vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9445.03(34)
' Analytical Methods for Petroleum Refining Residues and Hastes
APPROVAL DATE: 5-25-84
EFFECTIVE DATE: 5-25-84
ORIGINATING OFFICE: Office of Solid Waste
0 FINAL
D DRAFT
STATUS:
[ 1
{ 1
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- .In development or circulating
headquarters
REFERENCE (other documents):
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
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PART 261 - APPENDICES
DOC: 9445.03(84)
Key Words: Refinery Waste, Test Methods
Regulations:
Subject: Analytical Methods for Petroleum Refining Residues and Wastes
Addressee: Hazardous Waste Branch Chiefs, Regions I-X
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: #9445.03(84)
Date:
Summary:
5-25-84
The draft document, "Handbook for the Analysis of Petroleum Refinery
Residues and Wastes," describes the analytical plan OSW will employ in its
petroleum refinery waste study and is useful for RCRA permit writers in
evaluating petroleum waste analyses submitted in land treatment permit
applications. This document provides EPA's most recent guidance on analytical
methods for organics.
In using the draft document, two things should be noted. First, applicants
do not need to submit in the land treatment permit applications the EP toxicity,
test data described in Sections 3.1.1 and 3.1.2. Instead, applicants should
report total metal concentrations. Second, certain of the analytical quality
control procedures described may not be sufficient for RCRA permit waste analysis
plans. Applicants should specify in the permit application comprehensive
quality assurance/quality control (QA/QC) procedures for waste sampling and
analyses. Applicants can find general guidance on QA/QC procedures in Test
Methods for Evaluating Solid Wastes. SW-846, and Permit Applicants' Guidance
Manual for the General Facility Standards of 40 CFR 264, SW-968.
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34
Clarification of Guidance on Petroleum
Refinery Waste Analyses
John H. Skinner, Director
Office of Solid Waste
Hazardous Waste Branch Chiefs
Regions I-X
On April 3, 1984, I forwarded to yon a memo entitled,
"Guidance on Petroleum Refinery Waste Analyses for Land
Treatment Permit Applications" (see copy attached). My
April 3 memo provided guidance on evaluating petroleum
refinery waste analyses submitted in land treatment permit
applications. It included a list of hazardous constituents
suspected to be present in petroleum refinery wastes and
described the analytical methods for these wastes. This
memo provides additional guidance clarifying the analytic?1
methods that should be used for these wastes.
Attached is a copy of a draft document entitled,
"Handbook for the Analysis of Petroleum Pefinery Residues
and Waste." This document describes the analytical plan
that will be employed in OSW's petroleum refinery waste
study. The analytical plan includes sample preparation
techniques, inorganic and organic analytical methods, and
analytical quality control procedures. Although developed
for the OSW petroleum refinery waste study, the information
provided in the attached document will be useful in any
situation in which petroleum refinery waste analyses are
necessary, including RCRA permitting.
The draft analytical method for organics provided in my
April 3 memo was derived from an earlier draft of the attached
document* This revised document now includes a more complete
description of this method, and thus should be consulted by
permit writers and applicants as EPA's most recent guidance.
Specifically, Section 3.2 of the document includes the
analytical methods for organic parameters. The hazardous
organic constituents identified in my April 3 memo should be
evaluated in, waste analyses for land treatment permit.
applications.
f
In using the attached document, two points should be noted,
First, the Extraction Procedure (EP) toxicity test data, as
described in Sections 3.1.1 and 3.1.2, need not be submitted
in the land treatment permit application. Rather, total
metal concentrations should be reported in the application.
Second, certain of the analytical quality control procedures
described in this document, including frequency of procedural
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blanks, duplicates, and Instrumentation checks, may not he
sufficient for RC*A permit waste analysis plan?. The
analytical OA/OC procedures described were developed for
laboratories that are under close EPA supervision and are
participating in the OSV7 performance audit program. Also
OA/OC procedures for sampling are not addressed in the
attached document. Comprehensive quality assurance/quality
control procedures for waste sampling and analysis should be
specified in the permit application. General guidance on
OA/OC procedures can be found in Test Methods for Evaluating
Solid Wastes (sw-«4f») and in Permit Applicants^ Guidance
Manual for the General Facility Standards of 40 TFP 264
(SW-968).
If you have any questions on the analytical procedures
described in the attached document please contact Ben Smith
(FTS-382-4791) of the Waste Identification Branch. Any questions
regarding the use of this guidance in permitting land treatment
units should be directed to Mike Plynn. (FTS-382-44R9) of the Land'
Disposal Branch.
Attachments
cct Jack Lehman
Fred Lindsey
Ken Shuster
Eileen Claussen
Matt Straus
Bruce Meddle
Peter Guerrero
v,H-565E:MFlynn:ajj382-46b8:M2102:WSM:5/18/84
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