pyrophosphate
Tetranitromethane
Thallium
Thallium compounds, N.O.S. 1
Thallic oxide
Thallium(l) acetate
Thallium(l) carbonate
Thallium(l) chloride
Thallium(l) nitrate
Thallium selenite
Thallium(l) sulfate
Thioacetamide
Thiofanox
Chemical Abstracts Name
Silver cyanide Ag(CN)
Propanoic acid, 2-(2,4,5-trichlorophenoxy)-
Sodium cyanide Na(CN)
D-Glucose, 2-deoxy-2-
[[(methylnitrosoamino)carbonyl]amino]-.
Strychnidin- 1 0-one
Dibenzob,e][l,4]dioxin, 2,3,7,8-tetrachloro-
Benzene, 1,2,4,5-tetrachloro-
Ethane, tetrachloro-, N.O.S.
Ethane, 1,1,1,2-tetrachloro-
Ethane, 1,1,2,-tetrachloro-
Ethene, tetrachloro-
Phenol, 2,3,4,6-tetrachloro-
Thiodiphosphoric acid, tertaethyl ester
Plumbane, tetraethyl-
Diphosphoric acid, tetraethyl ester
Methane, tetranitro-
Same
Thallium oxide T12O3
Acetic acid, thallium(l+) salt
Carbonic acid, dithallium(l+) salt
Thallium chloride T1C1
Nitric acid, thallium(l+) salt
Selenious acid, dithallium(l+) salt
Sulfuric acid, dithallium(l+) salt
Ethanethioamide
2-Butanone, 3,3-dimethyl-l-(methylthio)-, )-
[(methylamino)carbonyl] oxime.
Chemical
Abstract No.
506-64-9
93-72-1
143-33-9
18883-66-4
57-24-9
1746-01-6
95-94-3
25322-20-7
630-20-6
79-34-5
127-18-4
58-90-2
3689-24-5
78-00-2
107-49-3
509-14-8
7440-28-0
1314-32-5
563-68-8
6533-73-9
7791-12-0
10102-45-1
12039-52-0
7446-18-6
62-55-5
39196-18-4
Hazardous
Waste No.
P104
See F027
P106
U206
P108
P108
U207
U208
U209
U210
See F027
P109
P110
Pill
P112
P113
U214
U215
U216
U217
P114
P115
U218
P045
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B13
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Thiomethanol
Thiophenol
Thiosemicarbazide
Thiourea
Thiram
Toluene
Toluenediamine
Toluene-2,4-diamine
Touene-2,6-diamine
Toluene-3,4-diamine
Toluene diisocyanate
o-Toluidine
o-Toluidine hydrochloride
p-Toluidine
Toxaphene
1 ,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Trichloroethylene
Trichloromethanethiol
Trichloromonofluoromethane
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-1
Trichloropropane, N.O.S.1
1 ,2,3-Trichloropropane
O,O,O-Triethyl phosphorothioate
1,3,5-Tri nitrobenzene
Tris(l-aziridinyl)phosphine sulfide
Tris(2,3-dibromopropyl) phosphate
Chemical Abstracts Name
Methanethiol
Benzenethiol
Hydrazinecarbothioamide
Same
Thioperoxydicarbonic diamide [(H2N)C(S)]2S2 tetramethyl-
Benzene, methyl-
Benzenediamine, ar-methyl-
1,3-Benzenediamine, 4-methyl-
1,3-Benzenediamine, 2-methyl-
1,2-Benzenediamine, 4-methyl-
Benzene, 1,3-diisocyanatomethyl-
Benzenamine, 2-methyl-
Benzenamine, 2-methyl-, hydrochloride
Benzenamine, 4-methyl-
Same
Benzene, 1,2,4-trichloro
Ethane, 1,1,3-trichloro-
Ethene, trichloro-
Methanethiol, trichloro-
Methane, trichlorofluoro-
Phenol, 2,4,5-trichloro-
Phenol, 2,4,6-trichloro-
Acetic acid, (2,4,5-trichlorophenoxy)-
Propane, 1,2,3-trichloro-
Phosphorothioic acid, O,O,O-triethyl ester
Benzene, 1,3,5-trinitro-
Aziridine, l,l',l"-phosphinothioylidynetris-
1-Propanol, 2,3-dibromo-, phosphate (3:1)
Chemical
Abstract No.
74-93-1
108-98-5
79-19-6
62-56-6
137-26-8
108-88-3
25376-45-8
95-80-7
823-40-5
496-72-0
26471-62-5
95-53-4
636-21-5
106-49-0
8001-35-2
120-82-1
79-00-5
79-01-6
75-70-7
75-69-4
95-95-4
88-06-2
93-76-5
25735-29-9
96-18-4
126-68-1
99-35-4
126-72-7
Hazardous
Waste No.
U153
POM
P116
U219
U244
U220
U221
U223
U328
U222
U353
P123
U227
U228
P118
U121
See F027
See F027
See F027
U234
U235
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B14
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Trypan blue
Uracil mustard
Vanadium pentoxide
Vinyl chloride
Warfarin
Warfarin salts, when present at
concentrations less than 0.3%.
Warfarin salts, when present at
concentrations greater than 0.3%
Zinc cyanide
Zinc phosphide
Zinc phosphide
Chemical Abstracts Name
2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-di methyl[l,l'-
biphenyl]-4,4'-diyl)bis(azo)]-bis[5-amino-4-hydroxy-,
tetrasodium salt.
2,4-(lH,3H)-Pyrimidinedione, 5-[bis(2-
chloroethyl)amino]-.
Vanadium oxide V2O5
Ethene, chloro-
2H- 1 -Benzopyran-2-one, 4-hydroxy-3-(3-oxo- 1 -
phenylbutyl)-, when present at concentrations greater than
0.3%.
Zinc cyanide Zn(CN)2
Zinc phosphide Zn3P2, when present at concentrations
greater than 10%.
Zinc phosphide Zn3P2, when present at concentrations of
10% or less.
Chemical
Abstract No.
72-57-1
66-75-1
13-14-62-1
75-01-4
81-81-2
557-21-1
1314-84-7
1314-84-7
Hazardous
Waste No.
U236
U237
P120
U043
U248
U248
P001
P121
P122
U248
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B15
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
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This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. B16
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Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
and Recovery Act
Appendix C:
Commercial Chemical Products or Manufacturing Chemical
Intermediates Identified as Acute Hazardous Waste
(40 CFR 261.33(a) through 261.33(e))
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
(COMMENT: Primary hazardous properties of these materials have been indicated by the letters (t) (toxicity), and (r) (reactivity); absence
of a letter indicates that the compound only is listed for acute toxicity.)
Hazardous Waste No.
P023
P002
P057
P058
P002
POOS
P070
P004
POOS
P006
P007
POOS
P009
P119
P099
P010
P012
P011
P011
P012
P038
P036
P054
P067
P013
P024
P077
P028
P042
Substance
Acetaldehyde, chloro-
Acetamide, N-(aminothioxomethyl)-
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sodium salt
1 -Acetyl-2-thiourea
Acrolein
Aldicarb
Aldrin
Allyl alcohol
Aluminum phosphide (r,t)
5-(Aminomethyl)-3-isoxazolol
4-Aminopyridine
Ammonium picrate (r)
Ammonium vanadate
Argebtate(l), bis(cyano-C)-, potassium
Arsenic acid H3AsO4
Arsenic oxide As2O3
Arsenic oxide As2O5
Arsenic pentoxide
Arsenic trioxide
Arsine, diethyl
Arsonous dichloride, phenyl
Aziridine
Aziridine, 2-methyl
Barium cyanide
Benzenamine, 4-chloro-
Benzenamine, 4-nitro-
Benzene, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy- 2-(methylamino)ethyl]- (r)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C1
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P046
POM
P001
P028
P015
P016
P017
P018
P021
P021
P022
P095
P023
P024
P026
P027
P029
P029
P030
P031
P033
P033
P034
P016
P036
P037
P038
P041
P040
P043
Substance
Benzeneethanamine, alpha,alpha- dimethyl- (r)
Benzenethiol
2H-l-Benzopyran-2-one,4-hydroxy-3- (3-oxo-l-phenylbutyl)-, and salts when present at
concentrations greater than 0.3%
Benzyl chloride
Beryllium powder
Bis(chloromethyl)ether
Bromoacetone
Brucine
Calcium cyanide
Calcium cyanide Ca(CN)2
Carbon disulfide
Carbonic dichloride
Chloroacetaldehyde
p-Chloroaniline
1 -(o-Chlorophenyl)thiourea
3-Chloropropionitrile
Copper cyanide
Copper cyanide Cu(CN)
Cyanides (soluble cyanide salts), n.o.s.
Cyanogen
Cyanogen chloride
Cyanogen chloride (CN)C1
2-Cyclohexyl-4,6-dinitrophenol
Dichloromethyl ether
Dichlorophenylarsine
Dieldrin
Diethylarsine
Diethyl-p-nitrophenyl phosphate
O,O-Diethyl O-pyrazinyl phosphorothioate
Diisopropyl fluorophosphate (DEP)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C2
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P004
P060
P037
P051
P044
P045
P046
P047
P048
P020
P085
Pill
P039
P049
P050
P088
P051
P051
P042
P031
P066
P101
P054
P097
P056
P057
P058
P065
P059
Substance
l,4:5,8-Dimethanonapthalene, 1,2,3 ,4,10, 10-hexachloro-l,4,4a,5,8,8a- hexahydro,
4alpha,4abeta,5alpha, 8alpha,8abeta)-
1 ,4: 5,8-Dimethanonapthalene, 1 ,2,3,4, 10,1 0-hexachloro- 1 ,4,4a,5,8,8a- hexahydro-
4alpha,4abeta,5beta, 8beta,8abeta)-
(1 alpha,
, (1 alpha,
2,7:3,6-Dimethanonapth[2,3b]oxirane, 3,4,5,6,9,9-hexachloro-la,2,2a,3, 6,6a,7,7a-octahydro-,(l-
aalpha, 2beta,2aalpha,3beta,6beta,6aalpha, 7beta,7aalpha)-
2,7:3,6-Dimethanonapth[2,3b]oxirane, octahydro, (laalpha,2beta,2abeta,
3alpha,6alpha,6abeta,7beta,7aalpha)-
Dimethoate
3,3-Dimethyl-l-(methylthio)-2-butanone, O-[(methylamino)carbonyl]oxime
alpha,alpha-Dimethylphenethylamine
4,6-Dinitro-o-cresol and salts
2,4-Dinitrophenol
Dinoseb
Diphosphoramide,octamethyl-
Diphosphoric acid, tetraethyl ester
Disulfoton
Dithiobiuret
Endosulfan
Endothall
Endrin
Endrin and metabolites
Epinephrine
Ethanedinitrile
Ethanimidothioic acid, N-[[(methylamino)carbony] oxy]-, methyl ester
Ethyl cyanide
Ethyleneimine
Famphur
Fluorine
Fluoroacetamide
Fluoroacetic acid, sodium salt
Fulminic acid,mercury(2+)salt (r,t)
Heptachlor
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C3
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P062
P116
P068
P063
P063
P096
P064
P060
P007
P092
P065
P082
P064
P016
PI 12
P118
P050
P059
P066
P068
P064
P069
P071
P072
P073
P073
P074
P074
P075
P076
Substance
Hexaethyl tetraphosphate
Hydrazinecarbothioamide
Hydrazine, methyl-
Hydrocyanic acid
Hydrogen cyanide
Hydrogen phosphide
Isocyanic acid, methyl ester
Isodrin
3(2H)-Isoxazolone, 5-(aminomethyl)-
Mercury (acetato-O)phenyl-
Mercury fulminate (r,t)
Methanamine, N-methyl-N-nitroso
Methane, isocyanato-
Methane, oxybis[chloro-
Methane, tetranitro- (r)
Methanethiol, trichloro-
6,9-Methano-2,4,3-benzodioxathlepen, 6,7,8,9,10,10-hexachloro- l,5,5a,6,9,9a-hexahydro-,3-
oxide
4,7-Methano-lH-indene, 1,4,5,6,7,8,8- heptachloro-3a,4,7,7a-tetrahydro-
Methomyl
Methyl hydrazine
Methyl isocyanate
2-Methyllactonitrile
Methyl parathion
alpha-Naphthylthiourea
Nickel carbonyl
Nickel carbonyl, (T-4)-
Nickel cyanide
Nickel cyanide Ni(CN)2
Nicotine and salts
Nitric oxide
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C4
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P077
P078
P076
P078
P081
P082
P084
P074
P085
P087
P087
P088
P089
P034
P048
P047
P020
P009
P092
P093
P094
P095
P096
P041
P039
P094
P044
P043
P089
P040
P097
Substance
p-Nitroaniline
Nitrogen dioxide
Nitrogen oxide NO
Nitrogen oxide
Nitroglycerine (r)
N-Nitrosodimethylamine
N-Nitrosomethylvinylamine
Nickel cyanide
Octamethylpyrophosphoramide
Osmium oxide
Osmium tetroxide
7-Oxabicyclo[2.2.1]heptane-2,3- dicarboxylic acid
Parathion
Phenol, 2-cyclohexyl-4,6-dinitro
Phenol, 2,4-dinitro
Phenol, 2-methyl-4,6-dinitro- and salts
Phenol, 2-(l-methylpropyl)-4,6-dinitro
Phenol, 2,4,6-trinitro-, ammonium salt (r)
Phenylmercury acetate
Phenylthiourea
Phorate
Phosgene
Phosphine
Phosphoric acid, diethyl 4- nitrophenyl ester
Phosphorodithioic acid, O,O-diethyl S-[2-(ethylthio)ethyl] ester
Phosphorodithioic acid, O,O-diethyl S-[(ethylthio)methyl] ester
Phosphorodithioic acid, O,O-dimethyl S[2-(methylamino)-2-oxoethyl] ester
Phosphorofluoric acid, bis(l-methylethyl) -ester
Phosphorothioic acid, O,O-diethyl O- (4-nitrophenyl) ester
Phosphorothioic acid, O,O-diethyl O- pyrazinyl ester
Phosphorothioic acid, O-[4-[(dimethylamino) sulfonyljphenyl] O,O-dimethyl ester
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C5
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P071
P110
P098
P098
P099
P070
P101
P027
P069
P081
P017
P102
POOS
POOS
P067
P102
POOS
P075
P103
P104
P104
P105
P106
P106
P108
P018
P108
P115
P109
P110
Pill
Substance
Phosphorothioic acid, O,O-dimethyl O- (4-nitrophenyl) ester
Plumbane, tetraethyl-
Potassium cyanide
Potassium cyanide K(CN)
Potassium silver cyanide
Propanal, 2-methyl-2-(methylthio)-, O-[(methylamino)carbonyl]oxime
Propanenitrile
Propanenitrile, 3-chloro-
Propanenitrile, 2-hydroxy-2-methyl
1,2,3-Propanetriol, trinitrate (r)
2-Propanone, 1-bromo-
Propargyl alcohol
2-Propenal
2-Propen- 1 -ol
1 ,2-Propy lenimine
2-Propyn-l -ol
4-Pyridinamine
Pyridine, (S)-3-(l-methyl-2-pyrrolidinyl)-,(S)-, and salts
Selenourea
Silver cyanide
Silver cyanide Ag(CN)
Sodium azide
Sodium cyanide
Sodium cyanide Na(CN)
Strychnidin-10-one, and salts
Strychnidin 10-one, 2,3-dimethoxy-
Strychnine and salts
Sulfuric acid, dithallium(l) salt
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethylpyrophosphate
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C6
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
PI 12
P062
P113
P113
P114
P115
P109
P045
P049
POM
P116
P026
P072
P093
P123
P118
P119
P120
P120
P084
P001
P121
P121
P122
Substance
Tetranitromethane (r)
Tetraphosphoric acid, hexaethyl ester
Thallic oxide
Thallium(lll) oxide
Thallium(l) selenite
Thallium(l) sulfate
Thiodiphosphoric acid, tetraethyl ester
Thiofanox
Thiomidodicarbonic diamide
Thiophenol
Thiosemicarbazide
Thiourea, (2-chlorophenyl)-
Thiourea, 1-naphthalenyl-
Thiourea, phenyl-
Toxaphene
Trichloromethanethiol
Vanadic acid, ammonium salt
Vanadium oxide V2O3
Vanadium pentoxide
Vinylamine, N-methyl-N-nitroso
Warfarin and salts, when present at concentrations greater than 0.3%
Zinc cyanide
Zinc cyanide Zn(CN)2
Zinc phosphide Zn3P2, when present at concentrations greater than 0.3%
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
C7
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as Acute
Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
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This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. C8
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Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
and Recovery Act
Appendix D:
Potentially Incompatible Hazardous Wastes
(40 CFR 264, Appendix V)
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)
Below are examples of potentially incompatible wastes and waste components along with the harmful consequences
that result from mixing wastes in one group with wastes in another group. The list is intended as a guide to indicate the
need for special precautions when managing these potentially incompatible waste materials or components. This list is
not intended to be exhaustive. Operators must, as the regulations require, adequately analyze their wastes so they can
avoid creating uncontrolled substances or reactions of the type listed below, whether listed below or not.
In the lists below, the mixing of a Group A material with a Group B material may have the potential consequences as
noted.
Group 1-A
Group 1-B
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery acid
Caustic wastewater
Lime sludge and other corrosive alkalies
Lime wastewater
Lime and water
Spent caustic
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte, acid
Etching acid liquid or solvent
Pickling liquor and other corrosive acids
Spent acid
Spent mixed acid
Spent sulfuric acid
Potential Consequences: Heat generation, violent reaction.
Group 2-A
Group 2-B
Aluminum
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder
Other reactive metals and metal hydrides
Any waste in Group 1-A or 1-B
Potential Consequences: Fire or explosion; generation of flammable hydrogen gas.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D1
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)
Group 3-A
Group 3-B
Alcohols
Water
Any concentrated waste in
Groups 1-A or 1-B
Calcium
Lithium
Metal hydrides
Potassium
SO2-CI2, SOCIj, PCI3, CH3SICI3
Other water-reactive waste
Potential Consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.
Group 4-A
Group 4-B
Alcohols
Aldehydes
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and solvents
Concentrated Group 1-A or Group 1-B wastes
Group 2-A wastes
Potential Consequences: Fire, explosion, or violent reaction.
Group S-A
Spent cyanide and sulfide solutions
Group 5-B
Group 1-B wastes
Potential Consequences: Generation of toxid hydrogen cyanide, or hydrogen sulfide gas.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D2
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)
Group 6-A
Group 6-B
Chlorates
Chlorine
Chlorites
Chromic acid
Hypochlorites
Nitrates
Nitric acid, fuming
Perchlorates
Permanganates
Peroxides
Other strong oxidizers
Acetic acid and other organic acids
Concentrated mineral acids
Group 2-A wastes
Group 4-A wastes
Other flammable and combustible wastes
Potential Consequences: Fire, explosion, or violent reaction.
"Law, Regulations, and Guidelines for Handling of Hazardous Waste," California Department of Health, February
1975.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D3
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)
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This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. D4
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Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
and Recovery Act
Appendix E:
Land Disposal Restricted Wastes and Their Effective Dates
(40 CFR 268, Appendix VII)
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Table 1 - Land Disposal Restricted Wastes and Their Effective Dates
Waste Code
California list
California list
California list
California list
California list
RCRA Hazardous Wastes
RCRA Listed Wastes
D001
D002
D003
D004
D004
D005
D006
D007
D007
D008
D008
D009
D010
D011
D012
D013
DOM
D015
D016
Waste Category
Liquid hazardous wastes, including free liquids associated with solid
or sludge, containing free cyanides at concentrations greater than or
equal to 1000 mg/L or certain metals or compounds of these metals
greater than or equal to the prohibition levels.
Liquid (aqueous) hazardous wastes having a pH less than or equal to
2.
Dilute HOC wastewaters, defined as HOC-waste mixtures that are
primarily water and that contain greater than or equal to 1000 mg/L
but less than 10,000 mg/L.
Liquid hazardous waste containing PCBs greater than or equal to 50
ppm.
Other liquid and nonliquid hazardous wastes containing HOCs in
total concentration greater than or equal to 1000 mg.
Those that contain naturally occurring radioactive materials.
Mixed radioactive/hazardous wastes.
All
All
All
Wastewater
Nonwaste waters
Nonwaste water
All
All
All
Lead materials before secondary smelting
All others
Nonwaste water
All
All
All
All
All
All
All
Effective Date
8 July 1987
8 July 1987
8 July 1987
8 July 1987
8Novl988
8 May 1992
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E1
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
D017
F001
F001
F002 (1,1,2 -trichloroethane)
F002
F002
F003
F003
F004
F004
F005 (benzene, 2-ethoxy
ethanol, 2-nitropropane).
F005
F005
F006
F006
F006 (cyanides)
F007
F008
F009
F010
F011 (cyanides)
F011
F012 (cyanides)
F012
F019
Waste Category
All
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Wastewater and Nonwastewater
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Wastewater and Nonwastewater
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and soils.
All others
Wastewater
Nonwastewater
Nonwastewater
All
All
All
All
Nonwastewater
All others
Nonwastewater
All others
All
Effective Date
8 Aug 1990
8Novl988
8Novl986
8 Aug 1990
8Novl988
8Novl986
8Novl988
8Novl986
8Novl988
8Novl986
8 Aug 1990
8Novl988
8Novl986
8 Aug 1990
8 Aug 1988
8 July 1989
8 July 1989
8 July 1989
8 July 1989
8 June 1989
8 Dec 1986
8 July 1989
8 Dec 1989
8 July 1989
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E2
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
F020
F021
F022
F023
F024 (metals)
F024 (metals)
F024
F025
F026
F027
F028
F039
F039
K001 (organics)"
K001
K002
K003
K004
K004C
K005
K005C
K006
K007
K007C
K008
K008C
K009
K010
K011
K011
K013
Waste Category
All
All
All
All
Wastewater
Nonwaste water
All others
All
All
All
All
Wastewater
Nonwaste water
All
All others
All
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
All
Wastewater
Nonwaste water
Wastewater
Effective Date
8Novl988
8Novl988
8Novl988
8Novl988
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8Novl988
8Novl988
8Novl988
8 Aug 1990
8 May 1992
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1988
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E3
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K013
K014
K014
K015
K015
K016
K017
K018
K019
K020
K021
K021C
K022
K022
K023
K024
K025
K025C
K026
K027
K028 (metals)
K028
K029
K029
K030
K031
K031
K032
K033
K034
K035
Waste Category
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
All
All
All
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
All
Wastewater
Nonwaste water
All
All
Nonwaste water
All others
Wastewater
Nonwaste water
All
Wastewater
Nonwaste water
All
All
All
All
Effective Date
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 June 1989
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E4
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K036
K036c
K037"
K037
K038
K039
K040
K041
K042
K043
K044C
K045C
K046 (Nonreactive)
K046
K047
K048
K048
K049
K049
K050
K050
K051
K051
K052
K052
K060
K060C
K061
K061
K062
K069 (Non-Calcium Sulfate)0
Waste Category
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
All
All
All
All
All
All
all
Nonwaste water
All others
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwastewater (low zinc) (interim standard for high zinc remains in
effect until 7 Aug 1991).
All
Nonwastewater
Effective Date
8 June 1989
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8Novl990
8 Aug 1990
8Novl990
8 Aug 1990
8Novl990
8 Aug 1990
8Novl990
8 Aug 1990
8Novl990
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1988
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E5
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K069
K071
K073
K083
K084
K084
K085
K086 (organics)"
K086
K087
K093
K094
K095
K095
K096
K096
K097
K098
K099
K100
K100C
K101 (organics)
K101 (metals)
K101 (organics)
K101 (metals)
K102 (organics)
K102 (metals)
K102 (organics)
K102 (metals)
K103
K104
Waste Category
All others
All
All
All
Wastewater
Nonwaste water
All
All
All others
All
All
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
All
All
All
Wastewater
Nonwaste water
Wastewater
Wastewater
Nonwaste water
Nonwaste water
Wastewater
Wastewater
Nonwaste water
Nonwaste water
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 May 1992
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 May 1992
8 Aug 1988
8 Aug 1988
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E6
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K105
K106
K106
K113
K114
K115
K116
P001
P002
POOS
P004
POOS
P006
P007
POOS
P009
P010
P010
P011
P011
P012
P012
P013 (barium)
P013
POM
P015
P016
P017
P018
P020
P021
Waste Category
All
Wastewater
Nonwaste water
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Wastewater
Nonwaste water
Nonwaste water
All others
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 May 1992
8 June 1989
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E7
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
P022
P023
P024
P026
P027
P028
P029
P030
P031
P033
P034
P036
P036
P037
P038
P038
P039
P040
P041
P042
P043
P044
P045
P046
P047
P048
P049
P050
P051
P054
P056
Waste Category
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwaste water
All
Wastewater
Nonwaste water
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 May 1992
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E8
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
P057
P058
P059
P060
P062
P063
P064
P065
P065
P066
P067
P068
P069
P070
P071
P072
P073
P074
P075
P076
P077
P078
P079
P081
P082
P084
P085
P087
P088
P089
P092
Waste Category
All
All
All
All
All
All
All
Wastewater
Nonwaste water
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 May 1992
8 Aug 1990
8 June 1989
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E9
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
P092
P093
P094
P095
P096
P099 (silver)
P099
P101
P102
P103
PI 04 (silver)
P104
P105
P106
P108
P109
P110
Pill
PI 12
P113
P114
P115
P116
P118
P119
P120
P121
P122
P123
U001
U002
Waste Category
Nonwaste water
All
All
All
All
Wastewater
All others
All
All
All
Wastewater
All others
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 May 1992
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E10
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U003
U004
U005
U006
U007
U008
U009
U010
U011
U012
U014
U015
U016
U017
U018
U019
U020
U021
U022
U023
U024
U025
U026
U027
U028
U029
U030
U031
U032
U033
U034
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E11
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U035
U036
U037
U038
U039
U041
U042
U043
U044
U045
U046
U047
U048
U049
U050
U051
U052
U053
U055
U056
U057
U058
U059
U060
U061
U062
U063
U064
U066
U067
U068
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E12
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U069
U070
U071
U072
U073
U074
U075
U076
U077
U078
U079
U080
U081
U082
U083
U084
U084
U085
U086
U087
U088
U089
U090
U091
U092
U093
U094
U095
U096
U097
U098
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E13
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U099
U101
U101
U103
U105
U106
U107
U108
U109
U110
mil
U112
U113
U114
U115
U116
U117
U118
U119
U120
U121
U122
U123
U124
U125
U126
U127
U128
U129
U130
U131
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E14
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U132
U133
U134
U135
U136
U136
U137
U138
U140
U141
U142
U143
U144
U145
U146
U147
U148
U149
U150
U151
U151
U152
U153
U154
U155
U156
U157
U158
U159
U160
U161
Waste Category
All
All
All
All
Wastewater
Nonwaste water
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwaste water
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E15
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U162
U163
U164
U165
U166
U167
U168
U169
U170
U171
U172
U173
U174
U176
U177
U178
U179
U180
U181
U182
U183
U184
U185
U186
U187
U188
U189
U190
U191
U192
U193
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E16
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U194
U196
U197
U200
U201
U202
U203
U204
U205
U206
U207
U208
U209
U210
U211
U212
U213
U214
U215
U216
U217
U218
U219
U220
U221
U222
U223
U225
U226
U227
U228
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E17
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U234
U235
U236
U237
U238
U239
U240
U243
U244
U246
U247
U248
U249
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
a This table also does not include contaminated soil and debris wastes.
b The standard has been revised in the Third Third Final Rule.
c No land disposal standard has been revised in the Third Third Final Rule.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E18
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Table 2 - Summary of Effective Dates of Land Disposal Restrictions
for Contaminated Soil and Debris (CSD)
1.
2.
3.
4.
5.
6.
1.
8.
9.
Restricted hazardous waste in CSD
Solvent-(FOOl-FOOS) and dioxin-(F020-F023 and F026-F028) containing soil and
debris from CERCLA response of RCRA corrective actions.
Soil and debris not from CERCLA response or RCRA corrective actions
contaminated with less than 1% total solvents (F001-F005) or dioxins (F020-F023
and F026-F028).
Soil and debris contaminated with California list HOCs from CERCLA response or
RCRA corrective actions.
Soil and debris contaminated with California list HOCs not from CERCLA
response or RCRA corrective actions.
All soil and debris contaminated with First Third wastes for which treatment
standards are based on incineration.
All soil and debris contaminated with Second Third wastes for which treatment
standards are based on incineration.
All soil and debris contaminated with Third Third wastes or, First or Second Third
"soft hammer" wastes which had treatment standards promulgated in the Third
Third rule, for which treatment standards are based on incineration, vitrification, or
mercury retorting, acid leaching followed by chemical precipitation, or thermal
recovery of metals; as well as all inorganic solids debris contaminated with D004-
D01 1 wastes, and all soil and debris contaminated with mixed RCRA/radioactive
wastes.
Debris that is contaminated with wastes listed in 40 CFR 268. 10, 268.11, and
268.12 (including such wastes that are mixed radioactive hazardous wastes), and
debris that is contaminated with any characteristic waste for which treatment
standards are established (including such wastes that are mixed radioactive
hazardous wastes).
Hazardous soil having treatment standards based on incineration, mercury retorting
or vitrification, and soils contaminated with hazardous wastes listed in 40 CFR
268.10, 268.1 1, 268.12 that are mixed radioactive hazardous wastes.
Effective Date
8Novl990
8Novl990
8Novl990
8 July 1989
8 Aug 1990
8 June 1991
8 May 1993
8 May 1993
8 May 1993
NOTE:
1. Appendix VII is provided for the convenience of the reader.
2. Contaminated Soil and Debris Rule will be promulgated in the future.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E19
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
THIS PAGE INTENTIONALLY LEFT BLANK
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. E20
-------
Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
and Recovery Act
Appendix F:
Constituent Concentrations in Waste Extract (40 CFR 268.411)
-------
THIS PAGE INTENTIONALLY LEFT BLANK
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix F: Constituent Concentrations in Waste Extract (40 CFR 268.411)
Waste Code
D004*
Arsenic (CAS 7440-38-2)
D005*
Barium (CAS 7440-39-3)
D006*
Cadmium (CAS 7440-43-9)
D007*
Chromium (Total) (CAS 7440-47-32)
D008*
Lead (CAS 7439-92-1)
D009** (Low Mercury Subcategory less than 260 mg/kg)
Mercury (CAS 7439-97-6)
D010*
Selenium (CAS 7782-49-2)
D011*
Silver (CAS 7440-22-4)
F001-F005** (spent solvents)
Acetone (CAS 67-64-1)
n-Butyl alcohol (CAS 71-36-3)
Carbon disulfide (CAS 75-15-0)
Carbon tetrachloride (CAS 56-23-5)
Chlorobenzene (CAS 108-90-7)
Cresols (and cresylic acid)
Cyclohexanone (CAS 108-94-1)
1,2-Dichlorobenzene (CAS 95-50-1)
Ethyl acetate (CAS 141-78-6)
Ethylbenzene (CAS 100-41-4)
Ethyl ether (CAS 60-29-7)
Isobutanol (CAS 78-83-1)
Methanol (CAS 67-56-1)
Methylene chloride (CAS 75-9-2)
Methyl ethyl ketone (CAS 78-93-3)
Methyl isobutyl ketone (CAS 108-10-1)
Nitrobenzene (CAS 98-95-3)
Pyridine(CAS 110-86-1)
Tetrachloroethylene (CAS 127-18-4)
Toluene (CAS 108-88-3)
1,1,1-Trichloroethane (CAS 71-55-6)
l,l,2-Trichloro-l,2,2-Trifloroethane (CAS 76-13-1) Trichloroethylene
(CAS 79-01-6)
Trichlorofloromethane (CAS 75-69-4)
Xylene
F006*
Cadmium (CAS 7440-43-9)
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
Silver (CAS 7440-22-4)
Concentration (mg/L)
Wastewater
NA
NA
NA
NA
NA
NA
NA
NA
0.05
5.0
NA
0.05
0.15
2.82
NA
0.65
0.05
0.05
0.05
5.0
NA
0.20
0.05
0.05
0.66
1.12
0.079
1.12
1.05
1.05
0.062
0.05
0.05
NA
NA
NA
NA
NA
Non- Wastewater
5.0***
100
1.0
5.0
5.0
0.20
5.7
5.0
0.59
5.0
4.8
0.96
0.05
0.75
0.75
0.125
0.75
0.053
0.75
5.0
0.75
0.96
0.75
0.33
0.125
0.33
0.05
0.33
0.41
0.96
0.091
0.96
0.15
0.066
5.2
0.51
0.32
0.072
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
F1
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix F: Constituent Concentrations in Waste Extract (40 CFR 268.411)
Waste Code
F007*, F008*, F009*, F01 1* and F012*
Cadmium (CAS 7440-43-9)
Chromium (total)(CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
Silver (CAS 7440-22-4)
F019* Chromium (Total) (CAS 7440-47-32)
F020-F023 and F026-F026 dioxin containing wastes (same for wastewaters
and non-wastewaters)
FfxCDD-AH Hexachlorodibenzo-p-dioxins
FfxCDF— All Hexachlorodibenzofurans
PeCDD-AH Pentachlorodibenzo-p-dioxins
PeCDF— All Pentachlorodibenzofurans
TCDD-AH Tetrachlorodibenzo-p-dioxins
TCDF-- All Tetrachlorodibenzofurans
2,4,5-Trichorophenol (CAS 95-95-4)
2,4,6- Trichorophenol (CAS 86-06-2)
2,3,4,6-Tetrachlorophenol (CAS 58-90-2)
Pentachlorophenol (CAS 87-66-5)
F024*
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
F037*
Chromium(total)
Nickel
F038*
Chromium(total)
Nickel
F039*
Antimony (CAS 7440-36-0)
Arsenic (CAS 7440-38-2)
Barium (CAS 7440-39-3)
Cadmium (CAS 7440-43-9)
Chromium (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Mercury (CAS 7439-97-6)
Nickel (CAS 7440-02-0)
Selenium (CAS 7782-49-2)
Silver (CAS 7440-22-4)
K001*
Lead (CAS 7439-92-1)
K002*, K003*, K004*, and K005*
Chromium(Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K006* (anhydrous)
Chromium (Total) (CAS 7440-47-32
Lead (CAS 7439-92-1)
Concentration (mg/L)
Wastewater
NA
NA
NA
NA
NA
NA
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppm
<0.05 ppm
<0.05 ppm
<0.01 ppm
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Non- Wastewater
0.066
5.2
0.51
0.32
0.072
5.2
0.073
Reserved
0.088
1.7
0.20
1.7
0.20
0.23
5.0
52
0.066
5.2
0.51
0.025
0.32
5.7
0.072
0.51
0.094
0.37
0.094
0.37
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
F2
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix F: Constituent Concentrations in Waste Extract (40 CFR 268.411)
Waste Code
K006* (hydrated)
Chromium (Total) (CAS 7440-47-32)
K007* and K008*
Chromium(Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K015*
Chromium(Total) (CAS 7440-47-32)
Nickel (CAS 7440-02-0)
K021*
Antimony (CAS 7440-36-0)
K022*
Chromium(Total) (CAS 7440-47-32)
Nickel (CAS 7440-02-0)
K028*
Chromium(Total) (CAS 74440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
K031*
Arsenic (CAS 7440-38-2)
K046*
Lead (CAS 7439-92-1)
K048*, K049*, K050*, K051*, and K052* Chromium(Total) (CAS 7440-
47-32)
Nickel (CAS 7440-02-0)
K061*
antimony
arsenic
barium
beryllium
cadmium
chromium (total)
lead
mercury
nickel
selenium
silver
thallium
zinc
K062*
Chromium (Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K069** (Calcium Sulfate subcategory)
Cadmium (CAS 7440-43-9)
Lead (CAS 7439-92-1)
Concentration (mg/L)
Wastewater
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Non- Wastewater
5.2
0.094
0.37
1.7
0.2
0.23
5.2
0.32
0.073
0.021
0.088
5.6*
0.18
1.7
0.20
2.1
0.055
7.6
0.014
0.19
0.33
0.37
0.009
5.
0.16
0.3
0.078
5.3
0.094
0.37
0.1
40.24
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
F3
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix F: Constituent Concentrations in Waste Extract (40 CFR 268.411)
Waste Code
K071*
Mercury (CAS 7439-97-6)
K083*
Nickel (CAS 7440-02-2)
K084*
Arsenic (CAS 7440-38-2)
K086*
Chromium(Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K087*
Lead (CAS 7439-92-1)
K100*
Cadmium (CAS 7440-43-9)
Chromium(Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K101*andK102*
Arsenic (CAS 7440-38-2)
K106** (Low Mercury Subcategory— less than 260 mg/kg residues from
RMERC)
Mercury (CAS 7439-97-6)
K106** (Low Mercury Subcategory— less than 260 mg/kg that are not
residues from RMERC) Mercury (CAS 7439-97-6)
K115*
Nickel (CAS 7440-02-0)
P010* (Arsenic acid)**
Arsenic (CAS 7440-38-2)
P011* (Arsenic pentoxide)
Arsenic (CAS 7440-38-2)
P012* (Arsenic trioxide)
Arsenic (CAS 7440-38-2)
P013* (Barium cyanide)
Barium (CAS 7440-39-3)
P036* (Dichlorophenylarsine)
Arsenic (CAS 7440-38-2)
P038* (Diethylarsine)
Arsenic (CAS 7440-38-2)
P065** (Low Mercury Subcategory— less than 260 mg/kg Mercury
residues from RMERC) (mercury fulminate)
Mercury (CAS 7439-97-6)
Concentration (mg/L)
Wastewater
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Non- Wastewater
0.025
0.088
5.6*
0.094
0.37
0.51
0.066
5.2
0.51
5.6*
0.020
0.025
0.32
5.6*
5.6*
5.6*
52
5.6*
5.6*
0.20
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
F4
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix F: Constituent Concentrations in Waste Extract (40 CFR 268.411)
Waste Code
P065** (Low Mercury Subcategory— less than 260 mg/kg Mercury
incinerator residues (not residues from RMERC) (Mercury fulminate)
Mercury (CAS 7439-97-6)
P073* (Nickel carbonyl)
Nickel (CAS 7440-02-0)
P074* (Nickel cyanide)
Nickel (CAS 7440-02-0)
P092** (Low Mercury Subcategory— less than 260 mg/kg Mercury
residues from RMERC)(Phenyl mercury acetate)
Mercury (CAS 7439-97-6)
P092** (Low Mercury Subcategory— less than 260 mg/kg Mercury-
incinerator residues(not residues from RMERC) (Phenyl mercury acetate)
Mercury (CAS 7439-97-6)
P099* (Potassium silver cyanide)
Silver (CAS 7440-22-4)
PI 03* (Selenourea)
Selenium (CAS 7782-49-2)
P104* (Silver cyanide)
Silver (CAS 7440-22-4)
PI 10* (Tetraethyl lead)
Lead (CAS 7439-92-1)
PI 14* (Thallium selenite)
Selenium (CAS 7782-49-2)
U032* (Calcium chromate)
Chromium(Total) (CAS 7440-47-32)
UO51* (Creosote)
Lead (CAS 7439-92-1)
U136*(Cacodylicacid)
Arsenic (CAS 7440-38-2)
U144* (Lead acetate)
Lead (CAS 7439-92-1)
U145* (Lead phosphate)
Lead (CAS 7439-92-1)
U146* (Lead subacetate)
Lead (CAS 7439-92-1)
Concentration (mg/L)
Wastewater
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Non- Wastewater
0.025
0.32
0.32
0.20
0.025
0.072
5.7
0.072
0.51
5.7
0.094
0.51
5.6*
0.51
0.51
0.51
* See also Appendix 4-10, Table CCW in 40 CFR 268.43.
** See also Appendix 4-9, Table 2 in 40 CFR 268.42.
*** These treatment standards have been based on EP Leachate analysis but this does not preclude the use of TCLP analysis.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
F5
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Protocol for Conducting Environmental Compliance Audits of
Treatment, Storage and Disposal Facilities under the Resource
Conservation and Recovery Act
Appendix G:
Treatment Methods Expressed as Specific Technologies
(40 CFR 268.42)
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Table 1 - Technology Codes and Description of Technology-Based Standards
Technology
Code
ADGAS
AMLGM
BIODG
CARBN
CHOXD
CHRED
DEACT
FSUBS
HLVIT
IMERC
INCIN
Description of Technology-Based Standards
Venting of compressed gases into an absorbing or reacting media (i.e., solid or liquid)— venting can be
accomplished through physical release utilizing valves/piping; physical penetration of the container;
and/or penetration through detonation.
Amalgamation of liquid, elemental mercury contaminated with radioactive materials utilizing inorganic
reagents such as copper, zinc, nickel, gold, and sulfur that result in a nonliquid, semi-solid amalgam and
thereby reducing potential emissions of elemental mercury vapors to the air.
Biodegradation of organics or non-organics (i.e., degradable inorganics that contain the elements of
phosphorus, nitrogen, and sulfur) in units operated under either aerobic or anaerobic conditions such that
a surrogate compound or indicator parameter has been substantially reduced in concentration in the
residuals (e.g., Total Organic Carbon can often be used as an indicator parameter for the biodegradation of
many organic constituents that cannot be directly analyzed in wastewater residues).
Carbon adsorption (granulated or powered) of non- metallic inorganics, organo-metallics, and/or organic
constituents, operated such that a surrogate compound or indicator parameter has not undergone
breakthrough (e.g., Total Organic Carbon can often be used as an indicator parameter for absorption of
many organic constituents that cannot be directly analyzed in wastewater residues). Breakthrough occurs
when the carbon has become saturated with the constituent (or indicator parameter) and substantial change
in adsorption rate associated with that constituent occurs.
Chemical or electrolytic oxidation utilizing the following oxidation reagents (or waste reagents) or
combinations of reagents: (1) hypochlorite (e.g. bleach); (2) chlorine; (3) chlorine dioxide; (4) ozone or
UV (ultraviolet light) assisted ozone; (5) peroxides; (6) persulfates; (7) perchlorates; (8) permanganates;
and/or (9) other oxidizing reagents of equivalent efficiency, performed in units operated such that a
surrogate compound or indicator parameter has been substantially reduced in concentration in the
residuals (e.g., Total Organic Carbon can often be used as indicator parameter for the oxidation of many
organic constituents that cannot be directly analyzed in wastewater residues). Chemical oxidation
specifically indicates what is commonly referred to as alkaline chlorination.
Chemical reduction utilizing the following reducing reagents (or waste reagents) or combinations of
reagents: (1) sulfur dioxide; (2) sodium, potassium, or alkali salts or sulfides, bisulfites, metabisulfites,
and polyethylene glycols (e.g., NaPEG and KPEG); (3) sodium hydrosulfide; (4) ferrous salts; and/or (5)
other reducing reagents of equivalent efficiency, performed in units operated such that a surrogate
compound or indicator parameter has been substantially reduced in concentration in the residuals (e.g.,
Total Organic Halogens can often be used as an indicator parameter for the reduction of many halogenated
organic constituents that cannot be directly analyzed in wastewater residues). Chemical reduction is
commonly used for the reduction of hexavalent chromium to the trivalent state.
Deactivation to remove the hazardous characteristics of a waste due to its ignitability, corrosivity, and/or
reactivity.
Fuel substitution in units operated in accordance with applicable technical operating requirements.
Vitrification of high level mixed radioactive wastes in units in compliance with all applicable radioactive
protection requirements under control of the Nuclear Regulatory Commission.
Incineration of wastes containing organics and mercury in units operated in accordance with the technical
operating requirements of 40 CFR part 264 subpart O and part 265 subpart O. All wastewater and
nonwastewater residues derived from this process must then comply with the corresponding treatment
standards per waste code with consideration of any applicable subcategories (e.g., High or Low Mercury
Subcategories).
Incineration in units operated in accordance with the technical operating requirements of 40 CFR part 264
subpart O and part 265 subpart O.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G1
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Technology
Code
LLEXT
MACRO
NEUTRO
NLDBR
PRECP
RBERY
RCGAS
RCORR
RLEAD
RMERC
RMETL
Description of Technology-Based Standards
Liquid-liquid extraction (often referred to as solvent extraction) of organics from liquid wastes into an
immiscible solvent for which the hazardous constituents have a greater solvent affinity, resulting in an
extract high in organics that must undergo either incineration, reuse as a fuel, or other recovery/reuse and
a raffmate (extracted liquid waste) proportionately low in organics that must undergo further treatment as
specified in the standard.
Macroencapsulation with surface coating materials such as polymeric organic (e.g. resins and plastics) or
with a jacket or inert inorganic materials to substantially reduce surface exposure to potential leaching
media. Macroencapsulation specifically does not include any material that would be classified as a tank or
container according to 40 CFR 260. 10.
Neutralization with the following reagents (or waste reagents) or combination or reagents: (1) acids; (2)
bases; or (3) water (including wastewaters) resulting in a pH greater than 2 but less than 12.5 as measured
in the aqueous residuals.
No land disposal based on recycling.
Chemical precipitation of metals and other inorganics as insoluble precipitates of oxides, hydroxides,
carbonates, sulfates, chlorides, fluorides, or phosphates. The following reagents (or waste reagents) are
typically used alone or in combination: (1) lime (i.e., containing oxides and/or hydroxides of calcium
and/or magnesium; (2) caustic (i.e., sodium and/or potassium hydroxides; (3) soda ash (i.e., sodium
carbonate); (4) sodium sulfide; (5) ferric sulfate or ferric chloride; (6) alum; or (7) sodium sulfate.
Additional floculating, coagulation or similar reagents/processes that enhance sludge dewatering
characteristics are not precluded from use.
Thermal recovery of Beryllium.
Recovery/reuse of compressed gases including techniques such as reprocessing of the gases for
reuse/resale; filtering/adsorption of impurities; remixing for direct reuse or resale; and use of the gas as a
fuel source.
Recovery of acids or bases utilizing one or more of the following recovery technologies: (1) distillation
(i.e., thermal concentration); (2) ion exchange; (3) resin or solid adsorption; (4) reverse osmosis; and/or
(5) incineration for the recovery of acid— Note: this does not preclude the use of other physical phase
separation or concentration techniques such as decantation, filtration (including ultrafiltration), and
centrifugation, when used in conjunction with the above listed recovery technologies.
Thermal recovery of lead in secondary lead smelters.
Retorting or roasting in a thermal processing unit capable of volatilizing mercury and subsequent
condensing the volatilized mercury for recovery. The retorting or roasting in a thermal unit (or facility)
must be subject to one or more of the following: (a) a National Emissions Standard for Hazardous Air
Pollutants (NESHAP) for mercury; (b) a Best Available Control Technology (BACT) or a Lowest
Achievable Emission Rate (LAER) standard for mercury imposed pursuant to a Prevention of Significant
Deterioration (PSD) permit; or (c) a state permit that establishes emission limitations (within meaning of
section 302 of the Clean Air Act) for mercury. All wastewater and nonwastewater residues derived from
this process must then comply with the corresponding treatment standards per waste code with
consideration of any applicable subcategories (e.g., High or Low Mercury Subcategories).
Recovery of metals or inorganics utilizing one or more of the following direct physical/removal
technologies: (1) ion exchange; (2) resin or solid (i.e., zeolites) adsorption; (3) reserve osmosis; (40
chelation/solvent extraction; (5) freeze crystallization; (6) ultrafiltration and/or (7) simple precipitation
(i.e., crystallization)— Note: This does not preclude the use of other physical phase separation or
concentration techniques such as decantation, filtration (including ultrafiltration), and centrifugation,
when used in conjunction with the above listed recovery technologies.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G2
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Technology
Code
RORGS
RTHRM
RZINC
STABL
SSTRP
WETOX
WTRRX
Description of Technology-Based Standards
Recovery of organics utilizing one or more of the following technologies: (1) distillation; (2) thin film
evaporation; (3) steam stripping; (4) carbon adsorption; (5) critical fluid extraction; (6) liquid-liquid
extraction; (7) precipitation/crystallization (including freeze crystallization); or (8) chemical phase
separation techniques (i.e., addition of acids, bases, demulsifiers, or similar chemicals);— Note: this does
not preclude the use of other physical phase separation techniques such as a decantation, filtration
(including ultrafiltration), and centrifugation, when used in conjunction with the above listed recovery
technologies.
Thermal recovery of metals or inorganics from nonwastewaters in units identified as industrial furnaces
according to 40:260.10 (1), (6), (7), (11), and (12) under the definition of "industrial furnaces".
Resmelting in high temperature metal recovery units for the purpose of recovery of zinc.
Stabilization with the following reagents (or waste reagents) or combinations of reagents: (1) Portland
cement; or (2) lime/pozzolans (e.g., fly ash and cement kiln dust)— this does not preclude the addition of
reagents (e.g., iron slats, silicates, and clays) designed to enhance the set/cure time and/or compressive
strength, or to overall reduce the leachability of the metal or inorganic.
Steam stripping of organics from liquid wastes utilizing direct application of steam to the wastes operated
such that liquid and vapor flow rates, as well as, temperature and pressure ranges have been optimized,
monitored, and maintained. These operating parameters are dependent upon the design parameters of the
unit such as, the number of separation stages and the internal column design. Thus, resulting in a
condensed extract high in organics that must undergo either incineration, reuse as a fuel, or other
recovery/reuse and an extract wastewater that must undergo further treatment as specified in the standard.
Wet air oxidation performed in units such that a surrogate compound or indicator parameter has been
substantially reduced in concentration in the residuals (e.g., Total Organic Carbon can often be used as an
indicator for the oxidation of many organic constituents that cannot be directly analyzed in wastewater
residues).
Controlled reaction with water for highly reactive inorganic or organic chemicals with precautionary
controls for protection of workers from potential violent reactions as well as precautionary controls for
potential emissions of toxic/ignitable levels of gases released during the reaction.
Note 1: When a combination of these technologies (i.e., a treatment train) is specified as a single treatment standard, the order of
application is specified in 268.42, Table 2 by the five letter technology code that must be applied first, then the designation "fb"
(abbreviation for "followed by"), then the five letter technology code for the technology that must be applied next, and soon.
Note 2: When more than one technology (or treatment train) are specified as alternative treatment standards, the five letter technology
codes (or the treatment trains) are separated by a semicolon (;) with the last technology preceded by the word "or". This
indicates that any one of these BDAT technologies or treatment trains can be used for compliance with the standard.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G3
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Table 2 - Technology-Based Standards by RCRA Waste Codes
Waste Code
D001
Ignitable liquids based on 261 .21(a)(l) wastewaters
D001
Ignitable liquids based on 261.21(a)(l)Low TOC ignitable liquids
subcategory Less than 10% TOC
D001
Ignitable Liquids based on 261.21(a)(l)High TOC ignitable liquids
subcategory Greater than or equal to 10% TOC
D001
Ignitable compressed gases based on 261.21(a)(2)
D001
Ignitable reactives based on 261.21(a)(4)
D002
Acid subcategory based on 261.22(a)(l)
D002
Akaline subcategory based on 261.22(a)(l)
D002
Other corrosives based on 261.22(a)(2)
(NOTE: the following language under D003 reactive sulfides wastewater, "...
but not including dilution as a substitute for adequate treatment," is
suspended until 6-17-93; see FR 14319 3-17-93)
D003
Reactive sulfides based on 261.23(a)(5) but not including dilution as a
substitute for adequate treatment
D003
Explosives based on 261 .23(a)(6— 8)
D003
Water reactives based on 261.23(a)(2-4)
D003
Other reactives based on 261.23(a)(l)
D006 (CAS 7440-43-9)
Cadmium containing batteries
D008 (CAS 7439- 92-1)
Lead acid batteries that are identified as RCRA hazardous waste and that are
not excluded from regulation (see 40:268.80)
D009*** (CAS 7439-97-6)
Mercury (High Mercury subcategory— greater than or equal to 260 mg/kg
total mercury and organics (and are not incinerator residues))
Technology Code
Wastewaters
DEACT
NA
NA
NA
NA
DEACT
DEACT
DEACT
DEACT
DEACT
NA
DEACT
NA
NA
NA
Non- Wastewaters
NA
DEACT
FSUBS; RORGS or
INCIN
DEACT***
DEACT
DEACT
DEACT
DEACT
DEACT
DEACT
DEACT
DEACT
RTHRM
RLEAD
IMERC; or RMERC
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G4
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
D009*** (CAS 7439-97-6)
Mercury (High Mercury subcategory— greater than or equal to 260 mg/kg
total mercury inorganics (including incinerator residues and residues from
RMERC))
D012** (CAS 72-20-8)
Endrin
D013** (CAS 58-89-9)
Lindane
D014** (CAS 72-43-5)
Methoxychlor
D015** (CAS 8001-35-1)
Toxaphene
D016** (CAS 94-75-7)
2,4-D
D017** (CAS 93-72-1)
2,4,5-TP
F005*** (CAS 79-46-9)
2-Nitropropane
F005*** (CAS 110-80-5)
2-Ethoxyethanol
F024***
K025
Distillation bottoms from the production of nitrobenzene by the nitration of
benzene
K026
Stripping still tails form the production of methyl ethyl pyridines
K027
Centrifuge and distillation residues from toluene diisocyanate production
K039
Filter cake from the filtration of diethylphosphorodithioic acid in the
production of phorate
K044
Wastewater treatment sludges from the manufacturing and processing of
explosives
K045
Spent carbon from the treatment of wastewater containing explosives
K047
Pink/red water from TNT operations
Technology Code
Wastewaters
NA
BIODG; or
INCIN
CARBN; or
INCIN
WETOX; or
INCIN
BIODG; or
INCIN
CHOXD; BIODG
or INCIN
CHOXD or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
BIODG; or
INCIN
INCIN
LLEXT fb
SSTRPfb
CARBN; or
INCIN
INCIN
CARBN or
INCIN
CARBN or
INCIN
DEACT
DEACT
DEACT
Non-Wastewaters
RMERC
NA
NA
NA
NA
NA
NA
INCIN
INCIN
INCIN
INCIN
INCIN
FSUBS or INCIN
FSUBS or INCIN
DEACT
DEACT
DEACT
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G5
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
K069***
Emission control dust/sludge from secondary lead smelting: Non-Calcium
Sulfate Subcategory
K106***
Wastewater treatment sludge from the mercury cell process in chlorine
production: (High mercury subcategory— greater than or equal to 260 mg/kg
total mercury.)
K107
Column bottoms from product separation from the production of 1,1-
dimethylhydrazine (UDMH) from carboxylic acid hydrazides
K108
Condensed column overheads from product separation and condensed reactor
vent gases from the production of 1,1-dimethyl-hydrazine (UDMH) from
carboxylic acid hydrazides.
K109
Spent filter cartridges from product purification from the production of 1,1-
dimethylhydrazine (UDMH) from carboxylic acid hydrazides
K110
Condensed column overheads from intermediate separation from the
production of 1,1-dimethylhydrazine (UDMH) from carboxylic acid
hydrazides
K112
Reaction by-product water from the drying column in the production of
toluenediamine via hydrogenation of dinitrotoluene
K113
Condensed liquid light ends from the purification of toluenediamine in the
production of toluenediamine via hydrogenation of dinitrotulene
K114
Vicinals from the purification of toluenediamine in the production of
toluenediamine via hydrogenation of dinitrotolene
K115
Heavy ends from the purification of toluenediamine in the production of
toluenediamine via hydrogenation of dinitrotoluene
K116
Organic condensate from the solvent recovery column in the production of
toluene diisocyante via phosgenation of toluenediamine
Technology Code
Wastewaters
NA
NA
INCIN; or
CHOXD fb
CARBN; or
BIODG fb
CARBN
INCIN; or
CHOXD fb
CARBN; or
BIODG fb
CARBN
INCIN; or
CHXODfb
CARBN; or
BIODG fb
CARBN
INCIN; or
CHOXD fb
CARBN; or
BIODG fb
CARBN
INCIN; or
CHOXD fb
CARBN; or
BIODG fb
CARBN
CARBN; or
INCIN
CARBN; or
INCIN
CARBN; or
INCIN
CARBN; or
INCIN
Non-Wastewaters
RLEAD
RMERC
INCIN
INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G6
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
K123
Process wastewater (including supernates, filtrates, and washwaters) from the
production of ethylenebisdithiocarbamic acid and its salts
K124
Reactor vent scrubber water from the production of
ethylenebisdithiocarbamic acid and its salts
K125
Filtration, evaporation, and centrifugation solids from the production of
ethylenebisdithiocarbamic acid and its salts
K126
Baghouse dust and floor sweepings in milling and packaging operations from
the production or formulation of ethylene bisdithiocarbamic acid and its salts
P001 (CAS 81-81-2)
Warfarin (>0.3%)
P002 (CAS 591-08-2)
1 -Acetyl-2-thiourea
POOS (CAS 107-02-8)
Aceolein
POOS (CAS 107-18-6)
Allyl alcohol
P006 (CAS 20859-73-8)
Aluminum phosphide
P007 (CAS 2763-96-4)
5-Aminoethyl 3-isoxazolol
POOS (CAS 504-24-5)
4-Aminopyridine
P009 (CAS 131-74-8)
Ammonium picrate
Technology Code
Wastewaters
INCIN; or
CHOXD fb
(BIODG or
CARBN)
INCIN; or
CHOXD fb
(BIODG or
CARBN)
INCIN; or
CHOXD fb
(BIODG or
CARBN)
INCIN; or
CHOXD fb
(BIODG or
CARBN)
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
Non-Wastewaters
INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
FSUBS; or INCIN
FSUBS; or INCIN
CHOXD; CHRED; or
INCIN
INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G7
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
POM (CAS 108-98-5)
Thiophenol (Benzebe thiol)
P015 (CAS 7440-41-7)
Beryllium powder
P016 (CAS 542-88-1)
Bis(chloromethyl)ether
P017 (CAS 598-31-2)
Bromoacetone
P01 8 (CAS 357-57-3)
Brucine
P022**(CAS75-15-0)
Carbon disulfide
P023 (CAS 107-20-0)
Chloroacetaldehyde
P026 (CAS 5344-82-1)
l-(o-Chlorophenyl) thiourea
P027 (CAS 542-76-7)
3-Chloropropionitrile
P028 (CAS 100-44-7)
Benzyl chloride
P031 (CAS 460-19-5)
Cyanogen
P033 (CAS 506-77-4)
Cyanogen chloride
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
RMETL; or
RTHRM
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
WETOX or
INCIN
CHOXD;
WETOX or
INCIN
Non-Wastewaters
INCIN
RMETL; or RTHRM
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
CHOXD; WETOX or
INCIN
CHOXD; WETOX or
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G8
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
P034 (CAS 131-89-5)
2-Cyclohexyl-4,6-dinitrophenol
P040 (CAS 297-97-2)
O,O-Diethyl O-pyrzinyl phosphorothioate
P041 (CAS 3 11-45-5)
Diethyl-p-nitrophenyl phosphate
P042 (CAS 51-43-4)
Epinephrine
P043 (CAS 55-91-4)
Diisopropyl florophosphate(DFP)
P044 (CAS 60-5 1-5)
Dimethoate
P045 (CAS 39196-18-4)
Thiofanox
P046 (CAS 122-09-8)
alpha, alpha-Dimethylphenethylamine
P047 (CAS 534-52-1)
4,6-Dinitro-o-cresol salts
P049 (CAS 541-53-7)
2,4-Dithlobluret
P054(CAS 151-56-4)
Aziridine
P056** (CAS 7782-41-4)
Fluorine
P057 (CAS 640-19-7)
Fluoroacetamide
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CARBN; or
INCIN
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CARBN; or
INCIN
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
INCIN
FSUBS; or INCIN
FSUBS; or INCIN
INCIN
FSUBS; or INCIN
FSUBS; or INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
ADGAS fb NEUTR
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G9
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
P058 (CAS 62-74-8)
Fluoroacetic acid, sodium salt
P062 (CAS 757-58-4)
Hexaethy Itetrapho sphate
P064 (CAS 624-83-9)
Isocyanic acid, ethyl ester
P065*** (CAS 628-86-4)
Mercury fulminate: (High Mercury Subcategory— greater than or equal to 260
mg/kg total Mercury either incinerator residues or residues from RMERC)
P065*** (CAS 628-86-4)
Mercury fulminate: (All Nonwastewaters that are not incinerator residues
from RMERC; regardless of Mercury content)
P066 (CAS 16752-77-5)
Methomyl
P067 (CAS 75-55-8)
2-Methylaziridine
P068 (CAS 60-34-4)
Methyl hydrazine
P069 (CAS 75-86-5)
Methyllactonitrile
P070 (CAS 116-06-3)
Aldicarb
P072 (CAS 86-88-4)
1 -Naphthyl-2-thiourea
P075 (CAS 54-1 1-5)
Nicotine and salts
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
INCIN
FSUBS; or INCIN
INCIN
RMERC
IMERC
INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
INCIN
INCIN
INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G10
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
P076(CAS 10102-43-9)
Nitric oxide
P078(CAS 10102-44-0)
Nitrogen dioxide
P081 (CAS 55-63-0)
Nitroglycerin
P078(CAS 10102-44-0)
Nitrogen dioxide
P081 (CAS 55-63-0)
Nitroglycerin
P082** (CAS 62-75-9)
N-Nitrosodimethylamine
P084 (CAS 4549-40-0)
N-Nitrosomethylvinylamine
P085 (CAS 152-16-9)
Octamethylpyrophosphoramide
P087 (CAS 20816-12-0)
Osmium tetroxide
P088 (CAS 145-73-3)
Endothall
P092*** (CAS 62-38-4)
Phenyl mercury acetate: (High Mercury Subcategory - greater than or equal
to 260 mg/kg total Mercury - either incinerator residues or residues from
RMERC)
P092*** (CAS 62-38-4)
Phenyl mercury acetatate: (All nonwastewaters that are not incinerator
residues and are not residues from RMERC: regardless of Mercury Content)
P093 (CAS 103-85-5)
N-Phenylthiouea
Technology Code
Wastewaters
ADGAS
ADGAS
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
ADGAS
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CARBN; or
INCIN
RMETL; or
RTHRM
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
ADGAS
ADGAS
FSUBS; CHOXD;
CHRED; or INCIN
ADGAS
FSUBS; CHOXD;
CHRED; or INCIN
RMERC
INCIN
FSUBS; or INCIN
RMETL; or RTHEM
FSUBS; or INCIN
REMEC
IMERC; or RMERC
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G11
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
P095 (CAS 75-44-5)
Phosgene
P096 (CAS 7803-51-2)
Phosphine
P102 (CAS 107-19-7)
Propargyl alcohol
P105 (CAS 26628-22-8)
Sodium azide
PI 08 (CAS 57-24-9)
Strychnine and salts
P109 (CAS 3689-24-5)
Tetraethyidithiopyrophosphate
PI 12 (CAS 509-14-8)
Tetranitromethane
P113**(CAS 1314-32-5)
Thallic oxide
PI 15** (CAS 7446- 18-6)
Thallium (1) sulfate
PI 16 (CAS 79- 19-6)
Thiosemicarbazide
PI 18 (CAS 75-70-7)
Thrichloromethanethiol
PI 19** (CAS 7803-55-8)
P120** (CAS 1314-62-1)
Vanadium pentoxide
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
NA
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
NA
Non-Wastewaters
INCIN
CHOXD; CHRED; or
INCIN
FSUBS; or INCIN
FSUBS; CHOXD; or
INCIN
INCIN
FSUBS; or INCIN
FSUBS; CHOXD;
CHRED; or INCIN
RTHRM; or STABL
RTHRM; or STABL
INCIN
INCIN
STABL
STABL
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G12
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
P122 (CAS 1314-84-7)
Zinc Phosphide (>10%)
U001 (CAS 75-07-0)
Acetaldehyde
U003** (CAS 75-05-8)
Acetonitrile
U006 (CAS 75-36-5)
Acetyl Chloride
U007 (CAS 79-06-1)
Acrylamide
U008(CAS79-10-7)
Acrylic acid
U010 (CAS 50-07-7)
Mitomycin C
U011 (CAS 61-82-5)
Amitrole
U014 (CAS 492-80-8)
Auramine
U015 (CAS 115-02-6)
Azaserine
U016 (CAS 225-51-4)
Benz(c)acridine
U017 (CAS 98-87-3)
Benzal chloride
Technology Code
Wastewaters
CHOXD;
CHRED; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
CHOXD; CHRED; or
INCIN
INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G13
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U020 (CAS 98-09-9)
Benzensulfonyl chloride
U021 (CAS 92-87-5)
Benzidine
U023 (CAS 98-07-7)
Benzotrichloride
U026 (CAS 494-03-1)
Chlomaphazin
U033 (CAS 353-50-4)
Carbonyl fluoride
U034 (CAS 75-87-6)
Trichloroacetaldehyde (Chloral)
U035 (CAS 305-03-3)
Chlorambucil
U038** (CAS 510-15-6)
Chlorobenzilate
U041 (CAS 106-89-8)
1 -Chloro-2,3-epoxy propane (Epichlorohydrin)
U042**(CAS 110-75-8)
2-Chloroethyl vinyl ether
U046 (CAS 107-39-2)
Chloromethyl methyl ether
U049 (CAS 3 165-93-3)
4-Chloro-o-toluidine hydrochloride
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G14
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U053 (CAS 4170-30-3)
Crotonaldehyde
U055 (CAS 98-82-8)
Cumeme
U056 (CAS 110-82-7)
Cyclohexane
U057** (CAS 108-94-1)
Cyclohexanone
U058 (CAS 50-18-0)
Cyclophosphamide
U059 (CAS 20830-81-3)
Daunomycin
U062 (CAS 2303- 16-4)
Diallate
U064 (CAS 189-55-9)
1 ,2,7,8-Dibenzopyrene
U073 (CAS 91-94-1)
3,3'-Dichlorobenzidine
U074 (CAS 1476-11-5)
cis- 1 ,4-Dichloro-2-butylene trans- 1 ,4-Dichloro-2-butylene
U085 (CAS 1464-53-5)
1 ,2: 3 ,4-Diepoxybutane
U086 (CAS 1615-80-1)
N,N-Diethylhydrazine
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
Non-Wastewaters
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
INCIN
INCIN
FSUBS;
INCIN
INCIN
FSUBS; or INCIN
FSUBS; CHOXD;
CHRED; or INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G15
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U087 (CAS 3288-58-2)
O,O-Diethy S-methyldithiophosphate
U089 (CAS 56-53-1)
Diethy stilbestrol
U090 (CAS 94-58-6)
Dihydrosafrole
U091(CAS119-9-4)
3,3'-Dimethoxybenzidine
U092 (CAS 124-40-3)
Dimethylamine
U093** (CAS 621-90-9)
p-Dimethylaminoazobenzene
U094 (CAS 57-97-6)
7,12-Dimethy benz(a)anthracene
U095 (CAS 119-93-7)
3,3'-Dimethylbenzidine
U096(CAS80-15-9)
a,a-Dimethyl benzyl hydroperoxide
U097 (CAS 79-44-7)
Dimethylcarbomyl chloride
U098 (CAS 57-14-7)
1 , 1 -Dimethylthydrazine
Technology Code
Wastewaters
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
Non-Wastewaters
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G16
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U099 (CAS 540-73-8)
1 ,2-Dimethylhydrazine
U103 (CAS 77-78-1)
Dimethyl sulfate
U109 (CAS 122-66-7)
1 ,2-Diphenylhydrazine
Ul 10 (CAS 142-84-7)
Dipropylamine
Ul 13 (CAS 140-88-5)
Ethyl acrylate
Ul 14 (CAS 11 1-54-6)
Ethylene bis-dithiocarbamic acid
U115 (CAS 75-21-8)
Ethylene oxide
Ul 16 (CAS 96-45-7)
Ethylene thiourea
Ul 19 (CAS 62-50-0)
Ethyl methane sulfonate
U122 (CAS 50-00-0)
Formaldehyde
U123(CAS64-18-6)
Formic acid
Technology Code
Wastewaters
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
FSUBS; CHOXD;
CHRED; or INCIN
FSUBS; CHOXD;
CHRED; or INCIN
FSUBS; CHOXD;
CHRED; or INCIN
INCIN
FUSES; or INCIN
INCIN
CHOXD; or INCIN
INCIN
INCIN
FSUBS; or INCIN
FSUBS; or INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G17
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U124 (CAS 110-00-9)
Furan
U125 (CAS 98-01-1)
Furfural
U126 (CAS 765-34-4)
Glycidaldehyde
U132 (CAS 70-30-4)
Hexachlorophenene
U133 (CAS 302-01-2)
Hydrazine
U134** (CAS 7664-39-3)
Hydrogen Flouride
U135 (CAS 7783-06-4)
Hydrogen Sulfide
U143 (CAS 303-34-4)
Lasiocarpine
U147 (CAS 108-3 1-6)
Malaic anhydride
U148 (CAS 123-33-1)
Maleic hydrazide
U149(CAS 109-77-3)
Malononitrile
U150 (CAS 148-82-3)
Melphalan
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
NA
CHOXD;
CHRED; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
FSUBS; or INCIN
FSUBS; or INCIN
FSUBS; or INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
ADGAS fb NEUTR; or
NEUTR
CHOXD; CHRED; or
INCIN
INCIN
CARBN; or INCIN
FSUBS; or INCIN
INCIN
INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G18
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U151*** (CAS 7439-97-6)
Mercury: (High Mercury Subcategory - greater than or equal to 260 mg/kg
total Mercury
U153 (CAS 74-93-1)
Methane thiol
Ul 54 (CAS 67-56-1)
Methanol
Ul 56 (CAS 79-22-1)
Methyl chlorocarbonate
U160 (CAS 1338-23-4)
Methyl ethyl ketone perioxide
U163 (CAS 70-25-7)
N-Methyl N'-nitro N-Nitrosoguanidine
U164 (CAS 56-04-2)
Methylthiouracil
U166 (CAS 130-15-4)
1 ,4-Naphthoquinone
U167 (CAS 134-32-7)
1 -Naphthylamine
U168** (CAS 91-59-8)
2-Naphthlyamine
U171 (CAS 79-46-9)
2-Nitropropane
U173(CAS1116-54-7)
N-Nitroso-di-n-ethanolamine
Technology Code
Wastewaters
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
CHOXD;
CHRED;
CARBN;
BIODG; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
RMERC
INCIN
FSUBS; or INCIN
INCIN
FSUBS; CHOXD;
CHRED; or INCIN
FSUBS; CHOXD;
CHRED; or INCIN
INCIN
FSUBS; or INCIN
INCIN
INCIN
INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G19
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U176 (CAS 759-73-9)
N-Nitroso-N-ethylurea
U177 (CAS 684-93-5)
N-Nitroso-N-methylurea
U178 (CAS 615-53-2)
N-Nitroso-N-methylurehane
U182 (CAS 123-63-7)
Peraldehyde
U184 (CAS 76-01-7)
Pentachloroethane
Ul 86 (CAS 504-60-9)
1,3-Pentadiene
U189 (CAS 1314-80-3)
Phosphorus sulfide
U191 (CAS 109-06-8)
2-Picoline
U193 (CAS 1120-71-4)
1,3-Propane sultone
U194 (CAS 107-10-8)
n-Propylamine
U197 (CAS 106-51-4)
p-Benzoquinone
U200 (CAS 50-55-5)
Reserpine
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CHOXD;
CHRED; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
Non-Wastewaters
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
FSUBS; or INCIN
CHOXD; CHRED; or
INCIN
INCIN
INCIN
INCIN
FSUBS; or INCIN
INCIN
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G20
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Waste Code
U201 (CAS 108-46-3)
Resorcinol
U202 **** (CAS 81-07-2)
Saccharin and salts
U206(CAS 18883-66-4)
Steptozatocin
U213 (CAS 109-99-9)
Tetrahydrofuran
U214** (CAS 563-68-8)
Thallium (1) acetate
U215** (CAS 6533-73-9)
Thallium (1) carbonate
U216** (CAS 7791-12-0)
Thallium (1) chloride
Technology Code
Wastewaters
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
(WETOX or
CHOXD) fb
CARBN; or
INCIN
NA
NA
NA
Non-Wastewaters
FSUBS; or INCIN
INCIN
INCIN
FSUBS; or INCIN
RTHRM; or STABL
RTHRM; or STABL
RTHRM; or STABL
* See also Table CCWE in 268.41 (see accession number 8807).
** See also Table CCW in 268.43 (see accession number 8808).
*** See also Tables CCWE in 268.41 (see accession number 8807) and CCW in 268.43 (see accession number 8808).
**** CAS Number given for parent compound only.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G21
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix G: Treatment Methods Expressed as Specific Technologies (40 CFR 268.42)
Table 3 - Technology-Based Standards for Specific Radioactive Hazardous Mixed Waste
Waste Code with Waste Description and/or Treatment Category
D002, D004, D005, D006, and D007
Radioactive high level wastes generated during the reprocessing of fuel rods
subcategory
D008 (CAS 7439- 92-1)
Radioactive lead solids subcategory*
D008
Radioactive high level wastes generated during the reprocessing of fuel rods
subcategory
D009 (CAS 7439-97-6)
Elemental mercury contaminated with radioactive materials
D009 (CAS 7439-97-6)
Hydraulic oil contaminated with mercury; radioactive materials subcategory
D009,D010,D011
Radioactive high level wastes generated during the reprocessing of fuel rods
subcategory
Ul 51 (CAS 7439- 97-6)
Mercury: Elemental mercury contaminated with radioactive materials
Wastewaters
NA
NA
NA
NA
NA
NA
NA
Non Wastewaters
HLVIT
MACRO
HLVIT
AMLGM
IMERC
HLVIT
AMLGM
* These lead solids include, but are not limited to, all forms of lead shielding, and other elemental forms of lead. These lead solids do not
include treatment residuals such as hydroxide sludges, other wastewater treatment residuals, or incinerator ashes that can undergo
conventional pozzolanic stabilization, nor do they include organolead materials that can be incinerated and stabilized as ash.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G22
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Protocol for Conducting Environmental Compliance Audits of
Treatment, Storage and Disposal Facilities under the Resource
Conservation and Recovery Act
Appendix H:
Constituent Concentrations in Wastes (40 CFR 268.43(a))
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
D003 (CAS 57-12-5) (reactive cyanides category-based on 261.23(a)(5))
Cyanides (Total)
Cyanides (Amenable)
D004* (CAS 7440-38-2)
Arsenic
D005* (CAS 7440-39-2) Barium
D006* (CAS 7440-43-9) Cadmium
D007* (CAS 7440-47-32) Chromium (Total)
D008* (CAS 7439-92-1)
Lead
D009* (CAS 7439-97-6) Mercury
D010* (CAS 7782-49-2) Selenium
D011* (CAS 7440-22-4)
Silver
D012** (CAS 720-20-8)
Endrin
D013** (CAS 58-89-9)
Lindane
D014** (CAS 72-43-5) Methoxychlor
D015** (CAS 8001-35-1) Toxaphene
D016** (CAS 94-75-7)
2,4-D
D017** (CAS 93-76-5)
2,4,5-TP Silvex
F001-F005 spent solvents*** 1,1,2-Trichloroethane (CAS 71-55-6)
Benzene (CAS 7 1-43-2)
F001-F005 spent solvents
(Pharmaceutical industry wastewater subcategory)
Methylene chloride (CAS 75-09-2)
F006*
Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
Concentrations
Wastewaters
(mg/L) Notes
Reserved
0.86
5.0
100
1.0
5.0
5.0
0.20
1.0
5.0
NA
NA
NA
NA
NA
NA
0.030
0.070
0.44
1.2
0.86
Non- Wastewaters
(mg/kg) Notes
590 (3)
30
NA
NA
NA
NA
NA
NA
NA
NA
0.13(1)
0.066(1)
0.18(1)
1.3(1)
10.0(1)
7.9(1)
7.6(1)
3.7(1)
NA
590
30
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H1
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Cadmium (CAS 7440-43-9)
Chromium (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
F007*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
F008*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7439-92-1)
F009*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
F010
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
F011*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
Concentrations
Wastewaters
(mg/L) Notes
1.6
0.32
0.040
0.44
1.9
0.1
0.32
0.04
0.44
1.9
0.1
0.32
0.04
0.44
1.9
0.1
0.32
0.04
0.44
1.9
0.1
1.9
0.1
0.32
0.04
0.44
Non- Wastewaters
(mg/kg) Notes
NA
NA
NA
NA
590
30
NA
NA
NA
590
30
NA
NA
NA
590
30
NA
NA
NA
1.5
NA
110
9.1
NA
NA
NA
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H2
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
F012*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
F019*
Cyanides (total) (CAS 57-12-5)
Cyanides (amenable) (CAS 57-12-5)
Chromium (total) (CAS 7440-47-32)
F024**
Note: F024 organic standards must be treated via incineration (INCIN)
2-Chloro-l,3-butadiene (CAS 126-99-6)
3-Chloropropene (CAS 107-05- )
1,1-Dichloroethane (CAS 75-34-3)
1,2-Dichloroethane (CAS 107-06-2)
1,2-Dichloropropane (CAS 78-87-5)
cis-l,3-Dichloropropene (CAS 10061-01-5)
trans- 1,3-Dichloropropene (CAS 10061-02-6)
Bis(2-ethylhexyl)phthalate (CAS 117-81-7)
Hexachloroethane (CAS 67-72-1)
Chromium (total) (CAS 7440-47-32)
Nickel (CAS 7440-02-0)
F025 (light ends subcategory) Chloroform (CAS 67-66-3)
1,2-Dichloroethane (CAS 107-06-2)
1,1-Dichloroethylene (CAS 75-35-4)
Methylene chloride (CAS 75-9-2)
Carbon tetrachloride (CAS 56-23-5)
1,1,2-Trichloroethane (CAS 79-00-5)
Trichloroethylene (CAS 79-01-6)
Vinyl chloride (CAS 75-01-4)
Concentrations
Wastewaters
(mg/L) Notes
1.9
0.1
0.32
0.04
0.44
1.2
0.86
0.32
0.28(1)
0.28(1)
0.014(1)
0.014(1)
0.014(1)
0.014(1)
0.014(1)
0.036(1)
0.036(1)
0.35
0.47
0.046 (2)
0.21 (2)
0.025 (2)
0.089 (2)
0.057 (2)
0.054 (2)
0.054 (2)
0.27 (2)
Non- Wastewaters
(mg/kg) Notes
110
9.1
NA
NA
NA
590 (3)
30(3)
NA
0.28(1)
0.28(1)
0.014(1)
0.014(1)
0.014(1)
0.014(1)
0.014(1)
1.8(1)
1.8(1)
NA
NA
6.2(1)
6.2(1)
6.2(1)
31(1)
6.2(1)
6.2(1)
5.6(1)
33(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H3
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
F025 (spent filters/aids and desiccants subcategory) Chloroform (CAS 67-66-
3)
Methylene chloride (CAS 75-9-2)
Carbon tetrachloride (CAS 56-23-5)
1,1,2-Trichloroethane (CAS 79-00-5)
Trichloroethylene (CAS 79-01-6)
Vinyl chloride (CAS 75-01-4)
Hexachlorobenzene (CAS 118-74-1)
Hexachlorobutadiene (CAS 87-68-3)
Hexachloroethane (CAS 67-72-1)
F039**(and D001 and D002 wastes prohibited by 268.37) Acetone (CAS 67-
64-1)
Acenaphthylene (CAS 208-96-8)
Acenaphthene (CAS 83-32-9)
Acetonitrile (CAS 75-05-8)
Acetophenone (CAS 96-86-2)
2-Acetylaminofluorene (CAS 53-96-3)
Acrolein
Acrylonitrile (CAS 107-02-8)
Aldrin(CAS 107-13-1)
(CAS 309-00-2)
4-Aminobiphenyl (CAS 92-67-1)
Aniline (CAS 62-53-3)
Anthracene (CAS 120-12-7)
Aramite (CAS 140-57-8)
Aroclor 1016 (CAS 12674-11-2)
Aroclor 1221 (CAS 11104-28-2)
Aroclor 1232 (CAS 11141-16-5)
Aroclor 1242 (CAS 53469-21-9)
Aroclor 1248 (CAS 12672-29-6)
Aroclor 1254 (CAS 11097-69-1)
Concentrations
Wastewaters
(mg/L) Notes
0.046 (2)
0.089 (2)
0.057 (2)
0.054 (2)
0.054 (2)
0.27 (2)
0.055 (2)
0.055 (2)
0.055 (2)
0.28 (2)
0.059 (2)
0.059 (2)
0.17(2)
0.010(2)
0.059 (2)
0.29 (2)
0.24 (2)
0.021 (2)
0.13(2)
0.81 (2)
0.059 (2)
0.36 (2)
0.013(2)
0.014(2)
0.013(2)
0.0172)
0.013(2)
0.014(2)
Non- Wastewaters
(mg/kg) Notes
6.2(1)
31(1)
6.2(1)
6.2(1)
5.6(1)
33(1)
37(1)
28(1)
30(1)
160(1)
3.4(1)
4.0(1)
NA
9.7(1)
140(1)
NA
84(1)
0.066(1)
NA
14(1)
4.0(1)
NA
0.92(1)
0.92(1)
0.92(1)
0.92(1)
0.92(1)
1.8(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H4
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Aroclor 1260 (CAS 11096-82-5)
alpha-BHC (CAS 319-84-6)
beta-BHC (CAS 319-85-7)
delta-BHC (CAS 319-86-8)
gamma-BHC (CAS 58-89-9)
Benzene (CAS 7 1-34-2)
Benzo(a)anthracene (CAS 56-55-3)
Benzo(b)fluoranthene (CAS 205-99-2)
Benzo(k)fluoranthene (CAS 207-08-9)
Benzo(g,h,i)perylene (CAS 191-24-2)
Benzo(a)pyrene (CAS 5-32-8)
Bromodichloromethane (CAS 75-27-4)
Bromoform (CAS 72-25-2) (Tribromomethane)
Bromomethane (CAS 74-83-9) (methyl bromide)
4-Bromophenyl phenyl ether (CAS 101-55-3)
n-Butyl alcohol (CAS 71-36-3)
Butyl benzyl phthalate (CAS 85-68-7)
2-sec-Butyl-4,6-dinitrophenol (CAS 88-85-7)
Carbon tetrachloride (CAS 56-23-5)
Carbon disulfide (CAS 75-15-0)
Chlordane (CAS 57-74-9)
p-Chloroaniline (CAS 106-47-8)
Chlorobenzene (CAS 108-90-7)
Chlorobenzilate (CAS 510-15-6)
2-Chloro-l,3-butadiene (CAS 126-99-8)
Chlorodibromomethane (CAS 124-48-1)
Chloroethane (CAS 75-00-3)
bis(2-Chloroethoxy) methane (CAS 111-91-1)
bis(2-Chloroethyl) ether (CAS 1 1 1-44-4)
Chloroform (CAS 67-66-3)
Concentrations
Wastewaters
(mg/L) Notes
0.014(2)
0.00014 (2)
0.00014 (2)
0.023 (2)
0.0017 (2)
0.14(2)
0.059 (2)
0.055 (2)
0.059 (2)
0.0055 (2)
0.061 (2)
0.35 (2)
0.63 (2)
0.11(2)
0.055 (2)
5.6 (2)
0.017(2)
0.066 (2)
0.057 (2)
0.014(2)
0.0033 (2)
0.46 (2)
0.057 (2)
0.10(2)
0.057 (2)
0.057 (2)
0.27 (2)
0.036 (2)
0.033 (2)
0.046 (2)
Non- Wastewaters
(mg/kg) Notes
1.8(1)
0.066(1)
0.066(1)
0.066(1)
0.066(1)
36(1)
8.2
3.4(1)
3.4(1)
1.5(1)
8.2(1)
15(1)
15(1)
15(1)
15(1)
2.6(1)
7.9(1)
2.5(1)
5.6(1)
NA
0.13(1)
16(1)
5.7(1)
NA
NA
15(1)
6.0(1)
7.2(1)
7.2(1)
5.6(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H5
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
bis(2-Chloroisopropyl) ether(CAS 39638-32-9)
p-Chloro-m-cresol (CAS 59-50-7)
Chloromethane (Methyl chloride)(CAS 74-87-3)
2-Chloronaphthalene (CAS 91-58-7)
2-Chlorophenol (CAS 95-57-8)
3-Chloropropylene (CAS 107-05-1)
Chrysene (CAS 218-01-9)
o-Cresol (CAS 95-48-7)
Cresol (m- and p-isomers)
Cyclohexanone (CAS 108-94-1)
l,2-Dibromo-3-chloropane (CAS 96-12-8)
l,2-Dibromoethane(CAS 106-93-4) (Ethylene dibromide)
Dibromomethane (CAS 74-95-3)
2,4-Dichlorophenoxyacetic acid (2,4-D) (CAS 94-75-7)
o,p'-DDD(CAS53-19-0)
p,p'-DDD (CAS 72-54-8)
o,p'-DDE (CAS 3424-82-6)
p,p'-DDE (CAS 72-55-9)
o,p'-DDT (CAS 780-02-6)
p,p'-DDT (CAS 50-29-3)
Dibenzo(a,h)anthracene (CAS 53-70-3)
Dibenzo(a,e)pyrene (CAS 192-65-4)
m-Dichlorobenzene (CAS 541-73-1)
o-Dichlorobenzene (CAS 95-50-1)
p-Dichlorobenzene (CAS 106-46-7)
Dichlorodifluoromethane (CAS 75-71-8)
1,1-Dichloroethane (CAS 75-34-3)
1,2-Dichloroethane (CAS 107-06-2)
1,1-Dichloroethylene (CAS 75-35-4) trans- 1,2-Dichloroethene
2,4-Dichlorophenol (CAS 120-83-2)
Concentrations
Wastewaters
(mg/L) Notes
0.055 (2)
0.018(2)
0.19(2)
0.055 (2)
0.044 (2)
0.036 (2)
0.059 (2)
0.11(2)
0.77 (2)
0.36 (2)
0.11(2)
0.028 (2)
0.11(2)
0.72 (2)
0.023 (2)
0.023 (2)
0.031 (2)
0.031 (2)
0.0039 (2)
0.0039 (2)
0.055 (2)
0.061 (2)
0.036 (2)
0.088 (2)
0.090 (2)
0.23 (2)
0.059 (2)
0.21 (2)
0.025 (2)
0.044 (2)
Non- Wastewaters
(mg/kg) Notes
7.2(1)
14(1)
33(1)
5.6(1)
5.7(1)
28(1)
8.2(1)
5.6(1)
3.2(1)
NA
15(1)
15(1)
15(1)
10(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
8.2(1)
NA
6.2(1)
6.2(1)
6.2(1)
7.2(1)
7.2(1)
7.2(1)
33(1)
14(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H6
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
2,6-Dichlorophenol (CAS 87-65-0)
1 ,2-Dichloropropane
cis-l,3-Dichloropropene (CAS 10061-01-5)
trans- 1,3-Dichloropropene (CAS 10061-02-6)
Dieldrin (CAS 60-57-1)
Diethyl phthalate (CAS 84-66-2)
2,4-Dimethyl phenol (CAS 105-67-9)
Dimethyl phthalate (CAS 131-11-3)
Di-n-butyl phthalate (CAS 84-74-2)
1,4-Dinitrobenzene (CAS 100-25-4)
4,6-Dinitro-o-cresol (CAS 534-52-1)
2,4-Dinitrophenol (CAS 51-28-5)
2,4-Dinitrotoluene (CAS 121-14-2)
2,6-Dinitrotoluene (CAS 606-20-2)
Di-n-octyl phthalate (CAS 117-84-0)
Di-n-propylnitrosamine (CAS 621-64-7)
Diphenylamine (CAS 122-39-4)
1,2-Diphenyl hydrazine (CAS 122-66-7)
Diphenylnitrosamine (CAS 621-64-7)
1,4-Dioxane (CAS 123-91-1)
Disulfoton (CAS 298-04-4)
Endosulfan I (CAS 939-98-8)
Endosulfan II (CAS 33213-6-5)
Endosulfan sulfate (CAS 1031-07-8)
Endrin (CAS 72-20-8)
Endrin aldehyde (CAS 7421-93-4)
Ethyl acetate (CAS 141-78-6)
Ethyl cyanide (CAS 107-12-0)
Ethyl benzene (CAS 100-41-4)
Ethyl ether (CAS 60-29-7)
Concentrations
Wastewaters
(mg/L) Notes
0.044 (2)
0.85 (2)
0.036 (2)
0.036 (2)
0.017(2)
0.20 (2)
0.036 (2)
0.047 (2)
0.057 (2)
0.32 (2)
0.28 (2)
0.12(2)
0.32 (2)
0.55 (2)
0.017(2)
0.40 (2)
0.52 (2)
0.087 (2)
0.40 (2)
0.12(2)
0.017(2)
0.023 (2)
0.029 (2)
0.029 (2)
0.0028 (2)
0.025 (2)
0.34 (2)
0.24 (2)
0.057 (2)
0.12(2)
Non- Wastewaters
(mg/kg) Notes
14(1)
18(1)
18(1)
18(1)
0.13(1)
28(1)
14(1)
28(1)
28(1)
2.3(1)
160(1)
160(1)
140(1)
28(1)
28(1)
14(1)
NA
NA
NA
170(1)
6.2(1)
0.066(1)
0.13(1)
0.13(1)
0.13(1)
0.13(1)
33(1)
360(1)
6.0(1)
160(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H7
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
bis(2-Ethylhexyl) phthalate (CAS 117-81-7)
Ethyl methacrylate (CAS 97-63-2)
Ethylene oxide (CAS 75-21-8)
Famphur (CAS 52-85-7)
Fluoranthene (CAS 206-44-0)
Fluorene (CAS 86-73-7)
Fluorotrichloromethane (CAS 75-69-4)
Heptachlor (CAS 76-44-8)
Heptachlor epoxide (CAS 1024-57-3)
Hexachlorobenzene (CAS 118-74-1)
Hexachlorobutadiene (CAS 87-68-3)
Hexachlorocyclopentadiene (CAS 77-47-4)
Hexachlorodibenzo-furans
Hexchlorodibenzo-p-dioxins
Hexchloroethane (CAS 67-72-1)
Hexachloropropene (CAS 1888-71-7)
Indeno(l,2,3,-c,d)pyrene (CAS 193-39-5)
lodomethane (CAS 74-88-4)
Isobutanol (CAS 78-83-1)
Isodrin (CAS 465-73-6)
Isosafrole (CAS 120-58-1)
Kepone (CAS 143-50-8)
Methacrylonitrile (CAS 126-98-7)
Methanol (CAS 67-56-1)
Methapyrilene (CAS 91-80-5)
Methoxychlor (CAS 72-43-5)
3-Methylcholanthrene (CAS 56-49-5)
4,4-Methylene-bis-(2-chloroaniline) (CAS 101-14-4)
Methylene chloride (CAS 75-09-2)
Methyl ethyl ketone (CAS 78-93-3)
Concentrations
Wastewaters
(mg/L) Notes
0.28 (2)
0.14(2)
0.12(2)
0.017(2)
0.068 (2)
0.059 (2)
0.020 (2)
0.0012 (2)
0.016(2)
0.055 (2)
0.055 (2)
0.057 (2)
0.000063 (2)
0.000063 (2)
0.055 (2)
0.035 (2)
0.0055 (2)
0.019(2)
5.6 (2)
0.021 (2)
0.081 (2)
0.0011(2)
0.24 (2)
5.6 (2)
0.081 (2)
0.25 (2)
0.0055 (2)
0.50(2)
0.089 (2)
0.28 (2)
Non- Wastewaters
(mg/kg) Notes
28(1)
160(1)
NA
15(1)
8.2(1)
4.0(1)
33(1)
0.066(1)
0.066(1)
37(1)
28(1)
3.6(1)
0.001(1)
0.001(1)
28(1)
28(1)
8.2(1)
65(1)
170(1)
0.066(1)
2.6(1)
0.13(1)
84(1)
NA
1.5(1)
0.18(1)
15(1)
35(1)
33(1)
36(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H8
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Methyl isobutyl ketone (CAS 108-10-1)
Methyl methacrylate (CAS 80-62-6)
Methyl methansulfonate (CAS 66-27-3)
Methyl parathion (CAS 298-00-0)
Naphthalene (CAS 91-20-3)
2-Naphthylamine (CAS 91-59-8)
p-Nitroaniline (CAS 100-01-6)
Nitrobenzene (CAS 96-95-3)
5-Nitro-o-toluidine (CAS 99-55-8)
4-Nitrophenol (CAS 100-02-7)
N-Nitrosodiethylamine (CAS 55-18-5)
N-Nitrosodimethylamine (CAS 62-75-9)
N-Nitroso-di-n-butylamine (CAS 924-16-3)
N-Nitrosomethylethylamine (CAS 10595-95-6)
N-Nitrosomorpholine (CAS 59-89-2)
N-Nitrosopiperidine (CAS 100-75-4)
N-Nitrosopyrrolidine (CAS 930-55-2)
Parathion (CAS 56-38-2)
Pentachlorobenzene (CAS 608-93-5)
Pentachlorodibenzo-furans
Pentachlorodibenzo-p-dioxins
Pentachloronitrobenzene (CAS 82-68-8)
Pentachlorophenol (CAS 87-86-5)
Phenacetin (CAS 62-44-2)
Phenanthrene (CAS 85-01-8)
Phenol (CAS 108-95-2)
Phorate (CAS 298-02-2)
Phthalic anhydride (CAS 85-44-9)
Pronamide (CAS 23950-58-5)
Pyrene (CAS 129-00-0)
Concentrations
Wastewaters
(mg/L) Notes
0.14(2)
0.14(2)
0.018(2)
0.014(2)
0.059 (2)
0.52 (2)
0.028 (2)
0.068 (2)
0.32 (2)
0.12(2)
0.40 (2)
0.40 (2)
0.40 (2)
0.40 (2)
0.40 (2)
0.013(2)
0.013(2)
0.014(2)
0.055 (2)
0.000063 (2)
0.000063 (2)
0.055 (2)
0.089 (2)
0.081 (2)
0.059 (2)
0.039 (2)
0.021 (2)
0.069 (2)
0.093 (2)
0.067 (2)
Non- Wastewaters
(mg/kg) Notes
33(1)
160(1)
NA
4.6(1)
3.1(1)
NA
28(1)
14(1)
28(1)
29(1)
28(1)
NA
17(1)
2.3(1)
2.3(1)
35(1)
35(1)
4.6(1)
37(1)
0.001(1)
0.001(1)
4.8(1)
7.4(1)
16(1)
3.1(1)
6.2(1)
4.6(1)
NA
1.5(1)
8.2(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H9
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Pyridine (CAS 110-86-1)
Safrole (CAS 94-59-7)
Silvex (2,4,5-TP) (CAS 93-72-1)
2,4,5-1 (CAS 93-76-5)
1,2,4,5,- Tetrachlorobenzene (CAS 95-94-3)
Tetrachlorodibenzo-furans
Tetrachlorodibenzo-p-dioxins
1,1,1,2-Tetrachloroethane (CAS 630-20-6)
1,1,2,2-Tetrachloroethane (CAS 70-34-6)
Tetrachloroethene (CAS 127-18-4)
2,3,4,6-Tetrachlorophenol (CAS 58-90-2)
Toluene (CAS 108-88-3)
Toxaphene (CAS 8001-35-1)
1,2,4-Trichlorobenzene (CAS 120-82-1)
1,1,1-Trichloroethane (CAS 71-55-6)
1,1,2-Trichloroethane (CAS 79-00-5)
Trichloroethylene (CAS 79-01-6)
2,4,5-Trichlorophenol (CAS 95-95-4)
2,4,6-Trichlorophenol (CAS 88-06-2)
1,2,3-Trichloropropane (CAS 96-18-4)
l,l,2-Trichloro-l,2,2-trifluoro-ethane (CAS 76-13-1)
Tris(2,3-dibromopropyl (CAS 126-72-7)
Vinyl chloride (CAS 75-01-4)
Xylene(s)
Cyanides (total) (CAS 57-12-5)
Fluoride (CAS 16964-48-8)
Sulfide (CAS 8496-25-8)
Antimony (CAS 7440-36-0)
Arsenic (CAS 7440-38-2)
Barium (CAS 7440-39-3)
Concentrations
Wastewaters
(mg/L) Notes
0.014(2)
0.081 (2)
0.72 (2)
0.72 (2)
0.055 (2)
0.000063 (2)
0.000063 (2)
0.057 (2)
0.057 (2)
0.056 (2)
0.030 (2)
0.080 (2)
0.0095 (2)
0.055 (2)
0.054 (2)
0.054 (2)
0.054 (2)
0.18(2)
0.035(2)37(1)
0.85 (2)
0.057 (2)
0.11(2)
0.27 (2)
0.32 (2)
1.2(2)
35(2)
14(2)
1.9(2)
1.4(2)
1.2(2)
Non- Wastewaters
(mg/kg) Notes
16(1)
22(1)
7.9(1)
7.9(1)
19(1)
0.001(1)
0.001(1)
42(1)
42(1)
5.6(1)
37(1)
28(1)
1.3(1)
19(1)
5.6(1)
5.6(1)
5.6(1)
37(1)
28(1)
28(1)
NA
33(1)
28(1)
1.8(1)
NA
NA
NA
NA
NA
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H10
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Beryllium (CAS 7440-41-7)
Cadmium (CAS 7440-43-9)
Chromium (total) (CAS 7440-47-32)
Copper (CAS 7440-50-8)
Lead (CAS 7439-92-1)
Mercury (CAS 7439-97-6)
Nickel (CAS 7440-02-0)
Selenium (CAS 7782-49-2)
Silver (CAS 7440-22-4)
Thallium (CAS 7440-28-0)
Vanadium (CAS 7440-62-2)
Zinc (CAS 7440-66-6)
K001* Naphthalene (CAS 91-20-3)
Pentachlorophenol (CAS 87-86-5)
Penanthrene (CAS 85-01-8)
Pyrene (CAS 129-99-0)
Toluene (CAS 108-88-3)
Xylenes (total)
Lead (CAS 7439-92-1)
K002*, K003*, and K004* Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K005*
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Cyanides(total) (CAS 57-12-5)
K006*
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K007*
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Concentrations
Wastewaters
(mg/L) Notes
0.82 (2)
0.20 (2)
0.37
1.3(2)
0.28 (2)
0.15(2)
0.55 (2)
0.82 (2)
0.29 (2)
1.4(2)
0.042 (2)
1.0(2)
0.031(1)
0.18(1)
0.031(1)
0.028(1)
0.028(1)
0.032(1)
0.037
0.9 (2)
3.4 (2)
0.9 (2)
3.4 (2)
0.74 (2)
0.9 (2)
3.4 (2)
0.9 (2)
3.4 (2)
Non- Wastewaters
(mg/kg) Notes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.5(1)
7.4(1)
1.5(1)
1.5(1)
28(1)
33(1)
NA
NA
NA
NA
NA
Reserved
NA
NA
NA
NA
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H11
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Cyanides (total) (CAS 57-12-5)
K008*
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K009
Chloroform (CAS 67-66-3)
K010
Chloroform (CAS 67-66-3)
K011, K013, and K014 Acetonitrile (CAS 75-05-8)
Acrylonitrile (CAS 107-13-1)
Acrylamide (CAS 79-06-1)
Benzene (CAS 7 1-34-2)
Cyanide(total) (CAS 57-12-5)
K015*
Anthracene (CAS 120-12-7)
Benzal chloride (CAS 98-87-3)
Sum of Benso(b) fluoranthene (CAS 205-99-2) and Benzo(k)fluoranthene
(CAS 207-08-9)
Phenanthrene (CAS 85-01-8)
Toluene (CAS 108-88-3)
Chromium (total) (CAS 7440-47-32)
Nickel (CAS 7440-02-0)
KOI 6 Hexachlorobenzene (CAS 118-74-1)
Hexachlorobutadiene (CAS 87-68-3)
Hexachlorocyclopentadiene (CAS 77-47-4). 0.007 (1)
Hexachloroethane (CAS 67-72-1)
Tetrachloroethene (CAS 127-18-4)
K017
1,2-Dichloropropane (CAS 78-87-5)
1,2,3-Trichloropropane (CAS 96-16-4)
Bis(2-chloroethyl)ether (CAS 1 1 1-44-4)
Concentrations
Wastewaters
(mg/L) Notes
0.74 (2)
0.9 (2)
3.4 (2)
0.1
0.1
38
0.06
19
0.02
21
1.0
0.28
0.029
0.27
0.15
0.32
0.44
0.033(1)
0.007(1)
5.6(1)
0.033(1)
0.007(1)
0.85(1,2)
0.85(1,2)
0.033 (1,2)
Non- Wastewaters
(mg/kg) Notes
NA
NA
6.0(1)
6.0(1)
1.8(1)
1.4(1)
23(1)
0.03(1)
57
3.4(1)
6.2(1)
3.4(1)
3.4(1)
6.0(1)
NA
NA
28(1)
5.6(1)
28(1)
6.0(1)
18(1)
28(1)
7.2(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H12
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
K018
Chloroethane (CAS 75-00-3)
Chloromethane (CAS 74-87-3)
1,1-Dichloroethane (CAS 75-34-3)
1,2-Dichloroethane (CAS 107-06-2)
Hexachlorobenzene (CAS 118-74-1)
Hexachlorobutadiene (CAS 87-68-3)
Hexachloroethane (CAS 67-72-1)
Pentachloroethane (CAS 76-01-7)
1,1,1-Trichloroethane (CAS 71-55-6)
K019
Bis(2-chloroethyl)ether (CAS 111-44-4).
Chlorobenzene (CAS 108-90-7)
Chloroform (CAS 67-66-3)
p-Dichlorobenzene (CAS 106-46-7)
1,2-Dichloroethane (CAS 107-06-2)
Fluorene (CAS 86-73-7)
Hexachloroethane (CAS 67-72-1)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
1,2,4,5-Tetrachlorobenzene (CAS 95-94-3)
Tetrachloroethene (CAS 127-18-4)
1,2,4-Trichlorobenzene (CAS 120-82-1)
1,1,1-Trichloroethane (CAS 71-55-6)
K020
1,2-Dichloroethane (CAS 107-06-2)
1,1,2,2-Tetrachloroethane (CAS 79-34-6)
Tetrachloroethene (CAS 127-18-4)
K021*
Chloroform (CAS 67-66-3)
Carbon tetrachloride (CAS 56-23-5)
Antimony (CAS 7440-36-0)
Concentrations
Wastewaters
(mg/L) Notes
0.007(1)
0.007(1)
0.007(1)
0.007(1)
0.033(1)
0.007(1)
NA
0.007(1)
0.007(1)
0.007(1)
0.006(1)
0.007(1)
0.008(1)
0.007(1)
0.007(1)
0.033(1)
0.007(1)
0.007(1)
0.017(1)
0.007(1)
0.023(1)
0.007(1)
0.007(1)
0.007(1)
0.007(1)
0.046 (2)
0.057 (2)
0.60 (2)
Non- Wastewaters
(mg/kg) Notes
6.0(1)
NA
6.0(1)
6.0(1)
28(1)
5.6(1)
28(1)
5.6(1)
6.0(1)
5.6(1)
6.0(1)
6.0(1)
NA
6.0(1)
NA
28(1)
5.6(1)
5.6(1)
NA
6.0(1)
19(1)
6.0(1)
6.0(1)
5.6(1)
6.0(1)
6.2(1)
6.2(1)
NA(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H13
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
K022*
Toluene (CAS 108-88-3)
Acetophenone (CAS 96-86-2)
Diphenylamine (CAS 22-39-4)
Diphenylnitrosamine (CAS 86-30-60)
Sum of Diphenylamine and Diphenylnitrosamine
Phenol (CAS 108-95-2)
Chromium (total) (CAS 7440-47-32)
Nickel (CAS 7440-02-0)
K023 and K024
Phthalic anhydride (measured as Phthalic acid) (CAS 85-44-9)
K028*
1,1-Dichloroethane (CAS 75-34-3)
trans- 1 ,2-Dichloroethane
Hexachlorobutadiene (CAS 87-68-3)
Hexachloroethane (CAS 67-72-1)
Pentachloroethane (CAS 76-01-7)
1,1,1,2-Tetrachloroethane (CAS 630-20-6)
1,1,2,2-Tetrachloroethane (CAS 79-34-6)
1,1,1-Trichlorethane (CAS 71-55-6)
1,1,2-Trichlorethane (CAS 79-00-5)
Tetrachloroethylene (CAS 127-18-4)
Cadmium (CAS 7440-43-9)
Chromium (total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
K029 Chloroform (CAS 67-66-3)
1,2-Dichloroethane (CAS 107-06-2)
1,1-Dichloroethylene (CAS 75-35-4)
1,1,1-Trichloroethane (CAS 71-55-6)
Vinyl chloride (CAS 75-01-4)
Concentrations
Wastewaters
(mg/L) Notes
0.080 (2)
0.010
0.52 (2)
0.40 (2)
NA
0.039
0.35
0.47
0.54(1)
0.007(1)
0.033(1)
0.007(1)
0.033(1)
0.033(1)
0.007(1)
0.007(1)
0.007(1)
0.007(1)
0.007(1)
6.4
0.35
0.037
0.47
0.046
0.21
0.025
0.054
0.27
Non- Wastewaters
(mg/kg) Notes
0.034(1)
19(1)
NA
NA
13(1)
12(1)
NA
NA
28(1)
6.0(1)
6.0(1)
5.6(1)
28(1)
5.6(1)
5.6(1)
5.6(1)
6.0(1)
6.0(1)
6.0(1)
NA
NA
NA
NA
6.0(1)
6.0(1)
6.0(1)
6.0(1)
6.0(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H14
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
K030
o-Dichlorobenzene (CAS 95-50-1)
p-Dichlorobenzene (CAS 106-46-7)
Hexachlorobutadiene (CAS 87-68-3)
Hexachloroethane (CAS 67-72-1)
Hexachloropropene (CAS 1888-71-7)
Pentachlorobenzene (CAS 608-93-5)
Pentachloroethane (CAS 76-01-7)
1,2,4,5-Tetrachlorobenzene (CAS 76-01-7)
Tetrachloroethane (CAS 127-18-4)
1,2,4-Trichlorobenzene (CAS 120-82-1)
K031*
Arsenic (CAS 7440-38-2)
K032
Hexachloropentadiene (CAS 77-47-4)
Chlordane (CAS 57-74-9)
Heptachlor (CAS 76-44-8)
Heptachlor epoxide (CAS 1024-57-3)
K033 and K034 Hexachlorocyclopentadiene (CAS 77-47-4)
K035
Acenaphthene (CAS 83-32-9)
Anthracene (CAS 120-12-7)
Benz(a)anthracene (CAS 56-55-3)
Benzo(a)pyrene (CAS 5-32-8)
Chrysene (CAS 218-01-9)
Dibenz(a,h)anthracene (CAS 53-70-3)
Fluoranthene (CAS 206-44-0)
Fluorene (CAS 86-73-7)
Indeno(l,2,3-cd)pyrene (CAS 193-39-5)
Cresols (m-and p-isomers)
Naphthalene (CAS 91-20-3)
o-cresol (CAS 95-48-7)
Concentrations
Wastewaters
(mg/L) Notes
0.008(1)
0.008(1)
0.007(1)
0.033(1)
NA
NA
0.007(1)
0.017
0.007(1)
0.023(1)
0.79
0.057 (2)
0.0033 (2)
0.012(2)
0.016(2)
0.057 (2)
NA
NA
0.059 (2)
NA
0.059 (2)
NA
0.068 (2)
NA
NA
0.77 (2)
0.059 (2)
0.11(2)
Non- Wastewaters
(mg/kg) Notes
NA
NA
5.6(1)
28(1)
19(1)
28(1)
5.6(1)
14(1)
6.0(1)
19(1)
NA
2.4(1)
0.26(1)
0.066(1)
0.066(1)
2.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
NA
3.4(1)
NA
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H15
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Phenanthrene (CAS 85-01-8)
Phenol (CAS 108-95-2)
Pyrene (CAS 129-00-0)
K036
Disulfoton (CAS 298-04-4)
K037
Disulfoton (CAS 298-04-4)
Toluene (CAS 108-88-3)
K038
Phorate (CAS 298-02-2)
K040
Phorate (CAS 298-02-2)
K041
Toxaphene (CAS 8001-35-1)
K042
1,2,4,5-Tetrachlorobenzene (CAS 95-94-3)
o-Dichlorobenzene (CAS 95-50-1)
p-Dichlorobenzene (CAS 106-46-7)
Pentachlorobenzene (CAS 608-93-5)
1,2,4-Trichlorobenzene (CAS 120-82-1).
K043
2,4-Dichlorophenol (CAS 120-83-2)
2,6-Dichlorophenol (CAS 87-65-0)
2,4,5-Trichlorophenol (CAS 95-95-4)
2,4,6-Trichlorophenol (CAS 88-06-2)
Tetrachlorophenols (total)
Pentachlorophenol (CAS 87-86-5)
Tetrachloroethene (CAS 79-01-6)
Hexachlorodibenzo-p-dioxins
Hexachlorodibenzo-furans
Pentachlorodibenzo-p-dioxins
Pentachlorodibenzo-furans
Tetrachlorodibenzo-p-dioxins
Concentrations
Wastewaters
(mg/L) Notes
0.059 (2)
0.039
0.067 (2)
0.025 (2)
0.025 (2)
0.080 (2)
0.025 (2)
0.025 (2)
0.0095 (2)
0.055 (2)
0.088 (2)
0.090 (2)
0.055 (2)
0.055 (2)
0.049(1)
0.013(1)
0.016(1)
0.039(1)
0.018(1)
0.22(1)
0.006(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
Non- Wastewaters
(mg/kg) Notes
3.4(1)
NA
8-2(1)
0.1(1)
0.1(1)
28(1)
0.1(1)
0.1(1)
2.6(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
0.38(1)
0.34(1)
8.2(1)
7.6(1)
0.68(1)
1.9(1)
1.7(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H16
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Tetrachlorodibenzo-furans
K046*
Lead (CAS 7439-92-1)
K048*
Benzene (CAS 7 1-43-2)
Benzo(a)pyrene (CAS 50-32-8)
Bis(2-ethylhexy)phthalate (CAS 117-81-7)
Chrysene (CAS 218-01-9)
Di-n-butyl phthalate (CAS 84-74-2)
Ethylbenzene (CAS 100-41-4)
Fluorene (CAS 86-73-7)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
Phenol (CAS 108-95-2)
Pyrene (CAS 129-00-0)
Toluene (CAS 108-88-3)
Xylene(s)
Cyanides(total) (CAS 57-12-5)
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K049*
Anthracene (CAS 120-12-7)
Benzene (CAS 7 1-43-2)
Benzo(a)pyrene (CAS 5-32-8)
Bis(2-ethylhexyl)phthalate (CAS 117-81-7)
Carbon disulfide (CAS 75-15-0)
Chrysene (CAS 2218-01-9)
2,4-Dimethylphenol (CAS 105-67-9)
Ethylbenzene (CAS 100-41-4)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
Concentrations
Wastewaters
(mg/L) Notes
0.001(1)
0.037
0.011(1)
0.047(1)
0.043(1)
0.043(1)
0.06(1)
0.011(1)
0.005(1)
0.033(1)
0.039(1)
0.047(1)
0.045(1)
0.011(1)
0.011(1)
0.028(1)
0.2
0.037
0.039(1)
0.011(1)
0.047(1)
0.043(1)
0.011(1)
0.043(1)
0.033(1)
0.011(1)
0.033(1)
0.039(1)
Non- Wastewaters
(mg/kg) Notes
0.001(1)
NA
14(1)
12(1)
7.3(1)
15(1)
3.6(1)
14(1)
NA
42(1)
34(1)
3.6(1)
36(1)
14(1)
22(1)
1.8(1)
NA
NA
28(1)
14(1)
12(1)
7.3(1)
NA
15(1)
NA
14(1)
42(1)
34(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H17
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Phenol (CAS 108-95-2)
Pyrene (CAS 129-00-0)
Toluene (CAS 108-88-3)
Xylene(s)
Cyanides(total) (CAS 57-12-5)
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K050*
Benzo(a)pyrene (CAS 50-32-8)
Phenol (CAS 108-95-2)
Cyanides(total) (CAS 57-12-5)
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K051* Acenaphthene (CAS 208-96-8)
Anthracene (CAS 120-12-7)
Benzene (CAS 7 1-43-2)
Benzo(a)anthracene (CAS 50-32-8)
Benzo(a)pyrene (CAS 117-81-7)
Bis(2-ethylhexyl)phthalate) (CAS 75-15-0)
Chrysene (CAS 2218-01-09)
Di-n-butyl phthalate (CAS 105-67-9)
Ethylbenzene (CAS 100-41-4)
Fluorene (CAS 86-73-7)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
Phenol (CAS 108-95-2)
Pyrene (CAS 129-00-0)
Toluene (CAS 108-88-3)
Xylene(s)
Cyanides(total) (CAS 57-12-5)
Concentrations
Wastewaters
(mg/L) Notes
0.047(1)
0.045(1)
0.011(1)
0.011(1)
0.028(1)
0.2
0.037(1)
0.047(1)
0.047(1)
0.028(1)
0.2
0.037
0.05(1)
0.039(1)
0.011(1)
0.043(1)
0.047(1)
0.043(1)
0.06(1)
0.011(1)
0.05(1)
0.033(1)
0.039(1)
0.047(1)
0.045(1)
0.011(1)
0.011(1)
Non- Wastewaters
(mg/kg) Notes
3.6(1)
36(1)
14(1)
22(1)
1.8(1)
NA
NA
12
3.6(1)
1.8(1)
NA
NA
NA
28(1)
14(1)
20(1)
12(1)
7.3(1)
3.6(1)
14(1)
42(1)
34(1)
3.6(1)
36(1)
14(1)
22(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H18
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K052* Benzene (CAS 71-43-2)
Benzo(a)pyrene (CAS 50-32-8)
o-Cresol (CAS 95-48-7)
p-Cresol (CAS 106-44-5)
2,4-Dimethylphenol (CAS 105-67-9)
Ethylbenzene (CAS 100-41-4)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
Phenol (CAS 108-95-2)
Toluene (CAS 108-88-3)
Xylenes
Cyanides(total) (CAS 57-12-5)
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K060
Benzene (CAS 7 1-43-2)
Benzo(a)pyrene) (CAS 50-32-8)
Naphthalene (CAS 91-20-3)
Phenol (CAS 108-95-2)
Cyanides(total) (CAS 57-12-5)
K061*
Cadmium (CAS 7440-43-9)
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
K062*
Chromium(total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
Nickel (CAS 7440-02-0)
Concentrations
Wastewaters
(mg/L) Notes
0.028(1)
0.2
0.011(1)
0.047(1)
0.011(1)
0.011(1)
0.033(1)
0.011(1)
0.033(1)
0.039(1)
0.047(1)
0.011(1)
0.011(1)
0.028(1)
0.2
0.037
0.17(1,2)
0.035 (1,2)
0.028 (1,2)
0.042 (1,2)
1.9
1.61
0.32
0.51
0.44
0.32
0.04
0.44
Non- Wastewaters
(mg/kg) Notes
1.8(1)
NA
14(1)
12(1)
6.2(1)
6.2(1)
NA
14(1)
42(1)
34(1)
3.6(1)
14(1)
22(1)
1.8(1)
NA
NA
0.071(1)
3.6(1)
3.4(1)
3.4(1)
1.2
NA
NA
NA
NA
NA
NA
NA
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H19
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
K069***
Cadmium (CAS 7440-43-9)
Lead (CAS 7439-92-1)
K071*
Mercury (CAS 7439-97-6)
K073
Carbon tetrachloride (CAS 56-23-5)
Chloroform (CAS 67-66-3)
Hexachloroethane (CAS 67-72-1)
Tetrachloroethene (CAS 127-18-4)
1,1,1-Trichloroethane (CAS 71-55-6)
K083*
Benzene (CAS 7 1-34-2)
Aniline (CAS 62-53-3)
Diphenylamine (CAS 22-39-4)
Diphenylnitrosamine (CAS 86-30-6)
Sum of diphenylamine and Diphenyl- nitrosamine
Nitrobenzene (CAS 98-95-3)
Phenol (CAS 108-95-2)
Cyclohexanone (CAS 108-94-1)
Nickel (CAS 7440-02-0)
K084 Arsenic (CAS 7440-38-2)
K085 Benzene (CAS 71-43-2)
Chlorobenzene (CAS 108-90-7)
o-Dichlorobenzene (CAS 95-50-1)
m-Dichlorobenzene (CAS 541-73-1)
p-Dichlorobenzene (CAS 106-46-7)
1,2,4-Trichlorobenzene (CAS 120-82-1)
1,2,4,5-Tetrachlorobenzene (CAS 95-94-3)
Pentachlorobenzene (CAS 608-93-5)
Hexachlorobenzene (CAS 118-74-1)
Aroclor 1016 (CAS 12674-11-2)
Concentrations
Wastewaters
(mg/L) Notes
1.6
0.51
0.030
0.057 (2)
0.046 (2)
0.055 (2)
0.056 (2)
0.054 (2)
0.14(2)
0.81
0.52 (2)
0.40 (2)
NA
0.068 (2)
0.039 (2)
0.36
0.47
0.79
0.14(2)
0.057 (2)
0.088 (2)
0.036 (2)
0.090 (2)
0.055 (2)
0.055 (2)
0.055 (2)
0.055 (2)
0.013(2)
Non- Wastewaters
(mg/kg) Notes
NA
NA
NA
6.2(1)
6.2(1)
30(1)
6.2(1)
6.2(1)
6.6(1)
14(1)
NA
NA
14(1)
14(1)
5.6(1)
NA
NA
NA
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
0.92(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H20
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Aroclor 1221 (CAS 11104-28-2)
Aroclor 1232 (CAS 11141-16-5)
Aroclor 1242 (CAS 53469-21-9)
Aroclor 1248 (CAS 12672-29-6)
Aroclor 1254 (CAS 11097-69-1)
Aroclor 1260 (CAS 11096-82-5)
K086* Acetone (CAS 67-64-1)
Acetophenone (CAS 96-86-2)
Bis(2-ethylhexyl)phthalate
n-Butyl alcohol (CAS 71-36-3)
Butyl benzyl phthalate (CAS 85-68-7)
Cyclohexanone (CAS 108-94-1)
1,2-Dichlorobenzene (CAS 95-50-1)
Diethyl phthalate (CAS 84-66-2)
Dimethylphthalate (CAS 131-11-3)
Di-n-butylphthalate (CAS 84-74-2)
Di-n-octylphthalate (CAS 117-84-0)
Ethyl acetate (CAS 141-78-6)
Ethylbenzene (CAS 100-41-4)
Methanol (CAS 67-56-1)
Methyl isobutyl ketone (CAS 108-10-1)
Methyl ethyl ketone (CAS 78-93-3)
Methylene chloride (CAS 75-09-2)
Naphthalene (CAS 91-20-3)
Nitrobenzene (CAS 98-95-3)
Toluene (CAS 108-88-3)
1,1,1-Trichloroethane (CAS 71-55-6)
Trichloroethylene (CAS 79-01-6)
Xylenes (Total)
Cyanides (Total) (CAS 57-12-5)
Concentrations
Wastewaters
(mg/L) Notes
0.014(2)
0.013(2)
0.017(2)
0.013(2)
0.014(2)
0.014(2)
0.28
0.010
0.28 (2)
5.6
0.017(2)
0.36
0.088
0.20 (2)
0.047 (2)
0.057 (2)
0.017(2)
0.34 (2)
0.057 (2)
5.6 (2)
0.14
0.28
0.089 (2)
0.059 (2)
0.068 (2)
0.080 (2)
0.054 (2)
0.054 (2)
0.32 (2)
1.91.5
Non- Wastewaters
(mg/kg) Notes
0.92(1)
0.92(1)
0.92(1)
0.92(1)
1.8(1)
1.8(1)
160(1)
9.7(1)
28(1)
2.6(1)
7.9(1)
NA
6.2(1)
28(1)
28(1)
28(1)
28(1)
33(1)
6.0
NA
33(1)
36(1)
33(1)
3.1(1)
14(1)
28(1)
5.6(1)
5.6(1)
28(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H21
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Chromium (Total) (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K087* Acenaphthylene (CAS 208-96-8)
Benzene (CAS 7 1-43-2)
Chrysene (CAS 218-01-9)
Fluoranthene (CAS 206-44-0)
Indeno(l,2,3-cd)pyrene (CAS 193-39-5)
Naphthalene (CAS 91-20-3)
Phenanthrene (CAS 85-01-8)
Toluene (CAS 85-01-8)
Xylenes
Lead (CAS 7439-92-1)
K093 and K094 Phthalic anhydride (CAS 85-44-9)
(measured as Phthalic acid)
K095
1,1,1,2-Tetrachloroethane (CAS 630-20-6)
1,1,2,2-Tetrachloroethane (CAS 79-34-6)
Tetrachloroethene (CAS 127-18-4)
1,1,2-Trichloroethane (CAS 79-00-5)
Trichloroethylene (CAS 79-01-6)
Hexachloroethane (CAS 67-72-1)
Pentachloroethane (CAS 76-01-7)
K096 1,1,1,2-Tetrachloroethane (CAS 630-20-6)
1,1,2,2-Tetrachloroethane (CAS 79-34-6)
Tetrachloroethene (CAS 127-18-4)
1,1,2-Trichloroethane (CAS 79-00-5)
Trichloroethene (CAS 79-01-6)
Trichloroethylene (CAS 79-01-6)
1,3-Dichlorobenzene (CAS 541-73-1)
Pentachloroethane (CAS 76-01-7)
1,2,4-Trichlorobenzene (CAS 120-82-1)
Concentrations
Wastewaters
(mg/L) Notes
0.32
0.037
0.028(1)
0.014(1)
0.028(1)
0.028(1)
0.028(1)
0.028(1)
0.028(1)
0.008(1)
0.014(1)
0.037
0.54(1)
0.057
0.057
0.056
0.054
0.054
0.055
0.055
0.057
0.057
0.056
0.054
0.054
0.054
0.036
0.055
0.055
Non- Wastewaters
(mg/kg) Notes
NA
NA
3.4(1)
0.071(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
3.4(1)
0.65(1)
0.07(1)
NA
28(1)
5.6(1)
5.6(1)
6.0(1)
6.0(1)
5.6(1)
28(1)
5.6(1)
5.6(1)
5.6(1)
6.0(1)
6.0(1)
5.6(1)
5.6(1)
5.6(1)
5.6(1)
19(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H22
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
K097 Hexachlorocyclopentadiene (CAS 77-47-4)
Chlordane (CAS 57-74-9)
Heptachlor (CAS 76-44-8)
Heptachlor epoxide (CAS 1024-57-3)
K098
Toxaphene (CAS 8001-35-1)
K099
2,4-Dichlorophenoxyacetic acid (CAS 94-75-7)
Hexachlorodibenzo-p-dioxins
Hexachlorodibenzofurans
Pentachlorodibenzo-p-dioxins
Pentachlorodibenzofurans
Tetrachlorodibenzo-p-dioxins
Tetrachlorodibenzofurans
K100*
Cadmium (CAS 7440-43-9)
Chromium (CAS 7440-47-32)
Lead (CAS 7439-92-1)
K101
o-Nitroaniline
Arsenic (CAS 7440-38-2)
Cadmium (CAS 7440-43-9)
Lead (CAS 7439-92-1)
Mercury (CAS 7439-97-6)
K102*
o-Nitrophenol
Arsenic (CAS 7440-38-2)
Cadmium (CAS 7440-43-9)
Lead (CAS 7439-92-1)
Mercury (CAS 7439-97-6)
K103
Aniline (CAS 62-53-3)
Benzene (CAS 7 1-34-2)
Concentrations
Wastewaters
(mg/L) Notes
0.057 (2)
0.0033 (2)
0.0012 (2)
0.016(2)
0.0095 (2)
1.0(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
1.6
0.32
0.51
0.27(1)
0.79
0.24
0.17
0.082
0.028(1)
0.79
0.24
0.17
0.082
4.5
0.15
Non- Wastewaters
(mg/kg) Notes
2.4(1)
0.26(1)
0.066(1)
0.066(1)
2.6(1)
1.0(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
0.001(1)
NA
NA
NA
14(1)
NA
NA
NA
NA
13(1)
NA
NA
NA
NA
5.6(1)
6.0(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H23
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
2,4-Dinitrophenol (CAS 51-28-5)
Nitrobenzene (CAS 98-95-3)
Phenol (CAS 108-95-2)
K104
Aniline (CAS 62-53-3)
Benzene (CAS 7 1-43-2)
2,4-Dinitrophenol (CAS 51-28-5)
Nitrobenzene (CAS 98-95-3)
Phenol (CAS 108-95-2)
Cyanides (Total) (CAS 57-12-5)
K105
Benzene (CAS 7 1-43-2)
Chlorobenzene (CAS 108-90-7)
o-Dichlorobenzene (CAS 95-50-1)
p-Dichlorobenzene (CAS 106-46-7)
2,4,5-Trichlorophenol (CAS 95-95-4)
2,4,6-Trichlorophenol (CAS 88-06-2)
2-Chlorophenol (CAS 95-57-8)
Phenol (CAS 108-95-2)
K106***
Mercury (CAS 7439-97-6)
K115*
Nickel (CAS 7440-02-0)
P004 (Aldrin)
Aldrin (CAS 309-00-2)
P010* (Arsenic acid)
Arsenic (CAS 7440-38-2)
P011* (Arsenic pentoxide) Arsenic (CAS
7440-38-2)
P012* (Arsenic trioxide)
Arsenic (CAS 7440-38-2)
P013* (Barium cyanide) Cyanides (Total)
Cyanides (Amenable)
P020 (Dinoseb)
2-sec-Butyl-4,6-dinitrophenol (CAS 88-85-7)
Concentrations
Wastewaters
(mg/L) Notes
0.61
0.073
1.4
4.5
0.15
0.61
0.073
1.4
2.7
0.14
0.057
0.088
0.090
0.18
0.035
0.044
0.039
0.030
0.47
0.21 (2)
0.79
0.79
0.79
1.9
0.1
0.066
Non- Wastewaters
(mg/kg) Notes
5.6(1)
5.6(1)
5.6(1)
5.6(1)
6.0(1)
5.6(1)
5.6(1)
5.6(1)
1.8(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
4.4(1)
NA
NA
0.066(1)
NA
NA
NA
110
9.1
2.5(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H24
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
P021 (Calcium cyanide) Cyanides (Total) (CAS
57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P022** (Carbon disulfide) Carbon disulfide (CAS 75-15-0)
P024 (p-Chloroaniline)
p-Chloroaniline (CAS 106-47-8)
P029 (Copper cyanide) Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P030 (Cyanides (soluble salts and complexes)
Cyanides (Total) (CAS 57-12-5)
Cyanides (Amendable) (CAS 57-12-5)
P036* (Dichlorophenylarsine) Arsenic (CAS 7440-38-2)
P037
Dieldrin (CAS 60-57-1)
P038* (Diethylarsine)
Arsenic (CAS 7440-38-2)
P039
Disulfoton (CAS 298-04-4)
P047
4,6-Dinitro-o-cresol (CAS 534-52-1)
P048
2,4-Dinitrophenol (CAS 51-28-5)
P050
Endosulfan I (CAS 939-98-8)
Endosulfan II (CAS 33213-6-5)
Endosulfan sulfate (CAS 1031-07-8)
P051
Endrin (CAS 72-20-8)
Endrin aldehyde (CAS 7421-93-4)
P056**
Fluoride (CAS 16964-48-8)
P059
Heptachlor (CAS 76-44-8)
Heptachlor epoxide (CAS 1024-57-3)
P060
Isodrin (CAS 465-73-6)
Concentrations
Wastewaters
(mg/L) Notes
1.9
0.1
0.014
0.46
1.9
0.1
1.9
0.1
0.79
0.017(2)
0.79
0.017
0.28
0.12(2)
0.023 (2)
0.029 (2)
0.029 (2)
0.0028 (2)
0.025 (2)
35
0.0012 (2)
0.016(2)
0.021 (2)
Non- Wastewaters
(mg/kg) Notes
110
9.1
NA
16(1)
110
9.1
110
9.1
NA
0.13(1)
NA
0.1(1)
160(1)
160(1)
0.066(1)
0.13(1)
0.13(1)
0.13(1)
0.13(1)
NA
0.066(1)
0.066(1)
0.066(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H25
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
P063 (Hydrogen cyanide) Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P065*** (Mercury fulminate) Mercury (CAS 7439-97-6)
P071
Methyl parathion (CAS 298-00-0)
P073* (Nickel carbonyl)
Nickel (CAS 7440-02-0)
P074* (Nickel cyanide) Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (Cas 57-12-5)
Nickel (CAS 7440-02-0)
P077
p-Nitroaniline (CAS 100-01-6)
P082**
N-Nitrosodimethylamine (CAS 62-75-9)
P089
Parathion (CAS 56-38-2)
P092*** (Phenylmercury acetate)
Mercury (CAS 7439-97-6)
P094
Phorate (CAS 298-02-2)
P097
Famphur (CAS 52-85-7)
P098 (Potassium cyanide) Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P099* (Potassium silver cyanide)
Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
Silver (CAS 7440-22-4)
P101
Ethyl cyanide (Propanenitrite)
(CAS 107-12-0)
PI 03* (Selenourea)
Selenium (CAS 7782-49-2)
P104* (Silver cyanide)
Cyanides (Total) (CAS 57-12-5)
Concentrations
Wastewaters
(mg/L) Notes
1.9
0.10
0.030
0.025
0.32
1.9
0.10
0.44
0.028 (2)
0.40 (2)
0.025
0.030
0.025
0.025
1.9
0.10
1.9
0.1
0.29
0.24 (2)
1.0(2)
1.9
Non- Wastewaters
(mg/kg) Notes
110
9.1
NA
0.1(1)
NA
110
9.1
NA
28(1)
NA
0.1(1)
NA
0.1(1)
0.1(1)
110
9.1
110
9.1
NA
360(1)
NA
110
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H26
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Cyanides (Amendable) (CAS 57-12-5)
Silver (CAS 7440-22-4)
P106 (Sodium cyanide) Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P110***(Tetraethyllead)
Lead (CAS 7439-92-1)
P113**(Thallicoxide)
Thallium (CAS 7440-28-0)
PI 14* (Thallium selenite) Selenium (CAS 7782-49-2)
PI 15** (Thallium(l)sulfate) Thallium (CAS 7440-28-0)
PI 19** (Ammonia vanadate) Vanadium (CAS 7440-62-2)
P120** (Vanadium pentoxide) Vanadium (CAS 7440-62-2)
P121 (Zinc cyanide)
Cyanides (Total) (CAS 57-12-5)
Cyanides (Amenable) (CAS 57-12-5)
P123
Toxaphene (CAS 8001-35-1)
U002
Acetone (CAS 67-64-1)
U003**
Acetonitrile (CAS 75-05-8)
U004
Acetophenone (CAS 98-86-2)
U005
2-Acetylaminofluorene (CAS 53-96-3)
U009
Acrylonitrile (CAS 107-13-1)
U012
Aniline (CAS 62-53-3)
U018
Benz(a)anthracene (CAS 56-55-3)
U019
Benzene (CAS 7 1-34-2)
U022
Benzo(a)pyrene (CAS 50-32-8)
Concentrations
Wastewaters
(mg/L) Notes
0.10
0.29
1.9
0.10
0.040
0.14(2)
1.0
0.14(2)
28(2)
28(2)
1.9
0.10
0.0095 (2)
0.28
0.17
0.010(1)
0.059 (2)
0.24 (2)
0.81
0.059 (2)
0.14(2)
0.061 (2)
Non- Wastewaters
(mg/kg) Notes
9.1
NA
110
9.1
NA
NA
NA
NA
NA
NA
110
9.1
1.3(1)
160(1)
0.17
9.7(1)
140(1)
84(1)
14(1)
8.2(1)
36(1)
8.2(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H27
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
U024
Bis(2-chloroethoxy)methane (CAS 111-91-1).
U025
Bis(2-chloroethyl)ether (CAS 1 1 1-44-4)
U027
Bis(2-chloroisopropyl)ether (CAS 39638-32-9)
U028
Bis(2-ethylhexyl)phthalate (CAS 117-81-7)
U029
Bromomethane (Methyl bromide) (CAS 74-83-9)
U030
4-Bromophenyl phenyl ether (CAS 101-55-3)
U031
n-Butyl alcohol (CAS 71-36-3)
U032* (Calcium chromate) Chromium (Total)
(CAS 7440-47-32)
U036
Chlordane (alpha and gamma)(CAS 57-74-9)
U037
Chlorobenzene (CAS 108-90-7)
U038**
Chlorobenzilate (CAS 510-15-6)
U039
p-Chloro-m-cresol (CAS 59-50-7)
U042**
2-Chloroethylvinyl (CAS 110-75-8)
U043
Vinyl chloride (CAS 75-01-4)
U044
Chloroform (CAS 67-66-3)
U045 Chloromethane (Methyl chloride) (CAS
74-87-3).
U047 2-Chloronaphthalene (CAS 91-58-7)
U048 2-Chlorophenol (CAS 95-57-8)
U050 Chrysene (CAS 218-01-9)
U051* (Creosote) Naphthalene (CAS 91-20-3)
Pentachlorophenol (CAS 87-86-5)
Phenanthrene (CAS 85-01-8)
Concentrations
Wastewaters
(mg/L) Notes
0.036
0.033
0.055 (2)
0.54(1)
0.11(1)
0.055(1)
5.6
0.32
0.033 (2)
0.057 (2)
0.10(2)
0.018(2)
0.057
0.27 (2)
0.046 (2)
0.19(2)
0.055 (2)
0.044 (2)
0.059 (2)
0.031
0.18
0.031
Non- Wastewaters
(mg/kg) Notes
7.2(1)
7.2(1)
7.2(1)
28(1)
15(1)
15(1)
2.6
NA
0.13(1)
5.7(1)
NA
14(1)
NA
33(1)
5.6(1)
33(1)
5.6(1)
5.7(1)
8.2(1)
1.5(1)
7.4(1)
1.5(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H28
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
Pyrene (CAS 129-00-0)
Toluene (CAS 108-88-3)
Xylenes (Total)
Lead (CAS 7439-92-1)
U052 (Cresols-Cresylic acid) o-Cresol (CAS 95-48-7)
Cresols (m- and p- isomers)
U057** Cyclohexanone (CAS 108-94-1)
U060 (DDD) o,p'-DDD (CAS 53-19-0)
o,p'-DDD (CAS 72-54-8)
U061 (DDT) o,p'-DDT (CAS 780-02-6)
p,p'-DDT (CAS 50-29-3)
o,p'-DDD (CAS 53-19-0)
p,p'-DDD (CAS 72-54-8)
o,p'-DDE (CAS 3424-82-6)
U063 Dibenzo(a,h)anthracene (CAS 53-70-3)
U066 l,2-Dibromo-3-chloropropane(CAS 96-12-8)
U067 1,2-Dibromo ethane (Ethylene dibromide) (CAS 106-93-4)
U068 Dibromethane (CAS 74-95-3)
U069 Di-n-butyl phathalate (CAS 84-74-2)
U070 o-Dichlorobenzene (CAS 95-50-1)
U071 m-Dichlorobenzene (CAS 541-73-1)
U072 p-Dichlorobenzene (CAS 104-46-7)
U075 Dichlorodifluoromethane (CAS 75-71-8)
U076 l,l-Dichloroethane(CAS 75-34-3)
U077 1,2-Dichloroethane (CAS 107-06-2)
U078 1,1-Dichloroethylene (CAS 75-35-4)
U079 (1,2-Dichloroethylene) trans- 1,2-Dichloroethylene (CAS 156-60-5)
U080 Methylene chloride (CAS 75-09-2)
U081 2,4-Dichlorophenol (CAS 120-83-2)
U082 2,6-Dichlorophenol (CAS 87-65-0)
Concentrations
Wastewaters
(mg/L) Notes
0.028
0.028
0.032
0.037
0.11(2)
0.77 (2)
0.36
0.023
0.023
0.0039 (2)
0.0039 (2)
0.023 (2)
0.023 (2)
0.031 (2)
0.055 (2)
0.11(2)
0.028 (2)
0.11(2)
0.54(1)
0.088 (2)
0.036
0.090 (2)
0.23 (2)
0.059 (2)
0.21 (2)
0.025 (2)
0.054 (2)
0.089 (2)
0.044 (2)
0.044 (2)
Non- Wastewaters
(mg/kg) Notes
1.5(1)
28(1)
33(1)
NA
5.6(1)
3.2(1)
NA
0.087(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
0.087(1)
8.2(1)
15(1)
15(1)
15(1)
28(1)
6.2(1)
6.2(1)
6.2 (2)
7.2(1)
7.2(1)
7.2(1)
33(1)
33(1)
33(1)
14(1)
14(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H29
-------
Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
U083 1,2-Dichloropropane (CAS 78-87-5)
U084 (1,3-Dichloropropene) cis-l,3-Dichloropropylene (CAS 10061-01-5)
trans- 1,3-Dichloropropylene (CAS 10061-02-6)
U088 Diethyl phthalate (CAS 84-66-2)
U093** p-Dimethylaminoazobenzene (CAS 60-11-7)
U101 2,4-Dimethylphenol (CAS 105-67-9)
U102 Dimethyl phthalate (CAS 131-11-3)
U105 2,4-Dinitrotoluene (CAS 121-14-2)
U106 2,6-Dinitrotoluene (CAS 606-20-2)
U107 Di-n-octyl phthalate (CAS 117-84-0)
U108 l,4-Dioxane(CAS 123-91-1)
Ulll Di-n-propylnitrosamine (CAS 621-64-7)
U112 Ethyl acetate (CAS 141-78-6)
U117 Ethyl ether (CAS 60-29-7)
Ul 18 Ethyl methacrylate (CAS 97-63-2)
U120 Fluoranthene (CAS 206-44-0)
U121 richloromonofluoromethane (CAS 75-69-4)
U127 Hexachlorobutadiene (CAS 118-74-1)
U128 Hexachlorobutadiene (CAS 87-68-3)
U129 (Lindane) alpha-BHC (CAS 319-84-6)
beta-BHC (CAS 319-85-7)
delta-BHC (CAS 319-86-8)
gamma-BHC (Lindane) (CAS 58-89-9)
U130 Hexachlorocyclopentadiene (CAS 77-47-7)
U131 Hexachloroethane (CAS 67-72-1)
U134** (Hydrogen fluoride) Floride (CAS 16964-48-8)
U136* (Cacodylic acid) Arsenic (CAS 7440-38-2)
U137* Indeno(l,2,3-c,d)pyrene(CAS 193-39-5)
UBS lodomethane (CAS 74-88-4)
U140 Isobutyl alcohol (CAS 78-83-1)
Concentrations
Wastewaters
(mg/L) Notes
0.85 (2)
0.036 (2)
0.036 (2)
0.54 (2)
0.13(2)
0.036 (2)
0.54(1)
0.32 (2)
0.55 (2)
0.54(1)
0.12(2)
0.40 (20
0.34 (2)
0.12(2)
0.14(2)
0.068 (2)
0.020 (2)
0.055 (2)
0.055 (2)
0.00014 (2)
0.00014 (2)
0.023 (2)
0.0017 (2)
0.057 (2)
0.055 (2)
35
0.79
0.0055 (2)
0.19(2)
5.6
Non- Wastewaters
(mg/kg) Notes
18(1)
18(1)
18(1)
28(1)
NA
14(1)
28(1)
140(1)
28(1)
28(1)
170(1)
14(1)
33(1)
160(1)
160(1)
8.2(1)
33(1)
37(1)
28(1)
0.66(1)
0.66(1)
0.66(1)
0.66(1)
3.6(1)
28(1)
NA
NA
6.2(1)
65(1)
170(1)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of TSDFs under RCRA
Appendix H: Constituent Concentrations in Wastes (CCW) (40 CFR 268.43(a))
Waste Codes
Regulated Hazardous Constituent with Applicable CAS Numbers
U141 Isosafrole (CAS 120-58-1)
U142 Kepone (CAS 143-50-8)
U144* (Lead acetate) Lead (CAS 7439-92-1)
U145* (Lead phosphate) Lead (CAS 7439-92-1)
U146* (Lead subacetate) Lead (CAS 7439-92-1)
U151*** Mercury (CAS 7439-97-6)
U152 Methacrylonitrile (CAS 126-98-7)
U154 Methanol (CAS 67-56-1)
U155 Methapyrilene (CAS 91-80-5)
U157 3-Methylcholanthrene (CAS 56-49-5)
U158 4,4'-Methylenebis(2-chloroaniline)(CAS 101-14-4)
U159 Methyl ethyl ketone (CAS 78-93-3)
U162 Methyl methacrylate (CAS 60-62-6)
U165 Naphthalene (CAS 91-20-3)
U168** 2-Naphthylamine (CAS 91-59-8)
U169 Nitrobenzene (CAS 98-95-3)
U170 4-Nitrophenol (CAS 100-02-7)
Concentrations
Wastewaters
(mg/L) Notes
0.081
0.0011
0.040
0.040
0.040
0.030
0.24 (2)
5.6
0.081
0.0055 (2)
0.50(2)
0.28
0.14
0.059 (2)
0.52 (2)
0.068 (2)
0.12(2)
Non- Wastewaters
(mg/kg) Notes
2.6(1)
0.13(1)
NA
NA
NA
NA
84(1)
NA
1.5(1)
15(1)
35(1)
36(1)
160(1)
3.1(1)
NA
14
29(1)
* See also Appendix 4-8, Table CCWE in 40 CFR 268.41
** See also Appendix 4-9, Table 2 in 40 CFR 268.42
*** See also Appendix 4-8, Table CCWE in 40 CFR 268.41 and Table 2 in 268.42
(1) Treatment standards for this organic constituent were established based upon incineration in units operated in accordance with the
technical requirements of 40 CFR Part 264 Subpart O or Part 265 Subpart O, or based upon combustion in fuel substitution units
operating in accordance with applicable technical requirements. A facility may certify compliance with these treatment standards
according to provisions in 40 CFR Part 268.7.
(2) Based on analysis of composite samples.
(3) As analyzed using SW-846 Method 9010 or 9012; sample size 10 gram; distillation time: one hour and fifteen minutes.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
H31
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