v>EPA
              United States
              Environmental Protection
              Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9472.03-83
               TITLE:
                      Analysis Requirements at Off-Site Storage Facilities
               APPROVAL DATE:  12/13/83

               EFFECTIVE DATE:   12/13/83

               ORIGINATING OFFICE:
               0 FINAL

               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    Di

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  SEPA
                                       vVasnmgion. OC 2W60
                                                        ..-. ~u.tr"-,
                       OSWER  Directive Initiation Request
                                                                                   9472.03-83
.Name of Contact Person
Skinner
tead Office - G OUST
O OEPR G OWPE
D OSW Q AA- OSWER
Ma,. Cooe - Branch
OSW
ieiepnone Numoer
Aosro.eo tor Review
Signature ot O'tice 0. rector Data
1
i
T.lls
      Waste  Analysis  Requirements at Off-Site Storage Facilities
Sui-nrr.ary ot Directive
      Where drummed wastes are  transferred  for storage to temporary holding facilities
      for more  than ten  days before shipment to final disposal facilities, they  are
      subject  tothe storage facility standards of  part 264.
        12/13/83 •
Kev  Words:
                  Waste Analysis,  Off-site  facilitv
Tvoe oi directive iManual. Policy O/recrtve. Announcement, etc.:

       Policy  Directive
                                                                   Status
                                                                     D Orah
                                                     i_i  New
                                                     i—i
Ooes- tnis Oirectwe Sup«rsede Pr«vious Oireciiveis,'   j  | Yes    X i
K Yes  to Either Question. What Jirective inumoe' ntlel
                                                      Does it Suoo'emen! Previous Oirectiveisi'
                                                                                         'es
Review P!an
      AA-OSWEfl
   Q OERR
   G OSW
                 Q OUST
                 Q OWPE
                 LJ Regions
G OECM
Q OGC
II
G
Ot^er .Soecr/y)
Tr.s Request Meets OSWER O'recnves Svstem Format
S.gr-ature of Lead 0".ce Directives Officer
                                                                                Date
Signature of OSWER Directives Officer
                                                                                Date

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MEMORANDUM

SUBJECT:  Waste Analysis Requirements at Off-Site •
          Storage Facilities

FROM:     John H. Skinner, Director
          Office of Solid Waste

TO:       Hazardous Waste Management Division Directors
          .Regions I-X


    On November 4, I met with representatives of Ashland Oil Co.
regarding waste analysis requirements at their off-site storage
facilities.  I would like to share the highlights of that discussion
with you, since it raised some generally applicable issues and
since Ashland facilities will be undergoing RCRA permit reviews
in a number of Regions.

    Ashland typically picks up drummed wastes generated by its
customers and transfers the drums for storage at temporary Ashland-
operated holding facilities before shipment to final disposal
facilities operated by other companies.  Ashland*s storage facilities
apparently hold these wastes for more than 10 days; therefore,
these facilities are subject to the storage facility standards
of Part 264.

     The focus of our meeting was the waste analysis requirements
of §264.13.  Ashland's representatives, briefly described their
waste analysis procedures, including:  initial submittal p-f
samples and profile sheets by generators; review and approval of
this information prior to initial acceptance of the waste streams?
annual resampling of the generator's waste streams; use of * manifest r'. "
and "fingerprint" analysis before acceptance of the wastes at      ,.
the final disposal facilities.

    The major question raised at the meeting was the requirement
of §264.13(c) that waste analysis plans at off-site facilities
"must also specify the procedures which will be used to inspect
and, if necessary, analyze each movement of hazardous waste
received at the facility to ensure that it matches the identity
of the waste designated on the accompanying manifest or shipping
paper".  Ashland was concerned that some Regional and State

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permit writers were interpreting this regulation to require
sampling and analysis of the contents of all, or a large number,
of drums received tor temporary storage.  They argued that this
was unnecessary and unreasonable, given their existing waste
analysis procedures, their intimate knowledge of the wastes
generated by their customers, the short duration of storage, and
their safety-oriented management practices (e.g., drums ara not
opened; drums which show evidence of stress ara not accepted).

     Some flexibility is allowed under $264.13(c), as to how many
drums must be inspected, and, if necessary, analyzed within each
movement.  The basic purpose of the waste analysis plan is to  .
ensure that the facility has "all the information which must be
known to treat, store, or dispose of the waste in accordance
with3 the P.C AA par nit standards ( ?264.13( a)).  Sampling and
analysis of incoming shipments ar« required "if necessary".
This depends on a soriaa of sita-apecific judgments which th«
parrait writer must make.  in making thaae judgments, the permit
writer should conaiderj

        the facility's agraesaonts with the generators} the generators1
        procedures for labeling, handling and manifesting vaatasf
        and the facility's control systems when wast* is received.

        the potential problems which may be posed due to the
        type and characteristics of the waste in relation to
        the storage process and the other waatas handled.

        the variability in waata characteristics and th«
        problams that raay pose,

        for intermediate storage, the procedures for "fingerprint
        analyses" at the ultimate disposal site, given the short     ,
        period of storage at the holding facility*
     -  the adequacy of visual inspections of labels on incoming
        drums to satisfy ths requirement of S2f4.1J(c).

     Because these are site-specific judgments, I did not provide
Ashland Oil an assessment of specific requirements at their
facilities.  I did indicate that there is flexibility inhereat
in the regulations but that permit writers must sppdy the regu-
lations to individual sites based oo these considerations*  -3*

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                               -3-
cc:  Regional Hazardous Waste Branch Chiefs
     Regional Permits Section Chiefs
     Jack Sweet, Ashland Oil
     Bill Hood, Ashland Oil
     Jack Lehman
     Bruce Weddle
     Eileen Claussen
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 dmf :TGrogan: 11/10/83 :Correct ions 11/21/83:WH-563:Disk Grogan
 Correct ionsrBWeddle:382-4746:11/28/83:PBTGroganCMA

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