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 ------- 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 ------- 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 ------- -2- 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* ------- -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 WH-563:TGrogan:cma:rm.263:382-2224:ll/9/83:Disk PBTGroganCMA 1 dmf :TGrogan: 11/10/83 :Correct ions 11/21/83:WH-563:Disk Grogan Correct ionsrBWeddle:382-4746:11/28/83:PBTGroganCMA ------- |