vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9445.05(84)
TITLE: RCRA Methods and Quality Assurance (QA) Activities
APPROVAL DATE: 12-20-84
EFFECTIVE DATE: 12-20-84
ORIGINATING OFFICE:
0 FINAL
of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
{ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- .In development or circulating
headquarters
REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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PART 261 - APPENDICES DOC: 9445.05(84)
Key Words: Test Methods, QA/QC, Analytic Methods
Regulations:
Subject: RCRA Methods and Quality Assurance (QA) Activities
i
Addressee: N/A
Originator: David Friedman, Manager, Methods Program
Source Doc: #9445.05(84)
Date: 12-20-84
Summar":
The following Issues were addressed in the memorandum:
1) The Method 3030 digestion procedure for waste oils is unsuitable for
the determination of barium, lead, mercury, and selenium. Method 3050
should be used for the digestion of these metals.
2) The RCRA Laboratory Evaluation Program (LEP) is being officially
implemented and expanded to include all EPA Regional laboratories and
OSW contractors. Since the Superfund program also established a LEP
as part of the CERCLA QA program, OSW and the Office of Emergency and
Remedial Response (OERR) will consolidate samples whenever possible
for individual program needs to minimize the impact-on participating
laboratories where possible.
3) The Waste Analysis Plans Guidance Manual for permit applicants and
permit reviewers and writers suggests a format for organizing the
waste analysis plan. The plan should be organized around the following
questions:
a) What are the specific wastes or types of wastes that will be
managed within each process?
b) What are the specific waste parameters that must be quantified in
order to satisfy the data needs?
c) What are the waste-associated properties that are of concern in
ensuring safe and effective management?
d) How will the necessary data be obtained?
The manual provides checklists to assure the completeness of the plan
and discusses "boundary conditions" and " tolerance limits."
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Continued from Document 9445.05(84)
4) Tests designed to determine whether a substance has explosive properties
are currently under consideration for international standardization. "
The Bureau of Mines proposed that these tests are suitable to determine
the properties described in 40 CFR §261.23(a)(6) and (7).
5) OSW proposed adopting a set of mandatory standard test methods to
improve the quality of ground-water monitoring at licensed hazardous
waste facilities.
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9445.05 (84.
2C :
MEMORANDUM - Number 4
SUBJECTi Notes on RCRA Methods and QA Activities
FROMi David Friedman, Manager
Methoda Program, WH-562B
TO« Addressees '
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*
« *-
We appreciate your comments and suggestions in response to
my previous RCRA Methods and QA Activities memos. This memo
will address several oC the topics suggested in recent
correspondences
RCRA Laboratory Evaluation Program
'. Standard Methods for Ground Water Testing
Method 3030 - Acid Digestion of Oils, Greases, and Waxes
Waste Analysis Plans Guidance Manual
Reactivity Evaluations for Solid Waste
RCRA Laboratory Evaluation Program
The Office of Solid Waste (OSW) appreciates the cooperation
of those Regional Laboratories that participated in the pilot
Laboratory Evaluation Program (LEP) that OSW conducted during
this past spring and summer. Now that the mechanics of the
program have been worked out, the RCRA LEP is being officially
implemented and expanded to include all EPA Regional Laboratories
and OSW contractors.
Since the Superfund program has also established a LEP as
part of the CERCLA QA program, OSW and the Office of Emergency
and Remedial Response (OERR) will consolidate sanples to minimize
the impact on participating laboratories wherever possible. The
differing needs of the two programs, however, will sonetimes
prevent such a consolidation.
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During PY 85, each laboratory will receive four sets of
check samples. Bach set will consist of two sanples to be
analyzed by different methods.
.*_. ... . .. - >'. r -
Standard Methods Proposed For Testing Hazardous Waste Facilities*
Ground water . ... ..
OSW recently proposed adopting a set of Mandatory standard
test methods to improve the quality of ground-water monitoring
at licensed hazardous waste facilities* It is expected that
such standardisation would also help speed up the permit process
by making the application evaluation process easier.
The rulemafcing of which this proposal is a part has five
objectives! 1) make the analysis and sampling methods in EPA
Publication 'Test Methods for Evaluating Solid Waste" (SW-846)
mandatory for all testing and monitoring activities required
under Subtitle C of RCRA; 2) consolidate in SW-846 all methods
necessary for Subtitle C testing; 3) eliminate certain requirements
for groundwatar testing in those limited circumstances where
the constituent being tested for immediately converts to another
substance upon contact with water* or where no testing method
has been developed to detect the constituent in question; 4) allow
the limited use of SW-846 methods for compliance monitoring
screening purposes; and 5) introduce the concept of hierarchical
testing that in certain cases may reduce the nunber of tests
required to determine whether classes of Appendix VIII compounds
are present* ._
As it stands now, hazardous waste facilities must sometimes
develop their own test methods to identify particular hazardous
constituents because EPA has not formally specified which of a
number of methods it considers acceptable. Federal and State
environmental officials must then approve these methods as
part of the facility permitting process. Since in the absence
of mandatory testing requirements Federal or State environ-
mental offices may develop differing requirements for acceptable
test methods, monitoring requirements and results may vary
from Region to Region (and State to State).
This proposed rule will allow permitting officials* to
quickly evaluate permit requests since all necessary methods
will be contained in a single manual. More important, by
consolidating test methods, it will be easier for the regulated
community to apply for and be granted hazardous waste permits.
For smaller facilities in particular, this proposal will help
assist them in meeting RCRA's permit requirements. In addition
to easing the permitting process, using standard methods for all
monitoring will better enable the Agency to determine the quality
of the data and to follow environmental quality trends.
Although EPA has prepared a series of draft guidance
documents which give some general information on monitoring
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methods, ho one document has hitherto listed all the sampling
and analysis methods that are specifically acceptable to osvr.
The proposed regulation proposes a number of new testing methods
and consolidates then into its existing test methods manual.
As noted above, the new standards also would save time and
coats? while maintaining environmental standards, by eliminating
groundwater testing for those chemicals that immediately decompose
in ground water* The proposed regulations would also reduce
unnecessary testing by allowing facilities monitoring their ground
water to test for the absence of certain classes of chemical wastes,
instead of testing for each individual chemical within a class.
For example, if a facility tests its ground water for halogens
and it finds none, then it would not have to test for each variety
of halogen listed in the regulations.
The proposed regulation appeared in the Federal Register
Oct. 1, 1984, at 49 PR 38786.
Analytical Report on Hethod 3030 - Acid Digestion of Oils, Greases
and Waxos
In response to Region V's comments (May 1984), we initiated
a task to examine EPA Hethod 3030 for its applicability to the
analysis of barium, lead, mercury, and selenium in waste oils
and to formulate any modifications necessary to produce satisfac-
tory analyses. -
The digestion of four waste oil samples by EPA Method 3030
gave very low recoveries for barium, lead, and mercury. Selenium
could not be determined in the digest due to severe interference
by sulfuric acid with the graphite furnace technique. The
initial heating step of Method 3030 produces a large quantity
of charred material which is not digested by the latter steps.
Barium is precipitated as barium sulfate. This accounts for
the absence of barium in the samples and lack of recovery. The
Method 3030 digestion procedure was judged to be unsuitable for
the determination of any of these metals. We recommend that
Method 3050 be used for the digestion of barium, lead, mercury,
and selenium.
Waate Analysis Plans Guidance Manual
Waste Analysis Plans Guidance Manual is intended to assist
both permit applicants and reviewera/writers in the preparation
and evaluation of waste analysis plans. The manual explains
the RCRA regulations that require a waste analysis plan and
provides a recommended approach, including checklists to ensure
completion of the plans. It presents sanple waste analysis
plans for various hazardous waste management scenarios.
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r-4 -
Although a waste analysis plan should demonstrate to EPA or
State-permitting officials that the facility operator knovs what
Information is needed to operate the facility properly and has
In place a program to gather the necessary Information, there is
no specific required format for the plan. However, the Manual
suggests that the plan be organited around the following four
questions! -
what are the specific wastes or types of wastes
that will be managed within each process? .
what are the specific waste parameters .that have
to be quantified in order to satisfy the data needs?
What are the waste-associated properties that are
of concern in ensuring safe and effective management
(e.g., Btu content, % water)? - .
*
Row will the necessary data be obtained. Including
a description of the sampling and analysis procedures "
and attendant quality control/quality assurance
procedures to be carried out by the permittee? .
'."*,
In addition to providing checklists to assure the completeness
Of the plan (and sample plans covering a variety of hazardous
waste management scenarios) the manual puts forth such concepts
as "boundary condition* and 'tolerance limits.11 "Boundary conditions'
gives the maximum and minimum values of waste properties which,
if exceeded, would alert the operator that the waste does not
meet its typical properties and requires further attention before
acceptance. "Tolerance limits" are those characteristics of a
waste or waste mixture that a waste management process can handle
while maintaining permit compliance. The manual also discusses
the selection of waste parameters, the need of periodic recharac-
terization of hazardous wastes, the performance of shipment
screening by offsite facility operators, and procedures for
waste sampling, analysis, and quality, assurance/quality control.
The manual, can be ordered fron the Government Printing Office
as document 155-000-00244-4, at a cost of S5.50. The address in
as followst
Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402
(202) 783-3238
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Reactivity evaluations for Solid Waste
In cooperation with the 0.3. Department of Transportation
and the United Nations Group of Experts on Explosives, the
Bureau of Minos has been conducting research on the development
of tests designed to determine whether a substance has explosive
properties. These tests are currently under consideration for
international standardization and are called the U.S. Gap Test
and the U.S. Internal Ignition Test. The Bureau of Mines has
proposed that these tests are suitable to determine the properties
described in 40 CPR 261.23 (a)(6) and (7) which defines a solid
waste as having the characteristics of reactivity if it has,
among others, any of the following properties!
(a)(6) Capable of detonation or explosive reaction if
subjected to a strong initiation source or if
heated under confinement.
(a)(7) Readily capable of detonation, explosive decomposi-
tion? or reaction at standard temperature; and
pressure.
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The methods were the subject of a single laboratory at the
Bureau of Mines Laboratory in Pittsburgh, PA, using waste
samples from processing waste treatment facilities. In addition,
a series of standard explosives were obtained and evaluated
for use in calibrating the teats.
A report summarizing the single laboratory evaluation should
be available for review early in 1985.
Symposium
A symposium on RCRA test methods and Quality Assurance is
being planned for July 24-26, 1985 in Washington, O.C.. Topics
to be included ares Organic and Inorganic Analytical Methods,
Hazardous Waste Identification Characteristics, Quality Assurance,
and Sampling. More Information will be included in our next issue,
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