SEPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
{5303P}
EPA 530-R-l 2-001
January 2013
http://www.epa.gov
Waste Analysis at Facilities that
Generate, Treat, Store, and Dispose
of Hazardous Wastes - DRAFT 2
A Guidance Manual
Storage
Generation/
Treatment
Land
Disposal
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
DISCLAIMER
This guidance represents EPA's current thinking on this topic. It does not create or confer
any rights for or on any person or operate to bind the public. You can use an alternative
approach if the approach satisfies the requirements of the applicable statutes and
regulations. If you want to discuss an alternative approach (you are not required to do so],
you may contact the EPA staff responsible for implementing this guidance. In addition,
please note that state hazardous waste programs may be more stringent and/or broader in
scope than the federal program. If you cannot identify the appropriate EPA staff, call the
number listed in the Acknowledgment.
ACKNOWLEDGMENT
This guidance document was developed by the U.S. Environmental Protection Agency's
Office of Resource Conservation and Recovery and was funded under EPA Contract No. EP-
W-10-056. For questions about the document, please contact the Work Group Chair: Gail
Hansen, 703-308-0463.hansen.gail@epa.gov.
EPA wishes to acknowledge and thank the following EPA and state representatives for
providing input into the guidance: Mary Andrews (OGC], Jim Aycock (EPA Region 7], Emily
Chow (OECA], Jace Cuje (ORD], Laura Dahlgren (Georgia], Darleen Groner (Missouri],
Vishnu Katari (OECA], Christopher Lambesis (EPA Region 5], Sharon Leitch (EPA Region 1],
Beth Lohman (Virginia], Maliha Nash (ORD], Liz McCarthy (EPA Region 1], Todd Ramaly
(EPA Region 5], Wray R. Rohrman (EPA Region 7], Tracey Sheppard (OGC], Jan Simmons
(Georgia], Steve Simoes (Vermont], Don J. Smith (NEIC], Amy Walden (Wisconsin], and
Stephen Yee (EPA Region 1].
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Table of Contents
Acronym List iv
Introduction 1
PART ONE: RCRA Waste Analysis - An Overview 1-1
1.0 What Waste Analysis Requirements Must You Meet? 1-1
1.1 Generator and TSDF Waste Analysis Requirements 1-3
1.1.1 Generator Waste Analysis Requirements 1-3
1.1.2 TSDF Waste Analysis Requirements 1-8
1.1.3 Transmitting Waste Analysis Information 1-12
1.2 How Can You Meet The Waste Analysis Requirements For Your Facility? 1-13
1.2.1 Sampling and Analysis for TSDFs 1-15
1.2.2 Acceptable Knowledge and TSDFs 1-18
1.2.3 Waste Analysis for Generators 1-22
PART TWO: Documenting and Conducting Waste Analysis 2-1
2.0 Developing a WAP and Conducting Waste Analysis 2-1
2.1 Content and Organization of the WAP 2-1
2.2 Facility Description 2-6
2.2.1 Description of Facility Processes and Activities 2-6
2.2.2 Identification/Classification of Hazardous Wastes Generated or Managed at Your
Treatment, Storage and Disposal Facility 2-7
2.2.3 Description of Hazardous Waste Management Units 2-8
2.3 Systematic Planning 2-10
2.4 Selecting Waste Analysis Parameters 2-15
2.4.1 Criteria for Parameter Selection 2-16
2.4.2 Parameter Selection Process 2-20
2.4.3 Rationale for Parameter Selection 2-22
2.4.4 Special Parameter Selection Requirements 2-22
2.5 Selecting Sampling Procedures 2-26
2.5.1 Sampling Strategies and Sampling Frequencies 2-27
2.5.2 Selecting Sample Equipment 2-34
2.5.3 Maintaining and Decontaminating Field Equipment 2-39
2.5.4 Sample Preservation and Storage 2-41
2.5.5 Establishing Quality Assurance/Quality Control Procedures 2-41
2.5.6 Establishing Health and Safety Protocols 2-44
2.6 Selecting a Laboratory and Laboratory Analytical Methods 2-46
2.6.1 Selecting a Laboratory 2-46
2.6.2 Selecting Laboratory Analytical Methods 2-50
2.7 Quantifying Data Uncertainty 2-53
Table of Contents
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.8 Determining Re-Evaluation Frequencies 2-56
2.9 Special Procedural Requirements 2-58
2.9.1 Procedures for Receiving Wastes Generated Off-Site 2-59
2.9.2 Procedures for Combustion Facilities 2-61
2.9.3 Procedures for Ignitable, Reactive, and Incompatible Waste 2-64
2.9.4 Procedures for Complying with LDR Requirements 2-65
2.10 Discrepancy Policy 2-65
2.10.1 Manifest Discrepancies 2-66
2.10.2 Discrepancies Between Incoming Waste and Profile 2-67
2.11 Rejection Policy 2-68
2.12 Recordkeeping 2-68
2.13 Corrective and Preventative Action Measures 2-70
PART THREE: Checklist 3-1
PART FOUR: Sample WAPs 4-1
Example WAP 1: Waste Analysis Plan for ACE Chemical Services 4-2
Example WAP 2: Waste Analysis Plan of Container Management Incorporated (CMI) 4-33
APPENDICES
APPENDIX A: Hazardous Waste Identification A-l
APPENDIX B: Regulatory Summary B-l
APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-l
APPENDIX D: Overview of Major Hazardous Waste Management Units D-l
APPENDIX E: Glossary of Terms E-l
APPENDIX F: Key Considerations and Tips F-l
APPENDIX G: References G-l
Table of Contents
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
List of Tables
TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs 2-4
TABLE 2-2: Description of Listed Wastes 2-7
TABLE 2-3: Description of Characteristic Waste 2-8
TABLE 2-4: Sampling Approach Overview 2-29
TABLE 2-5: Major Sample Types 2-31
TABLE 2-6: Applicability of Sampling Equipment to Wastestreams 2-40
TABLE 2-7: Laboratory QC Techniques 2-48
TABLE 2-8: Important QA Elements 2-49
TABLE 2-9: Re-Evaluation Frequencies 2-58
List of Figures
FIGURE 1-1: Summary of Generator Analytical Requirements 1-5
FIGURE 1-2: Analytical Requirements for LQGs under Subparts AA, BB,
andCCof40CFRPart265 1-6
FIGURE 1-3: Summary of TSDF Analytical Requirements 1-11
FIGURE 1-4: Waste Analysis Data Flow 1-13
FIGURE 1-5: Waste Analysis Quality-Conceptual Model 1-15
FIGURE 2-1: The Seven Steps of the DQO Process 2-10
FIGURE 2-2: Waste Analysis Parameter Selection Process 2-21
FIGURE 2-3: Illustration of Simple Random, Stratified Random and
Systematic Random Sampling 2-30
FIGURE 2-4: Samplers for Liquid Wastestreams 2-37
FIGURE 2-5: Samplers for Solid Wastestreams 2-38
FIGURE 2-6: Example Chain-of-Custody Record 2-45
FIGURE 2-7: Analytical Methods Selection Flowchart 2-52
FIGURE 2-8: Shipment Screening 2-60
FIGURE 2-9: Example Waste Profile Sheet 2-72
Table of Contents
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Acronym List
AA Atomic Absorption
AES Atomic Emission Spectroscopy
AK Acceptable Knowledge
ASTM American Society for Testing
and Materials
BIF Boiler and Industrial Furnace
BTU British Thermal Units
CAA Clean Air Act
CESQG Conditionally Exempt Small
Quantity Generators
CFR Code of Federal Regulations
CWA Clean Water Act
DOT Department of Transportation
DQO Data Quality Objectives
EPA Environmental Protection Agency
FAP Feedstream Analysis Plan
FR Federal Register
GC Gas Chromatography
HC1 Hydrochloric Acid
^L
H&S Health and Safety
HW Hazardous Waste
HWC Hazardous Waste Combustors
ICP Inductively Coupled Plasma
LDR Land Disposal Restrictions
LQG Large Quantity Generator
LQM Laboratory Quality Manual
LWAK Light Weight Aggregate Kiln
MACT Maximum Achievable Control
Technology
MDP Method-Defined Parameter
mg/L milligrams per liter
MIR Methods Innovation Rule
MS Mass Spectrometer
NELAP National Environmental
Laboratory Accreditation
Program
NIOSH National Institute for
Occupational Safety and Health
NTIS National Technical Information
Service
NSCEP National Service Center for
Environmental Publications
NWW Non-Wastewater
OSHA Occupational Safety and Health
Administration
PCB Polychlorinated Biphenyls
POHC Principle Organic Hazardous
Constituent
ppm parts per million
QA Quality Assurance
QC Quality Control
RCRA Resource Conservation and
Recovery Act
SDS Safety Data Sheet
SOP Standard Operating Procedure
SQG Small Quantity Generator
TC Toxicity Characteristic
TCLP Toxicity Characteristic Leaching
Procedure
TSDF Treatment, Storage, or Disposal
Facility
UHC Underlying Hazardous
Constituent
WAP Waste Analysis Plan
WPS Waste Profile Sheet
WW Wastewater
Acronym List
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Introduction
The purpose of this guidance manual is to discuss how a person can perform waste
analyses and develop waste analysis plans (WAPs} in accordance with the federal
hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA], as
amended. The federal hazardous waste regulations are codified at 40 CFR Parts 260
through 279. The primary audiences for this manual are hazardous waste generators and
owner/operators of treatment, storage, and disposal facilities (TSDFs). This manual can
also provide guidance in the development of used oil processor or re-refiner analysis
plans under 40 CFR Part 279. In addition, the manual can be helpful to federal and state
permit writers in evaluating WAPs and enforcement personnel in determining whether a
facility is in compliance with its WAP. Note: In discussing the WAP, this manual
presents federal hazardous waste requirements. Because state hazardous waste
programs may be more stringent and/or broader in scope than the federal
program, you need to consult your state's regulations to learn the requirements
that apply to you.
This manual achieves the following objectives:
Part One
Explains the general requirements in the federal hazardous waste regulations for
developing a WAP and/or conducting waste analysis.
Part Two
Presents general and facility-specific guidance on the procedures for developing a
useful WAP and conducting waste analysis.
Part Three
Provides a checklist to assist you in conducting waste analysis and preparing a WAP.
Part Four
Offers facility-specific WAP examples.
The previous edition of this manual was issued in 1994.1 This current edition includes
important updates and a greater focus on issues of particular importance to waste analyses.
For example, it includes an expanded discussion in Part Two on how to integrate Data
Quality Objectives into sampling/analysis activities. It also includes new WAP examples in
Part Four. These examples are meant only as a learning tool; they are not complete as
presented herein. This manual also includes information on some changes to the federal
1 The 1994 edition can be found at: http://www.epa.gov/epawaste/hazard/tsd/ldr/wap330.pdf.
Introduction
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
RCRA program concerning waste analyses that were introduced since the last manual was
published (e.g., new regulations}. The following is a list of these program changes:
Definition of solid waste final rule.
Alternative requirements for laboratories owned by eligible academic entities.
Conditional exemptions for military munitions.
Conditional exemptions for low-level mixed waste storage, treatment, transportation,
and disposal.
Organic air emission standards for tanks, containers and surface impoundments [40
CFR Part 264 and 265, Subpart CC]
Amendments to the Land Disposal Restrictions (LDR) regulations, including the Phase II
- IV rules
Revisions and updates to the "Test Methods for Evaluating Solid Waste, Physical/
Chemical Methods" (SW-846] and issuance of the Methods Innovation Rule (MIR}.
The above referenced program changes are summarized in Appendix B of this manual.
Refer to Appendix E for a glossary of terms.
Introduction
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
PART ONE:
RCRA Waste Analysis - An Overview
1.0 What Waste Analysis Requirements Must You Meet?
The cornerstone of the RCRA hazardous waste program is the requirement of generators and
owner/operators of treatment, storage and disposal facilities (TSDFs} to properly identify
and characterize, through waste testing and/or knowledge, all hazardous wastes that are
generated, treated, stored, or disposed of at their site or facility.2 Waste testing involves
identifying and verifying the chemical and physical characteristics and composition of a
waste by performing a detailed chemical and physical analysis of a representative sample of
the waste. In certain cases, a facility may apply knowledge of the waste in lieu of testing the
waste. Proper waste analysis is needed to:
Determine whether your waste is a RCRA hazardous waste under applicable federal and
state requirements (which can be more stringent and/or broader in scope than the
federal program}.
Classify the waste according to RCRA.
Ensure that the waste is managed properly.
Ensure you are complying with permitted
feedrate or other numerical limitations (e.g.,
metal feedrates] at your facility if applicable.
Waste analysis, therefore, is the pivotal activity for
properly ensuring that your facility (and any
subsequent handlers] complies with the applicable
regulations for proper waste treatment, storage,
or disposal.
The majority of RCRA's waste analysis
requirements apply to hazardous waste generators
and TSDFs. The RCRA generator standards apply to
large quantity generators (LQGs} and small
quantity generators (SQGs}.3 Briefly, LQGs and
SQGs are required to:
General References on the RCRA Program
EPA regulations (Title 40)
http://www.gpo.gov/fdsys/
RCRA Orientation Manual
http://www.epa.gov/epawaste/inforeso
urces/pubs/orientat/
RCRA Online (database)
http://www.epa.gov/epawaste/
inforesources/online/index.htm
1 RCRA Training Modules
http://www.epa.gov/epawaste/inforeso
urces/pubs/rmods.htm
1 Envirofacts (database)
http://www.epa.gov/enviro/index.html
RCRAInfo (database)
http://www.epa.gov/enviro/facts/
rcrainfo/search.html
This manual presents federal hazardous waste requirements. Because state hazardous waste programs may be
more stringent and/or broader in scope than the federal program, you need to consult your state's regulations to
learn the requirements that apply to you.
Conditionally exempt small quantity generators (CESQGs) are subject to 40 CFR 261.5 and also must make
hazardous waste determinations (261.5(g)(l)).
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Determine if they have generated a hazardous waste (see Parts 261 and 262};4
Determine if the hazardous waste is "prohibited" from land disposal under the Land
Disposal Restrictions (LDR} program (see Part 268}. A prohibited waste is a waste that
does not meet its applicable LDR treatment standards at its point of generation and
cannot be land disposed of until it meets those standards. If they have a prohibited
waste, they must either treat it on-site to meet the standards, or send it to an off-site
treater or recycler along with the required paperwork. A waste analysis plan (WAP] is
required for generator on-site treatment to meet LDR treatment levels;
Manage the hazardous wastes in accordance with the applicable Part 262 and 268
requirements (e.g., accumulate the hazardous wastes only in tanks or containers that
meet specified standards, perform periodic inspections}; and
Comply with Part 262 and 268 recordkeeping and reporting requirements (e.g., retain
waste analysis data}.
The requirements for permitted and interim-status TSDFs can be found primarily in 40
CFR Parts 264 through 268 and 270. Concerning waste analysis, §§264/ 265.13 require a
TSDFto:
Properly characterize hazardous wastes before managing them and repeat these
analyses as specified (pre-acceptance};
Inspect incoming shipments that are received at TSDFs from off-site sources for
hazardous waste management; and
Prepare and follow a WAP that adequately describes the methods, procedures and
equipment that will be used to perform these analytical requirements.
In addition, the TSDF may be subject to analytical requirements elsewhere in the
regulations, depending on the waste management activities that it performs (e.g., LDR
treatment, storage of organic waste in containers, feedstream analysis for hazardous waste
combustors and thermal treatment units}. The WAP must specify the methods that will be
used to meet these other analytical requirements (e.g., see 264/265.13(b}(6}}.
For additional information on these topics, refer to the references identified in this
section. In addition, Envirofacts and RCRAInfo can be used to learn about the RCRA-
regulated universe (e.g., generators and TSDFs} and the types and quantities of hazardous
wastes generated and managed by them.
Unless otherwise specified, "Part" or "Parts" herein are references to parts of Title 40 of the Code of Federal
Regulations.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
1.1 Generator and TSDF Waste Analysis Requirements
Following is a summary of some of the analytical and related requirements that apply to
generators and TSDFs. See Appendix C of this manual for more detailed information,
including the regulatory references, of many of the RCRA waste analysis requirements, to
which generators and TSDFs are subject.
1.1.1 Generator Waste Analysis Requirements
Persons who generate a solid waste are obligated under §262.11 determine if their wastes
are hazardous. Also if they intend to send the hazardous waste to a TSDF, the generator
may be required to provide waste-related information to the TSDF. The TSDF's WAP will
specify what information is required. A generator is required to prepare a WAP only if
he is managing and treating waste or contaminated soil in tanks, containers, or
containment buildings regulated under 40 CFR 262.34 to meet applicable LDR
treatment standards. Figures 1-1 and 1-2 provide an overview of RCRA waste analysis
and WAP requirements that apply to generators.
As a generator, you must determine if the waste generated is a RCRA hazardous waste, as
required by §262.11, by:
First determining if your waste is excluded from
regulation (see the solid and hazardous waste
exclusions at§261.4(a] and (b}};
Then determining if it is listed as a hazardous waste in
Applicability of WAPs to
Generators
A generator is not required to
c- i 4. T-V j7/ir»/-T-nn ^~>f\ j prepare a WAP except when
Subpart D of 40 CFR Part 261; and
For purposes of compliance with LDR Program in Part
268, or if the waste is not listed in Subpart D of Part 261,
determining whether the waste exhibits any of the treatment standards found at
, , &, . . .. . c , .r fn .:,.,., v §268.40. See §268.7(a)(5) for this
hazardous characteristics in Subpart C of Part 261. You
r requirement.
may test the waste or use knowledge to make the
managing and treating waste or
contaminated soil in qualified
units to meet applicable LDR
determination. (See Section 1.2.2 for a discussion of
some of the types of information that EPA would consider "acceptable" knowledge.} See
Appendix A for additional information on hazardous waste identification procedures.
If you have generated a hazardous waste, you must quantify the hazardous waste that
you generated during that month, as required by 40 CFR §§261.5 and 262.34. You then
must determine whether you are a SQG, LQG, or conditionally exempt small quantity
generator (CESQG}:
SQGs (generators of > 100 kg/month and < 1,000 kg/month of hazardous waste] are
subject to regulation under Part 262 and other applicable parts (e.g., Part 268}.
LQGs (generators of > 1,000 kg/month of hazardous waste] are subject to regulation
under Part 262 and other applicable parts (e.g., Part 268}.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
CESQGs (generators of < 100 kg/month of hazardous waste] are subject to limited
requirements as specified in §261.5 (e.g., hazardous waste determinations, monthly
counting}. They are not subject to waste analysis other than hazardous waste
determinations at §261.5(g](l}.
If you are a LQG or SQG, you must determine if your hazardous waste must be treated to
meet the LDR treatment standards before being land disposed, as required in §262.11 and
Part 268. You must determine each EPA hazardous waste code that applies to your
hazardous waste, which allows you to determine the applicable treatment standards under
the LDR program. You must refer to the treatment standards in 40 CFR §§268.40, 268.45,
and/or 268.49 to determine if your waste "as generated" must be treated. This determination
can be made concurrently with the hazardous waste determination described above. You can
either test the waste or use knowledge of the waste. Alternatively, you can send the waste to
a hazardous waste treatment facility subject to a RCRA permit, where the facility can make
the LDR determinations in accordance with 40 CFR §§264.13, 265.13, and 268.7(b}.
If the hazardous waste does not meet the treatment standards, it must be treated before
being land disposed. Some wastes must be treated by a particular treatment method before
land disposal while other wastes are subject to concentration-based treatment standards.
In addition, if you are a LQG, you must comply with the organic air emission standards in
Subparts AA, BB, and CC of Part 265, including waste analysis. For example, these subparts
require LQGs to test their waste or use knowledge of the waste to determine if the
requirements apply to their units.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
FIGURE 1-1: Summary of Generator Analytical Requirements
Generator of Hazardous
Wasteb
Test or use knowledge to determine if the
waste you generate is RCRA hazardous waste
(262.11)
Hazardous
Based on your hazardous waste quantity
generated during the month, do you qualify as
either a SQG or LQG? (261.5 and 262.34)c
.
Yes
Test or use knowledge to determine if your
hazardous waste meets all applicable LDR
treatment standards before land disposal
(268.7)e
Fails treatment
standards
Treat the waste to meet treatment standards
before land disposal. You can either treat on-
sitein qualified tanks, containers or
containment buildings or ship for off-site
treatment
Ship off-site
Ship the waste to treatment facility with
required LDR notice (268.7)
Non-
Hazardous
No further analytical (or other)
RCRA requirements apply
No
No further analytical requirements
apply11
Meets
treatment
standards
Ship waste to disposerwith
required LDR notice and
certification (268.7)
Treat
on-site
If you treat on-site in tanks,
containers, or containment buildings
to meet LDR standards, prepare and
follow a WAP (268.7(a)(5))
Ship wastes meeting treatment
standards to disposerwith required
LDR notice/certification (268.7), or if a
characteristic waste is rendered non-
hazardous, prepare/file the
notice/certification (268.9)
Footnotes
a. This figure presents federal RCRA hazardous waste requirements. You should consult your state's
regulations to learn the requirements that apply to you. This figure does not necessarily identify all
analytical requirements to which a generator may be subject. See Figure 1-2 for additional analysis
requirements for LQGs.
b. A "generator" is any person, by site, whose act or process produces hazardous waste or whose act
first causes a hazardous waste to become subject to regulation.
c. 40 CFR 261.5 and 262.34 establish standards for making waste quantity determinations and
determining generator status. Small quantity generators (SQGs) and large quantity generators (LQGs)
must comply with applicable generator standards in Part 262 and Part 268, including the waste
analysis requirements described in this figure.
d. If you are a conditionally exempt small quantity generator (CESQG), you must comply with the
requirements in section 261.5; however, no additional waste analysis is required.
e. This determination is usually made concurrently with the hazardous waste determination.
Alternatively, the generator can send the waste to a treater to make the LDR determinations.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
FIGURE 1-2: Analytical Requirements for LQGs under Subparts AA, BB, and CC
of 40 CFR Part 265 a
Large Quantity Generator
(LQG)b
-
An LOG must control organic air emissions from process vents under Subpart
AA of Part 265 if:
Its unit is one of the following types: distillation, fractionation, thin-film
evaporation, solvent extraction, air or steam stripping; and
The unit manages hazardous waste with total organic concentrations of >10
parts per million by weight (ppmw).
See 265.1034 fortest methods and procedures.
An LOG must control organic air emissions from "equipment" leaks under
Subpart BB of Part 265 if the equipment comes into contact with hazardous
waste with an organic concentration of > 10% by weight. "Equipment"
includes pumps, valves, lines, compressors, pressure release devices,
sampling connections, etc.
See 265.1063 fortest methods and procedures.
An LOG must control organic air emissions under Subpart CC of Part 265 if:
It manages hazardous waste in containers or tanks; and
The hazardous waste managed in the unit has an average volatile organic
concentration of > 500 ppmw at the point of generation.
See 265.1084 for waste determination procedures.
Footnotes
This figure presents federal RCRA hazardous waste requirements for large quantity generators (LQGs)
under the organic air emission standards. You should consult your state's regulations to learn the
requirements that apply to you. See Figure 1-1 for additional waste analysis requirements for generators.
40 CFR 261.5 and 262.34 establish standards for making waste quantity determinations and determining
generator status. Small quantity generators (SQGs)and large quantity generators (LQGs) must comply
with applicable generator standards in Part 262 and Part 268. Section 262.34(a) requires LQGs to comply
with Subparts AA, BB and CC of Part 265, among other things. Each subpart also includes applicability
criteria.
a.
b.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
1.1.1.1 LDRs: UHCs
If you determine that your waste exhibits a
hazardous waste characteristic, you must also
determine whether the hazardous waste contains
underlying hazardous constituents (UHCs) (there
are no UHCs for listed waste}. A UHC is any
constituent listed in 40 CFR §268.48, Table UTS-
Universal Treatment Standards, except fluoride,
selenium, sulfides, vanadium, and zinc, which can
reasonably be expected to be present at the point
of generation of the hazardous waste at a
concentration above the constituent-specific UTS
treatment standards (§268.2}. To determine
whether you need to be concerned about UHCs in
your waste, go to the Table -- Treatment Standards
for Hazardous Wastes in §268.40. The table shows,
for example, that a D001 non-wastewater exhibiting
the ignitability characteristic, except for High TOC
subcategory, has a treatment standard expressed as
"DEACT and meet §268.48 standards; or RORGs; or
CMBST." This means that, if you choose to treat it
using deactivation, you (or the treater receiving
your hazardous waste} must determine what the
UHCs are in your hazardous waste. Then, you can go
to the UTS table in 40 CFR §268.48, which lists the
UHCs and their respective treatment standards
expressed as a concentration. The waste must be
treated to both eliminate the characteristic^} and meet the UTS treatment standards, as
indicated in the UTS table. Compliance with the treatment standards in the UTS table is
measured by an analysis of grab samples, unless otherwise noted in the table.
1.1.1.2 LDRs: WAP Requirement
If you are a generator managing and treating prohibited waste or contaminated soil in
tanks, containers, or containment buildings regulated under 40 CFR §262.34 to meet
applicable LDR treatment standards, you must prepare and follow a WAP [40 CFR
268.7(a}(5}]. The WAP must describe the procedures you will carry out to comply with the
treatment standards. (Generators treating hazardous debris under the alternative
treatment standards of Table 1, 40 CFR §268.45, however, are not subject to these waste
analysis requirements.} The plan must be kept on-site in your records for review by
inspectors, and the following requirements must be met:
The WAP must be based on a detailed chemical and physical analysis of a
representative sample of the prohibited waste(s} being treated, and contain all
Applicability of UHCs to
Treatment Residuals
Generators of characteristic hazardous
wastes are required to identify any and all
underlying hazardous constituents
reasonably expected to be present above
their concentration-based levels (see
Table in 268.48) at the point of
generation. Thus, metal constituents that
did not qualify as UHCs in the original
waste are concentrated to above UTS
levels during treatment, treaters are not
expressly required to further treat the
residuals such that those metal
constituents meet UTS levels. If, however,
the residual exhibits a characteristic due
to a new property (e.g., concentrated
metals now exceed one or more of the
constituent-specific Toxicity Characteristic
thresholds), residuals exiting the
treatment unit would be considered a
new point of generation, the treater
would be considered to be the
generator,and the full suite of UHCs must
be reconsidered and identified, as
appropriate. See 64 FR 25411 (May 11,
1999) for additional clarification.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
information necessary to treat the waste(s} in accordance with the requirements of Part
268, including the minimum selected testing frequency.
Wastes shipped off-site must comply with the notification requirements of 40 CFR
§268.7(a)(3).
1.1.2 TSDF Waste Analysis Requirements
As a TSDF, you must comply with the applicable §264.13 and/or 265.13 requirements for
waste analysis and WAPs. Part 264 generally covers the requirements for permitted
facilities/regulated units, wheras Part 265 covers the interim status facilites/units. Figure
1-3 provides an overview of these requirements. The figure identifies the requirement for a
WAP at 264.13 and 265.13 as well as the analytical requirements, found elsewhere in the
RCRA regulations that must be addressed in the WAP (e.g., the Part 268 requirements for
treaters and disposers to test treated waste for LDR compliance}.5
The TSDF may use generator-supplied information to aid in its understanding of the waste
it receives and manages. However, the TSDF is ultimately responsible for understanding its
wastes to ensure compliance with its permit/regulations and manage the wastes in a safe
and protective manner. If the TSDF relies on generator-supplied information, it is
important to review and verify this information to ensure its adequacy (e.g., by performing
fingerprint analyses to determine if a shipment matches the manifest}.
TSDF Analytical Responsibilities
40 CFR §§264/265.13(a} establish two broad analytical responsibilities that you as a TSDF
must perform at a minimum:
Pre-acceptance. Before you can treat, store, or dispose of hazardous candidate waste,
you must obtain a detailed chemical and physical analysis of a representative sample
of the waste. At a minimum, the analysis must contain all the information, which must
be known to properly treat, store, or dispose of the waste in accordance with 40 CFR
Part 264 or 265 and the LDR program. The analysis may include information
developed under 40 CFR Part 261, and existing published or documented data on the
hazardous waste or on hazardous waste generated from similar processes. For
example, studies conducted on hazardous waste generated from similar processes as
the waste to be managed at the facility may be included in the analysis, as specified.
The owner or operator of an off-site facility may arrange for the generator of the
hazardous waste to supply part of the information required, except as otherwise
specified in 40 CFR §§268.7(b} and (c}. If the generator does not supply the
information or supplies incomplete or inadequate information, and the owner
or operator chooses to accept a hazardous waste, the owner or operator is
responsible for obtaining the information required for compliance.
5 The figure does not address all analytical requirements that may potentially apply to a TSDF.
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The analysis must be repeated as necessary to ensure that it is accurate and up to date.
As with the initial analysis, the owner or operator of an off-site TSDF may arrange for
the generator of the hazardous waste to supply part of the information required. At a
minimum, the analysis must be repeated:
When the owner or operator is notified, or has reason to believe, that the process or
operation generating the hazardous wastes, or non-hazardous wastes if applicable
under 40 CFR §264/265.113(d], has changed; and
For off-site facilities, when the evaluation of incoming shipments, described below,
indicates that the waste received at the facility does not match the waste designated
on the accompanying manifest or shipping paper.
Waste acceptance. If you are the owner or operator of an off-site facility, you must
inspect and, if necessary, analyze each hazardous waste shipment received at the
facility to determine whether it matches the identity of the waste specified on the
accompanying manifest or shipping paper.
Contents of WAP
40 CFR §§264/265.13(b] and (c] spell out the information that must be included in your
WAP in order to perform the analyses described in the text above as well as other analyses
that may be needed at your facility:
The parameters for which each hazardous waste, or non-hazardous waste if applicable
under 40 CFR §§264/265.113(d], will be analyzed and the rationale for the selection of
these parameters (i.e., how analysis of these parameters will provide sufficient
information of the waste's properties as specified}.
The test methods that will be used to test/analyze these parameters.
The sampling method that will be used to obtain a representative sample of the waste
to be analyzed. A representative sample may be obtained using either:
Appropriate sampling method in Appendix I of 40 CFR Part 261 for the waste; or
An equivalent sampling method.
The minimum frequency with which the initial analysis of the waste will be reviewed or
repeated to ensure that the analysis is accurate, up to date, and representative of the
waste over time.
For off-site facilities, the waste analyses that hazardous waste generators have agreed
to supply.
For permitted TSDFs and activities, where applicable: the methods that will be used to
meet the additional waste analysis requirements for specific waste management
methods as specified in 40 CFR §§264.17, 264.314, 264.341, 264.1034(d], 264.1063(d],
264.1083, and 268.7. (See Figure 1-3.}
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For interim-status TSDFs and activities, where applicable: the methods that will be used
to meet the additional waste analysis requirements for specific waste management
methods as specified in 40 CFR §§265.200, 265.225, 265.252, 265.273, 265.314,
265.341, 265.375, 265.402, 265.1034(d], 265.1063(d], 265.1084, and 268.7. (See
Figure 1-3.}
For surface impoundments exempted from land disposal restrictions under 40 CFR
§268.4(a], the procedures and schedules described in 40 CFR §264/265.13(b}(7}.
For owners and operators seeking an exemption to the air emission standards of
Subpart CC in accordance with 40 CFR §264.1082 or 265.1083, the information
specified in 40 CFR §§264/265.13(b}(8}.
For off-site facilities, the procedures that 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. At a minimum, the plan must describe:
The procedures that will be used to determine the identity of each waste managed
at the facility.
The sampling method that will be used to obtain a representative sample of the
waste to be identified, if the identification method includes sampling.
The procedures that the owner or operator of an off-site landfill receiving containerized
hazardous waste will use to determine whether a hazardous waste generator or treater
has added a biodegradable sorbentto the waste container.
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FIGURE 1-3: Summary of TSDF Analytical Requirements'
TSDFs
Comply with 264.13 and 265.13 requirements for
waste analysis and preparing /following a WAP
(see text for additional information)
In addition to the above, the following WAP requirements apply to
specific types of facilitiesb
For hazardous waste landfills:
tests to demonstrate absence or presence of free liquids in bulk or containerized liquids;c
tests to determine if sorbent added to container free liquids is non-biodegradable (264.314
and 265.314)°
For hazardous waste combustors, analysis of waste feed for trial burn and throughout normal
operation (40 CFR Parts 264/265 Subpart O, Part 266 Subpart H, Part 270 Subpart F, and
Part 63 Subpart EEE))
For process vents associated with distillation, fractionation ,or other operation as specifiedd,
direct measurement or knowledge to support an exemption from Part 264 or 265, Subpart
AA, if applicable (264.1034(d) and 265.1034(d))b
For compressors, pumps, and other equipment as specifiede, tests or knowledge to support
an exemption from Part 264 or 265, Subpart BB, if applicable (264.1063(d) and
265.1063(d))b
For containers, tanks, and surface impoundments, direct measurement or knowledge to
support an exemption from Part 264 or 265, Subpart CC' (264.1083 and 265.1084)b
Fortreaters and disposers of LDR-restricted waste, tests to assure that the treated waste
meets the applicable treatment standards (268.7)c
Permitted TSDFs only
5»
Document compliance with applicable requirements to take precautions for ignitable, reactive
or incompatible waste activities(264.17)
Interim-Status TSDFs/UnitsOnly
For tank, surface impoundment, waste pile, thermal treatment, or chemical, physical or
biological treatment that is used fora new/different purpose as specified , test or use
knowledge for purposes of trial test (265.200,265.225,265.252,265.375,265.402)
For land treatment, determine the concentrations of substances and constituents of waste
before placing it in the unit (265.273)
Footnotes
This figure presents federal RCRA hazardous waste requirements. You should consult your state's regulations to learn
the requirements that apply to you. This figure does not address all analytical requirements that may potentially apply
to a TSDF. It only addresses the §264.13 and 265.13 requirement for a WAP, the analytical requirements identified in
§264.13(b)(6)and 265.13(b)(6), and combustor requirements (e.g., Part 266).
LQGsalso are subject to Part 265, Subparts AA, BB and CC, as specified.
Testing (and not knowledge) is required or specified in the regulations. See §268.7(b)(1 )-(2) and 268.7(c)(2).
Distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations that manage
hazardous waste with organic concentrations > 10ppmware subject to Part 264 or 265, Subpart AA.
Compressors, pumps, and other equipment as specified that contain or contact hazardous waste with organic
concentration > 10% by weight may be subject to Subpart BB. Consult 40 CFR §254/265 for exemptions to and other
information regarding Subpart BB.
Subpart CC applies to containers, tanks and surface impoundments with waste having an average volatile organic
(VO) concentration at the point of waste origination of > 500 parts ppmw.
a.
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1.1.3 Transmitting Waste Analysis Information
In addition to conducting waste analyses and developing/following a WAP, a generator (or
owner/operator of a TSDF making an offsite shipment] must provide waste analysis
information to the TSDF that subsequently receives the waste, as specified [40 CFR §268.7].
For example, if you are:
A generator of a hazardous waste who sends waste
off-site for treatment, storage, or disposal, you must
provide to the TSDF the waste analysis information,
the applicable RCRA codes, and the applicable LDR
treatment standards. It is recommended that the
generator also provide the TSDF with a description of
the process that generated the waste. The
information will help ensure, among other things,
that your waste can be accepted according to the
facility permit. [See 40 CFR §264/265.13(a] and
§268.7(a}] Refer to the Generator Paperwork
Requirements Table at §268.7(a] to see the
information required on LDR notifications
and certifications.
Adding Waste Codes to an LDR
Notification (§268.7(a))
An Example
A waste stream, KO62, is listed due to
corrosivity, hexavalent chromium and
lead. The LDR treatment standard for
K062 only includes treatment for
metals. If the K062 waste stream is
actually corrosive, the LDR notification
form will need to include the waste
codes K062 and D002 so the
treatment facility knows to treat the
waste for corrosivity.
An owner/operator of a treatment facility, you must provide waste analysis
information (including any information supplied by the generator, as well as waste
analysis data developed by your facility before and after treatment] to any off-site
storage or disposal facility receiving the waste to ensure that the waste is managed in
compliance with LDR requirements and their permit. [See 40 CFR §264.13(a] and
§268.7(b}] Refer to the Treatment Facility Paperwork Requirements Table at §268.7(b]
to see the information required on LDR notifications and certifications.
Please be aware that generators and TSDFs are
required to transmit waste-related information to
facilities receiving their wastes under the manifest
and LDR programs. A helpful summary of
information-sharing requirements under the LDR
program can be found in the "Generator Paperwork
Requirements Table" [40 CFR §268.7(a}] and
"Treatment Facility Paperwork Requirements
Table" [40 CFR §268.7(b}].
In addition to generators and TSDFs, waste
transporters and waste transfer facilities also have
hazardous waste-related responsibilities, as specified in Part 263. These facilities are
generally not required to conduct waste analyses. However, to ensure safe handling,
transporters and transfer facility owner/operators need to know the identity of the wastes
they are handling. They generally rely on the information provided by the generator or the
Information-Sharing under Manifest
and LDR Programs
Manifest Program
For generators, refer to Subpart B of
40 CFR Part 262
For TSDFs, refer to Subpart E of 40
CFR Part 264 or Part 265
LDR Program
For generators, treaters, and
disposers, refer to 40 CFR 268.7
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TSDF offering the waste for transport as presented on the hazardous waste manifest.
Therefore, the accuracy and completeness of the waste analysis performed by the
generators and TSDFs is critical to them and to the many individuals (e.g., subsequent
transporters, emergency response personnel] who may encounter these materials while
they are in transit.
Figure 1-4 depicts the transfer of waste analysis information that needs to occur among
facilities that are shipping and receiving waste. It is advantageous for all facilities involved
to provide detailed waste analysis information with each shipment of a waste stream, and
for the receiving facility to verify, through waste analysis, the information that the
generator or sender of the waste provided. By following these steps, there is an increased
likelihood that the waste will be treated, stored, or disposed of properly and a reduced
chance of accidents, releases, and mismanagement.
FIGURE 1-4: Waste Analysis Data Flow
Transfer
Generator
Treatment
L t
Storage
Disposal
1.2 How Can You Meet The Waste Analysis Requirements For
Your Facility?
You can meet general and specific waste analysis requirements using several approaches
or combinations of methods. Meeting waste analysis requirements by performing waste
sampling and laboratory analysis typically is more accurate, precise, and defensible than
other options. (The procedures and equipment for both obtaining and analyzing samples
are discussed in Part Two of this manual. In addition, see Appendix I of 40 CFR Part 261 for
sampling methods.} Section 1.2.1 addresses sampling and analysis.
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Waste analysis information can be acquired by either collecting samples and conducting
laboratory analysis or using published data and generator knowledge of the waste
generating process (known as acceptable knowledge, generator knowledge or process
knowledge}. Acceptable knowledge can include, but is not limited to:6
Process knowledge, whereby detailed information on the wastes is obtained from
existing published or documented waste analysis data or studies conducted on
hazardous wastes generated by processes similar to that which generated the waste
(process knowledge is supported with technical data};
Data from analysis or testing performed by the generator; or
In cases of newly listed wastes, data from recent waste analyses performed prior to the
effective date of the listings.
Generators may use any of these in making hazardous waste determinations. TSDFs may
have process-related permit requirements that exceed generator determinations.
Regulations establish more robust waste analysis requirements for TSDFs. At all times, the
owners/operators of a TSDF is responsible for obtaining sufficient information required for
compliance, regardless of the completeness or quality of any information received from the
generator or other parties. Although it may not meet all TSDF analysis requirements,
acceptable knowledge, as discussed above, may be sufficient for documenting compliance
in certain circumstances, and required to be used where no regulatory test defining
compliance exists (e.g., 0003}. If the regulatory agency determines that a TSDF's use of
acceptable knowledge is deficient, the agency can require the TSDF to take additional steps
to address such deficiencies.
Many factors influence the determination of WAP requirements. Some permit conditions
require compliance with precise numerical values. Other conditions can be met with less
sophisticated testing or simple direct visual inspection. Wastes and their matrices can be
highly variable even within a single shipment. Other waste shipments may be more
homogenous, but may have higher variability over time, perhaps reflecting seasonal or
market-based variations in the process generating the waste. All of these factors can be
evaluated for each waste in developing an appropriate waste analysis plan. Figure 1-5
shows how these factors may influence the quality and quantity of waste analysis that may
be needed for different permit conditions.
6 For additional discussion of acceptable knowledge, see 58 FR 48111 (September 14,1993), 59 FR 62916
(December 6,1994), and 62 FR 62081 (November 20,1997).
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FIGURE 1-5: Waste Analysis Quality- Conceptual Model
Frequent
Sampling & Analysis
Frequent
High Quality
Sampling & Analysis
Sampling & Analysis
Acceptable Knowledge
High Quality
Sampling & Analysis
Less
More
Level of Accuracyand Precision Needed to Document Compliance
For example, facilities with constituent feedrate limits may need relatively accurate and
precise analytic results to verify concentrations fall within an acceptable range to
document compliance (such as heavy metal feedrates in support of a risk-based permit
limit for a hazardous waste combustor or for compliance with the Maximum Achievable
Control Technology (MACT) standards of the Clean Air Act where the WAP includes
elements of the MACT-Feedstream Analysis Plan}. Waste streams comprising a variety of
materials, such as a catchall "contaminated debris" wastes (e.g., process waste mixed with
personal protective equipment, sample jars, etc.] may require frequent analysis to
document compliance. Acceptance screening of corrosive wastes may only require
occasional testing with simple test strips. Waste streams shown to be consistent over time
may only require periodic evaluation and/or testing.
1.2.1 Sampling and Analysis for TSDFs
Sampling and analysis can be used to meet all waste analysis requirements for a TSDF.
Frequent and higher quality sampling and analysis, such as analyzing the waste for a
broader list of constituents with laboratory instrumentation, may be necessary when:
A generator begins a new process or changes an existing process;
Wastes are received by a facility for the first time;
A generator has not provided appropriate laboratory information to the TSDF;
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The TSDF has reason to believe that the wastes shipped were not accurately identified
by the generator; or
EPA changes RCRA waste identification/classification rules.
Sampling and analysis can be used to document compliance for pre-acceptance, waste
acceptance, and other on-site waste management activities. These are described below.
Pre-Acceptance Sampling and Analysis
A TSDF may need to confirm various characteristics of a waste at the time of pre-
acceptance (profiling] to avoid accepting waste, which they are not permitted to handle.
Sampling and analysis may be essential for certain types of wastes and/or operations
conducted at the facility, e.g., if the TSDF's treatment/disposal processes must meet
numerical limits.
The analytical data can be submitted along with a "waste profile sheet (WPS}" or Waste
Characterization Report ("WCR") and other supporting data to the TSDF to describe the
generator's waste. An example of a waste profile sheet is provided in Figure 2-9 of this
manual. Waste profiles and submitted data should be used by the TSDF, pursuant to
§§264/265.13(a), to (1} know what waste they will be managing and (2} ensure that the
incoming waste received matches the waste the facility originally approved, which best
assures that they are allowed to manage such waste in accordance with their permit
and/or regulations.
Considerations for TSDF Pre-Acceptance Procedures
Specifying circumstances in which generic profiles can/cannot be used so they are not inappropriately used,
if applicable. For purposes of this manual, a generic profile (also called a "standard profile") is defined as a
profile that could be used for multiple waste streams that are similar in physical and chemical
characteristics. Generic profiles generally may not be acceptable if the TSDF's treatment/disposal processes
must meet numerical limits.
Sampling wastes during pre-acceptance under certain circumstances, e.g., if the TSDF's treatment/disposal
processes must meet numerical limits.
Establishing a recurring process for re-evaluating waste profiles or sending waste profiles to generators
periodically or as required by state regulation for their review, update, and certification to determine that
profiles are up to date.
Providing waste profiles to all generators annually for their review, update and certification that they are up
to date.
Carefully examining documentation from the generator supporting its waste profile sheet (e.g., see the
checklist in Section 1.2.2 for evaluating acceptable knowledge).
Waste Acceptance (Fingerprint Analysis]
Waste acceptance sampling and analysis can include rigorous laboratory instrumental
analysis, testing with field test kits and screening instruments, or by making qualitative
observations such as visual identification of color, number of phases, etc. The specific
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information needed for waste acceptance may depend on the variability of the waste, the
accuracy and precision needed to comply with permit requirements, and the stated
objectives of waste acceptance.
One objective of all waste acceptance sampling and analysis is to confirm the waste
received is the same as the waste expected. Visual identification of color and number of
phases are examples of fingerprint analysis that can be used to help verify that the waste
generated (or received by an off-site TSDF} matches the expected characteristics for that
waste. Other examples of this type of screening include specific gravity, flash point, BTU/lb,
pH, halogen content, cyanide content, and percent water. For certain types of wastes,
verifying the packaging form and packaging content of the waste would also be an
important waste acceptance activity.
Fingerprint analysis parameters specified in a waste analysis plan to verify that each waste
arriving at the gate of the TSDF is the actual waste expected are often quick screening tests
or observations since the detailed chemical and physical properties of a waste are usually
obtained under pre-acceptance sampling and analysis, subsequent sampling and analysis at
the TSDF, or from acceptable knowledge. Fingerprint parameters and the criteria for
acceptance/rejection of the waste will be discussed in Part Two of this manual.
Another example of a waste acceptance objective is the need to track metal concentrations in
a highly variable waste stream to document compliance with permitted feedrates. This type
of acceptance sampling could require sophisticated analysis using laboratory methods.
Although key parameters can be used to obtain a representation of waste composition
quickly, owner/operators should be aware that EPA will generally measure compliance
with the hazardous waste regulations based on a detailed chemical and physical analysis of
Considerations for TSDF Acceptance Procedures
Fingerprinting > 10% of the containers of each waste stream shipped from each generator.
Using a tiered approach for analyzing incoming shipments, whereby all shipments are
inspected/fingerprinted and non-conformances between shipment and WPS trigger a mandatory evaluation
to resolve it and update the WPS (or create a new one) if needed.
Documenting tolerance limits for at least one fingerprint parameter based on the operating requirements of
the facility's management systems, such as a +/- 2 pH unit difference between the shipment and that of the
pH in the profile. If the pH of an incoming shipment falls outside this range, the value would be considered a
non-conformance that should be evaluated and may be subsequently rejected or requalified as appropriate.
Visually inspecting lab packs as a potentially acceptable alternative to fingerprinting them when safe to do so
(e.g., open the containers and verify their contents and packing materials) and reviewing their inventories
(e.g., for incompatibility of materials).
Ensuring that a detailed analysis for the waste constituents regulated under the LDRs is completed at least
annually by the generator or treater (e.g., to verify that treated wastes do, in fact, meet applicable LDR
treatment standards). See EPA interpretive guidance, "Waste Analysis Requirements in Incoming Waste
Shipments -LDR," which is available at RCRA Online (Number 12943).
Usinig a random sampling approach for incoming shipments, whereby the TSDF takes a representative
sample from a small percentage of incoming waste shipments and performs a comprehensive chemical
analysis to verify LDR compliance.
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a representative sample of the waste(s} in question. As a result, it is important for the
selection of key parameters to be based on sufficient waste profile knowledge and data
testing frequency to ensure accurate waste representation.
Other Information Needed forTSDF On-site Management
Other information may be needed to document compliance with permit conditions, but
may not be needed for pre-acceptance or acceptance sampling and can be obtained from
sampling and analysis at the TSDF. An example includes verification of treatment objectives
as a result of permitted treatment or destruction. Sampling and analysis may be
particularly important for wastes that could affect the site's ability to achieve numerical
limits (e.g., feed rates for combustors, organic constituent levels for wastes subject to the
organic air emission standards in 40 CFR Subparts AA through CC of Part 264 and 265}.
1.2.2 Acceptable Knowledge and TSDFs
While waste generators are responsible for making accurate hazardous waste
classifications using procedures described in 40 CFR 262.11, TSDFs are not relieved of their
responsibility to obtain accurate waste analysis data despite the submission of information
provided to the TSDF by generators. Acceptable knowledge can be used to provide
information for pre-acceptance (profiling] needs as well as information needed to comply
with permit requirements. Acceptable knowledge may not be an appropriate substitute for
fingerprint or spot check procedures except in unique cases such as when the TSDF is
accepting properly manifested waste from another site owned by the same company. As
mentioned previously, however, there are situations where it may be sufficient to apply
acceptable knowledge. These situations could involve:
Hazardous constituents in wastes from specific processes that are well documented, such
as with the F-listed and K-listed wastes, provided that the wastes are not highly variable
and accurate and precise concentrations are not necessary for documenting compliance.
Wastes that are discarded unused commercial chemical products, reagents or chemicals
of known physical and chemical constituents, provided that the wastes are not highly
variable and accurate and precise concentrations are not necessary for documenting
compliance. See the P- and U-listed waste categories in 40 CFR §261.33.
Evaluating waste against the hazardous characteristics for which there is no defining
test (e.g., ignitable solids, oxidizers, reactive when wet, etc.]
Health and safety risks to personnel that would not justify sampling and analysis (e.g.,
radioactive mixed waste}.
Physical nature of the waste that prohibits taking a laboratory sample. For example, to
conduct waste analysis of surface-contaminated construction debris, such as steel girders,
piping, and linoleum, it may be necessary to use a combination of laboratory analysis and
acceptable knowledge. The acceptable knowledge would be applied to identifying the
composition of the base construction materials (e.g., steel}. One could then collect surface
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"wipe" samples and conduct
laboratory analysis to determine the
representative concentrations of any
contaminants present. If the base
materials are porous, such as gypsum,
the contamination could be
determined by conducting analysis on
the extracts obtained from a
solvent wash.
When using acceptable knowledge,
documentation is important for
presenting the information used as the
basis for the owner's or operator's
classification of the hazardous waste.
Examples of information that may be
used as part of the basis for acceptable
knowledge include: material balances
for the source or process generating the
hazardous waste; constituent-specific
chemical test data for the hazardous
waste from previous testing that are
still applicable to the current waste;
previous test data for other locations
managing the same type of waste; or
other knowledge based on information
included in manifests, shipping papers,
waste certification notices, and Safety
Data Sheets (SDSs, formerly known as
MSDSs}.7 All available information must
be considered and weighed in making a
knowledge-based hazardous waste
clissification.
Suggested Checklist for Evaluating Waste Determinations
Using Acceptable Knowledge (AK)
S Is published data as current as practicable (e.g., SDSs
greater than five years old may be obsolete due to
changes in RCRA program, improvements in testing
protocols, etc.)?
S Do material balances, if used, include the following
(among other things):
Raw ingredient descriptions and physical and
chemical properties
Physical and chemical processes involved prior to
and during generation
Intermediate products
Materials added and removed during the process?
S Does the generator review its original AK
determination annually, randomly, and whenever
the generating process/waste changes or the TSDF
finds a nonconformance?
S Does the generator understand the potential for
changes in the waste and its classification due to
environmental factors or spontaneous changes (e.g.,
separation of organic solvents from a water phase over
time, pH changes in contact with ambient air, etc.)?
S Are records kept demonstrating that periodic reviews
are being conducted (e.g., a log or certification by
facility personnel that is signed annually)?
S Are analytical results of published studies based on
currently acceptable sample/test methods?
S Are there significant differences between the published
studies and the site's generation processes/wastes
(e.g., raw materials used in the generation process) to
warrant concerns about relevancy?
S Has the TSDF visited the generator's site to confirm
determination?
S Has the TSDF obtained samples of generator's waste to
verify the accuracy of the generator's determination?
S Is the testing capable of illustrating the properties
of the waste that are related to the hazardous
characteristics?
7 The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical
manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data
Sheets) for each hazardous chemical to downstream users to communicate information on these hazards. The
information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented
in a consistent 16-section format. Refer to the OSHA web site for additional information (www.osha.gov).
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Special Concerns When Using Acceptable Knowledge
There are several special concerns that should be considered when relying on acceptable
knowledge to manage waste. First, if you own or operate an off-site TSDF and rely on
information supplied by a generator, it is important to understand, to the extent possible,
the process that generated the waste and ensure the integrity of the information. Second, it
is important to scrutinize carefully whether there are any differences between the waste
generation process and the process described in the published information/data being
utilized and whether the published information/data being used are current.
Generators and off-site TSDFs may use the checklist in this section as a starting point to
make hazardous waste determinations based on acceptable knowledge. Periodic re-
evaluation of hazardous waste determinations may be necessary because EPA periodically
revises the criteria that qualify a waste as a hazardous waste, or the waste properties may
change over time because of handling practices or exposure to the environment. Therefore,
if you use acceptable knowledge, you may need to review your waste analysis or waste
characterization information periodically to verify that the hazardous waste
determinations you have made are still accurate. In addition, you may need to determine if
your existing information is sufficient to identify any new constituent concentration
limitations (i.e., demonstrate compliance with LDR requirements}.
SDSs (aka MSDSs) for chemicals used in the process that generated the waste can be useful
in identifying the properties of constituents in the waste; however, it is not recommended
that they be relied on to exclude possible contaminants. Contaminants may be introduced
as a result of the use of the product and would not be identified on the SDS. SDSs typically
list constituents present at a minimum of 1% by mass (10,000 mg/kg}. Waste constituent
concentrations much lower than this routinely impact hazardous waste management and
waste analysis requirements.
The following examples highlight a potential concern with using acceptable knowledge:
A paint manufacturer used acceptable knowledge to identify the hazardous waste
constituents of six paint colors. During an EPA inspection, the company produced the
documents used to make the hazardous waste determinations that had been generated
years earlier. It was based on a test method that was now obsolete. EPA noted that the
company now manufactured eight colors. Through testing, EPA discovered that one of
the new paints required barium as a coloring agent. Barium is a metal that can cause a
waste to exhibit the hazardous waste characteristic of toxicity if found in
concentrations greater than 100 parts per million (100 ppm] per 40 CFR §261.24. This
manufacturer was found to be out of compliance because the level of barium was
greater than the maximum concentration for the toxicity characteristic, and the
manufacturer's waste analysis data was inaccurate.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Corrosive solids are not included in the corrosivity definition and so are not hazardous
wastes. However, if such material is managed outdoors and is contacted by rainfall, the
rainfall runoff from the waste could be a corrosive hazardous waste and could result in
a release of hazardous waste to the environment.
If the results of non-regulatory tests are used as part of the basis for applying
knowledge in making a hazardous waste determination, then the testing must be
relevant to the hazardous waste characteristic being considered for the waste. While
such testing may be useful in illustrating the properties of the waste, since they are not
part of the RCRA regulations, they cannot be the sole basis for determining waste non-
hazardous status.
Tips on Using a Safety Data Sheet (formerly Material Safety Data Sheets)
to Support Waste Determinations
Some wastes have their own corresponding safety data sheets (SDSs). Often, SDSs used to support
hazardous waste classifications for ingredients used in the process generating the waste. In this instance,
SDSs might not represent waste characteristics but are useful in identifying possible waste constituents.
The two essential steps when using an SDS:
Confirm that you have selected the correct SDS for your waste or process ingredients (this is a common
mistake), and
Check the date to confirm it is recent (e.g., more than five years old may be obsolete due to regulatory
changes, improvements in analytical methods, etc.).
Scan the SDS and look for mention of RCRA. The SDS may indicate if the material is a RCRA hazardous waste
when discarded.
If it does not mention RCRA, find the chemical abstract (CAS) number. Check to see if the CAS number is
identified in the lists in Subpart D of Part 261. If so, it may be a listed waste when discarded (assuming it is a
solid waste and no other exemptions/exclusions apply).
If it is not listed, it may still be RCRA characteristic. Refer to relevant information on chemical and physical
properties for each characteristic, e.g.
For ignitability, refer to flashpoint, fire point, etc. Also look at the NFPAfire rating (a rating of 0 or 1
indicates not ignitable, whereas a 3 and 4 would be indicative of ignitability).
For corrosivity, refer to pH.
For reactivity, refer to the section on reactivity.
For toxicity, refer to the constituents in the material, if shown. If none of them are listed under 261.24
Table 1 and the purity is high, then this may indicate it does not exhibit toxicity characteristic.
However, this requires thorough knowledge of the chemicals in a mixture.
SDSs can be useful in identifying constituents in the waste, however, they should not be exclusively relied
on to exclude possible contaminants. SDSs typically list constituents present at least 1% by mass (10,000
mg/kg). Concentrations much lower than this may impact hazardous waste management and waste
analysis requirements.
Should not use a SDS in the following circumstances:
If the material has been treated, mixed with other chemicals (e.g., acids with bases) or has otherwise
been chemically altered (except as indicators of possible constituents).
If the SDS is more than five years old, unless you confirm that all of its relevant data are still accurate.
As a substitute for laboratory analysis of constituent concentrations when required.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
In addition, where published studies are used as part of acceptable knowledge, it is
important to ensure that information is based on valid and relevant/applicable analytical
techniques. The ability of analytical equipment to detect low concentrations of contaminants
has improved over the years and constituents that once were determined to be "non-
detectable" may, in fact, be detectable using the sophisticated equipment available today.
Although EPA recognizes that sampling and analysis are not as economical or convenient as
using acceptable knowledge, they do usually provide advantages. Because accurate waste
identification is such an important factor for demonstrating compliance with RCRA,
misidentification can present a safety hazard and may subject your facility to enforcement
actions for violations of permit conditions, LDR requirements, annual reporting, and other
RCRA requirements. In addition, accurate waste analysis may be critical for meeting some
of the requirements of other regulatory programs such as effluent discharges under the
Clean Water Act, and transportation requirements regulated by the Department of
Transportation.
You are cautioned to keep abreast of current regulatory developments in the RCRA
program that may affect the classification of your waste, and to re-evaluate your wastes as
necessary using current analytical methods and/or acceptable knowledge, particularly any
time a rule affecting RCRA waste identification/classification is finalized.
1.2.3 Waste Analysis for Generators
Generators may use either sampling and analysis or acceptable knowledge in satisfying
their waste classification obligations. While hazardous waste determinations might not
include collecting the more detailed information that a TSDF may need, generators should
consider the same concepts and limitations regarding relevance, accuracy, precision,
representativeness, safety, and data quality discussed above for TSDFs when choosing an
approach to waste analysis.
Tips for Generators Unfamiliar with RCRA's Waste Determination Requirements
Learn your legal responsibilities under RCRA and your state's hazardous waste program by reviewing your
state's generator standards and guidance. Refer to relevant Federal Register notices and supporting
documents to get a more detailed explanation of the regulations, the intent of the requirements, and how
they are expected to be implemented by the regulated community. The basic obligations of generators
regarding waste classification can be found at 40 CFR 262.11.
Speak with the personnel at your site and compile paperwork to develop a collective knowledge of your
generating processes, potential wastes, regulatory requirements, and opportunities for waste minimization.
Contact your state agency, or the agency in the TSDF's state, if you have questions (e.g., should the
analyses be performed by certified laboratory?). If the state agency is not authorized to administer the
RCRA program, you should contact the U.S. EPA Regional Office in which that state resides.
Contract with a qualified consultant or TSDF for assistance in identifying, collecting and characterizing
your waste.
Join a trade association and/or subscribe to a trade newsletter to stay abreast of regulatory changes. The
RCRA penalty provisions can be found at 40 CFR Part 19.
PART ONE: RCRA Waste Analysis - An Overview
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
PART TWO:
Documenting and Conducting Waste Analysis
2.0 Developing a WAP and Conducting Waste Analysis
In Part One, you identified your waste analysis and waste analysis plan (WAP] responsibilities
and reviewed the methods by which you may meet these responsibilities (i.e., sampling and
laboratory analysis, and acceptable knowledge}. In Part Two, you will learn:8
What may be included in a WAP and how the WAP may be organized (Section 2.1}
How to use a systematic planning process to clearly define the objectives of your
sampling and analysis program (Section 2.3}
How to conduct waste analyses, including selecting
sampling parameters, strategies, and test methods to
meet your objectives, as well as identifying special
waste management conditions that may apply to
your facility (Sections 2.2, 2.4-2.9}
How to document your waste discrepancy and
rejection policies (Sections 2.10 and 2.11}
What recordkeeping requirements you may need to
fulfill (Section 2.12}
How to address corrective and preventative action
measures (Section 2.13}.
2.1 Content and Organization of the WAP
To facilitate conducting waste analyses and developing a
WAP, Table 2-1, which is presented at the end of this
section, provides a list of key questions arranged by
facility type, that when analyzed sequentially, provide an
overview of key considerations for your facility when
planning, documenting, and conducting waste analysis
activities. Answers to the questions posed in Table 2-1
will be based on facility-specific considerations. Relevant
facility-specific factors include:
Key Initial Considerations
for the Facility
WAPs are not one-size-fits-all; a
WAP that is appropriate for a
commercial treatment/
storage/disposal facility, may not
be appropriate for non-commercial
treatment/disposal facilities, or
even captive storage facilities.
Do not clutter up the WAP by
repeating information that exists
elsewhere in the permit (e.g., basic
facility description, process
descriptions); however, brief
summaries may sometimes be
appropriate.
Prepare procedures for subjecting
all wastes (solid and hazardous) to
an appropriate level of analysis.
For example, an incoming
hazardous waste shipment may be
incorrectly evaluated or reported
by the shipper as non-hazardous.
The receiving TSDF should have
measures in the WAP to detect and
properly evaluate such shipments.
This manual presents federal hazardous waste requirements. Because state hazardous waste programs may be
more stringent and/or broader in scope than the federal program, you need to consult your state's regulations to
learn the requirements that apply to you.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
The type of facility (i.e., generator,
TSDF, or both] and the operating status
of the facility's regulated activities (i.e.,
facility is permitted, the facility is
operating under interim status]
The characteristics and quantities of
wastes generated
The types of units that are used to
manage wastes on-site.
The text box below, Content and
Organization of WAP, recommends a
format for facility WAPs that the Agency
has found to be effective. While there is
no required format for a WAP, addressing
the ten elements in the text box will assist
you in WAP development. Of course, there
are other acceptable formats and facilities
are encouraged to work with the permitting agency to determine the most desirable
format based on their specific facility. In addition, note that several of the elements in
the text box are not specified for inclusion in the WAP by regulation; rather, EPA is
recommending them based on its experience. For purposes of clarity, the text box
identifies elements that are recommended or mandatory.
Generator WAP Requirements
Generators are not required to have or follow a WAP,
except if managing and treating prohibited waste or
contaminated soil in tanks, containers, or containment
buildings regulated under 40 CFR 262.34 to meet
applicable LDR treatment standards found at § 268.40
(§268.7(a)(5)). The plan must:
Be written, kept on site in the generator's files, and
made available to inspectors;
Describe the procedures the generator will carry out to
comply with the treatment standards;
Be based on a detailed chemical and physical analysis of
a representative sample of the prohibited waste(s)
being treated;
Contain all information necessary to treat the waste(s)
in accordance with the requirements of Part 268,
including the selected testing frequency.
Generators subject to §268.7(a)(5) should consult Part
Two for guidance on developing their WAPs in accordance
with applicable requirements.
Additionally, it may be helpful to include
documents such as sampling manuals and
standard operating procedures as
appendices to the WAP to increase the
usefulness of the document. Refer to
Appendix F of this manual for key
considerations and tips for both preparing
and reviewing WAPs and for inspecting
facilities for compliance with their WAPs.
When the permitting agency reviews your
proposed WAP and other parts of the
permit application, it will likely contact you
with questions, comments, and suggestions.
You may want to request a meeting and/or
phone call(s] with the agency prior to
and/or after submitting the application to
learn more about their expectations and requirements. You may also want to consider
having the permitting agency visit your site to learn more about your operations.
Key Considerations for the
Permitting Agency and Inspectors
Become familiar with the facility; schedule a visit.
Use clear, enforceable language when preparing permit
conditions and require the same from the facility in
their permit application (e.g., use "must" and "shall" as
opposed to "may" or "should").
Consider including a permit condition that requires
notification of any changes to the WAP or anything
outside of the flexibility of the test method.
Maintain a generic permit template that includes all
federal/state conditions. Keep it up-to-date.
During inspections, or compliance evaluations consider
using someone on-staff (Agency or Agency contractor)
with a chemistry or laboratory background to evaluate
WAP compliance.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Content & Organization of the WAP
1. Purpose
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs
Generators
Generator Only
1. What is the description of the facility
where wastes are generated and/or
managed? (2.2)
2. What processes result in hazardous
waste generation? (2.2)
3. What is the description of the
hazardous wastes that are generated?
What are the waste classifications, EPA
waste codes, and treatability groups,
of the hazardous wastes generated?
(2.2)
4. What waste parameters will be
identified for testing, analysis, and/or
monitoring and what is the rationale
for selecting these parameters? (2.4)
5. What sampling procedures (collection
strategies, equipment, sample
preservation methods and QA/QC
procedures) will be used? (2.5)
6. How will a laboratory be selected?
(2.6.1)
7. What testing and analytical methods
will be used? (2.6.2)
8. What frequency for re- evaluating the
waste will be established? (2.7, 2.8)
9. Will information be prepared on
waste's compliance with LDRs, which
can be shared with treaters and
disposers? (1.1. 3)
10. Are additional provisions for meeting
LDR regulations required? (2.9)
Generators That Treat Waste in
Certain Types of Units*
Address all Generator Only
information from items 1- 10 in
column one. And also, answer
the following:
Before Treatment
11. What are the applicable
treatment standards with
respect to the LDR
regulations? (2. .2, 2.9)
After Treatment
12. Have all the LDR
treatment standards
been met? (2.9)
rcrerannEH
On-Site Only
Address all Generator Only information
from items 1- 10 in column one. And also,
answer the following:
Before Treatment
11. What are the treatment or process
design limitations for optimal safe use
of equipment and materials? (2.2, 2.4)
12. What are the other operational
acceptance limits applicable to permit
and technological considerations (2.2,
2.4)
13. What are the applicable treatment
standards with respect to the LDR
regulations? (2.9)
After Treatment
14. Did the treatment achieve LDR
standards or is additional sampling and
analysis necessary to make this
determination? (2.2, 2.4, 2.5, 2.6, 2.9)
15. What new wastes, waste codes, and
treatability groups were generated?
(2.2)
16. Are there any additional applicable
treatment standards with respect to
LDR regulations? (2.2, 2.9)
17. What additional parameters of the
treated materials (residues) will need to
be monitored and why? (2.4)
18. How will the treated wastes be
sampled? (2. 5)
19. What testing/analytical methods will be
used to analyze the waste (2.6.2)
Off-Site Only
Address all Generator Only information from items 1-
10 in column one. And also, answer the following:
Before Acceptance
11. How will identification of wastes from off-site be
verified? (2.4, 2.8, 2.9)
12. Will corroborative testing be conducted using full-
scale analysis, fingerprinting, or other process such
as acceptable knowledge? (2.4, 2.6, 2.8, 2.9)
13. How will wastes be screened for contaminants
that are incompatible with the treatment process?
(2.6)
Before Treatment
14. What are the treatment process design limitation
for optimum safe use of equipment and materials?
(2.2, 2.4)
15. What are the other operational acceptance limits
applicable to permit and technological
considerations? (2.2, 2.4)
16. What are the applicable treatment standards for
LDR regulations? (2.9)
17. Did the treatment achieve the LDR standards or is
additional sampling and analysis necessary to
make this determination? (2.2, 2.4, 2.5, 2.8, 2.9)
18. What new waste/waste codes & treatability
groups were generated? (2.2)
19. Are there additional applicable treatment
standards with respect to LDR regulations (2.2, 2.9)
20. What additional parameters of the treated
materials (residues) will need to be monitored?
(2.4)
21. How will the treated waste be sampled? (2.5, 2.6)
22. What testing/analytical methods will be used to
analyze the waste? (2.6)
"Treatment in tanks, containers, or containment buildings. Numbers in parentheses indicate the pertinent section numbers.
PART TWO: Documenting and Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs (Continued)
Storage Facilities
On-Site Only
Address all Generator Only
information from items 1- 10. And
also, answer the following:
11. Will managing wastes (e.g. mixed
bulk chemicals) change the
chemical properties, such that
issues 12-15 below must be
addressed? (2.2)
12. How will the initial waste
characterization change? (2.4)
13. What additional sampling and
analysis are required at the
storage facility? (2.4, 2.5)
14. Will a new waste identification
be required and how will it be
verified? (2.8)
15. What are the applicable
treatment standards with
respect to LDR regulations as a
result of any blending or mixing
that may have occurred? (2.2,
2.8, 2.9)
Off-Site Only
Address all Generator Only
information from items 1- 10. And
also, answer the following:
Before Acceptance
11. How will identification of wastes
from off-site be verified? (2.8,
2.9)
12. Will corroborative testing be
conducted using full-scale
analysis, fingerprinting or other
process such as acceptable
knowledge? (2.4, 2.6, 2.8, 2.9)
13. How will wastes be screened for
contaminants that are
incompatible with the storage
process? (2.4)
After Acceptance
14. Will managing wastes (e.g.,
mixed bulk chemicals) change
the chemical properties, such
that issues 15-17 below must be
addressed? (2.2)
15. How will the initial waste
characterization change? (2.4)
16. What additional sampling and
analysis is required at the
storage facility? (2.4, 2.5)
17. Will new waste identification be
required and how will it be
verified? (2.8)
On-Site Only
Address all Generator Only
information from items 1- 10. And
also, answer the following:
11. Have all wastes designated for
land disposal met applicable LDR
treatment standards? (2.2, 2.9)
12. Is it necessary to conduct
additional (corroborative)
testing? (2.8, 2.9)
13. Have applicable tests been
conducted to ensure no free
liquids will be placed into
landfills? (2.4)
m
Off-Site Only
Address all Generator Only
information from items 1- 10. And
also, answer the following:
Before Acceptance
11. How will the identification of
wastes from off-site be verified?
(2.4, 2.8, 2.9)
12. How will wastes be screened for
contaminants that are
incompatible with the disposal
process? (2.4)
After Acceptance
13. What type corroborative testing
will be conducted, such as full-
scale testing and analysis,
fingerprinting, or other process
such as acceptable knowledge?
(2.6, 2.8, 2.9)
14. Have all wastes received on site
for disposal met applicable LDR
treatment standards? (2.2, 2.9)
15. Are additional procedural
requirements applicable for
wastes from off-site? (2.9)
16. Have applicable tests been
conducted to ensure no free
liquids will be placed into
landfills? (2.4)
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.2 Facility Description
The facility description is an important element of an effective waste management program.
The facility description should provide sufficient, yet succinct, information so that
implementing federal and state regulators and WAP users can clearly understand the:
Processes and activities that generate or are used to manage the wastes
Hazardous wastes generated or managed
Hazardous waste management units.
If your facility has an existing RCRA permit or is in the
process of developing a permit application, the majority of
facility description information should be available from
other sections of the permit or permit application. However,
it is also useful to include a summary of this information in
the WAP. It may be helpful for the WAP to reference
where in the permit (or permit application) this
information maybe obtained.
40 CFR 264/265.13 do not
require WAPs to provide a
facility description. However,
this guidance recommends that
a brief facility description (e.g.,
wastes and waste generating
processes) should be addressed
in the WAP.
2.2.1 Description of Facility Processes and Activities
As a hands-on tool for ensuring compliance with applicable regulatory requirements and/or
permit conditions, the WAP may need to provide a description of all on-site facility
processes and activities that are used to generate or manage hazardous wastes (or
reference applicable sections of the permit or permit application] that require sampling and
analysis. This information could include facility diagrams, narrative process descriptions,
and other data relevant to the wastestreams subject to waste analysis. Since many TSDFs,
especially facilities that received waste from off-site sources, use the WAP as an operating
manual, it is advisable to incorporate process descriptions directly into the document.
In addition to describing on-site processes and activities, the WAP may need to describe
how process description^} for each generator's wastestreams will be obtained, updated,
and kept on file as part of the off-site TSDF operating record (which is reviewed by
EPA/state inspectors}. If you own or operate a TSDF, this data should enhance your
knowledge of off-site generation processes and, therefore, should improve your ability to
determine the accuracy of generator waste classification.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.2.2 Identification/Classification of Hazardous Wastes Generated or
Managed at Your Treatment, Storage and Disposal Facility
In addition to describing the processes and activities at your facility, your WAP may need to
identify clearly:
Rationale for identifying each waste as hazardous
Procedures and protocols for identifying
wastes received from off-site sources
Each hazardous waste type managed at your
facility including:
On-site generated wastes
Off-site generated wastes
Waste codes your facility accepts
Wastes your facility does not accept
Each process generating these wastes
Pre-Acceptance of Offsite Wastes
If the facilitiy will receive offsite waste
shipments, the WAP should include processes
and procedures for pre-qualifying these wastes
before the first shipment. The WAP should
describe, for example, the types of information
these offsite sources should provide and the
facility's decision-making criteria.
Refer to Sections 1.2.land 2.9.1 of this manual
for additional information on pre-acceptance
and acceptance.
Appropriate EPA waste classifications (e.g., LDR classification as wastewater or non-
wastewater}.
If you generate or manage a RCRA listed waste, Table 2-2 provides one possible
format that you may use, to present relevant information.
TABLE 2-2: Description of Listed Wastes
Facility
Wastestream
Name
FACILITY A
Semi-
conductor
Manufacture
Spent Degreasing
Solvents
(Trichloroethene)
Process
Generating this
Waste
Machinery
Degreasing
Operations in
Bldg. 12
Rationale for EPA
Hazardous Waste Waste
Designation Code
'/NWW
Contains 25%
trichloroethene, cutting
oils, and other non-
hazardous degreasing
solvents
F001
WW
FACILITY B
Wood
Preserving
Facility
Bottom Sediment
Sludge
Treatment of
Wastewater from
Wood Preserving
Operations
Process used
pentachlorophenol
K001
NWW
NWW = Non-Wastewater
WW = Wastewater
In addition to identifying all listed wastes managed (i.e., all wastes generated on-site or
received from off-site], you may need to conduct testing and/or analysis to determine
whether you also manage any RCRA characteristic wastes (e.g., for purposes of complying
PART TWO: Documenting and Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
with LDR requirements}. Sampling and analysis methods that may be appropriate to
identify characteristics are provided in Sections 2.5 and 2.6 of this manual. If you identify
wastes as characteristic, you may choose to present relevant information as illustrated in
Table 2-3, Description of Characteristic Waste.
Facility
TABLE 2-3: Description of Characteristic Waste
Identify Process Rationale for EPA
Hazardous Generating Hazardous Waste Waste
FACILITY A
Pharmaceutical
Manufacturer
FACILITY B
Hazardous
Waste
Treatment
Facility
Waste this Waste Designation Code(s)
Toxicity
Toxicity
Analgesic
cream
(see Process
A-106)
Fuel
Incineration
Benzene >0.5 ppm
Cadmium > 1.0 ppm
in Waste Residues
D018
D006
UHC(s) WW/NWW
None
None
WW
NWW
NWW = Non-Wastewater
WW = Wastewater
ppm = parts per million
UHC = Underlying Hazardous Constituent
For TSDFs that handle many wastes, the information in Tables 2-2 and 2-3 could be
simplified into broader wastestream categories (e.g., spent non-halogenated solvents]
based on how each wastestream will be handled for treatment and disposal rather than by
the generator or by highly-specific wastestream names.
As a supplement to the above information, this portion of the WAP may also provide a
listing of any wastes or waste properties that the facility is not permitted to accept (i.e.,
unauthorized wastes}. Collectively, the identification of appropriate and unauthorized
waste types should enhance the facility's ability to develop effective sampling and
analytical procedures for the overall waste analysis program.
2.2.3 Description of Hazardous Waste Management Units
The final component of the facility description portion of the WAP may need to include a
description of each hazardous waste management unit at the facility that provides more
detailed information regarding the specific operating conditions and process constraints
for each unit.
A hazardous waste management unit is defined in the RCRA regulations as 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 [40 CFR
§260.10]. Examples include:
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Container storage areas. Note: 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].
Tanks and associated piping and underlying containment systems
Surface impoundments
Landfills
Waste piles
Containment buildings
Land treatment units
^H
Incinerators
Boilers and industrial furnaces
Miscellaneous units.
In your WAP, the description of the hazardous waste management units at your facility may
be provided in narrative and schematic form or a reference to the section of the permit or
permit application that contains this information may be included. The narrative
description may need to include the following:
A physical description of each management unit with dimensions, construction
materials, and components.
A description of each waste type managed in each unit.
A description of the methods for how each hazardous waste will be handled or
managed in the unit, for example:
If hazardous and non-hazardous wastes will be mixed or blended, the methods for
how these activities will be conducted should be described. In certain
circumstances, the hazardous waste may be subject to the "mixture" or "derived-
from" rules [40 CFR §§261.3(a)(2)(iv) and §261.3(c](2](i}]
If a surface impoundment will be used for neutralization of corrosive wastes, the
mechanism for achieving neutralization.
Process/design considerations necessary to ensure that waste management units are
operating in a safe manner and are meeting applicable permit-established performance
standards. This information may need to define specific physical and chemical
operating constraints that must be observed to ensure process integrity. For example,
flow injection incineration facilities typically require wastes to have certain minimum
and maximum levels of viscosity, heat content, and particulates for effective treatment.
Prohibitions that apply to the facility (e.g., PCBs in the incinerator feed, storage of
corrosive waste, unpermitted RCRA hazardous waste codes such as listed dioxin waste}.
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40 CFR 264/265.13 do not specify the
WAP development process described
in Section 2.3. However, using the
process described in this section or an
alternate process of applicable rigor is
recommended to ensure that quality
data is generated.
FIGURE 2-1: The Seven Steps
of the DQO Process
2.3 Systematic Planning
The process of waste analysis is one that involves the
collection and evaluation of data to characterize the
waste. For a waste analysis program to be successful, it
may be helpful to define clearly the objectives of the
program. One way to do this is to consider what
questions you need to answer about a waste to
characterize it adequately. Adequate characterization not
only complies with regulatory hazardous waste
management requirements, but also satisfies company
goals such as cost effective waste management, reducing
legal liability, and improving workplace safety.
The waste analysis process involves a number of steps
including:
Selecting the right parameters for testing
Collecting representative samples
Choosing a qualified laboratory
Selecting appropriate test methods
Quantifying data uncertainty
Making decisions.
At each step in the process, the waste handler needs to make a number of choices (e.g.,
sampling method, number of samples, test methods, etc.}. Small errors made during this
process can result in inaccurate or inappropriate data that may result in making a wrong
decision or violating the conditions of the permit. Systematic planning processes
methodically identify the considerations and approach to data collection prior to waste
sampling. Systematic planning that considers the data needs best ensure that (1} your data
will support your decisions; and (2} compliance with permit and regulatory requirements.
Many systematic planning processes tools are available to guide planning efforts although
the Data Quality Objectives (DQO] process is the most commonly used systematic planning
application in the general environmental community. The DQO process may be
implemented when data are being used to select between two opposing conditions, such as
determining compliance with a standard.
The DQO process includes a seven step planning process as shown in Figure 2-1 and offers
a structured approach to "beginning with the end in mind." It is a framework for asking the
right questions and using the answers to develop and implement a plan for data collection.
The DQO process will enable you to get useful information in a cost-effective manner. The
process is iterative and adaptive, as your knowledge about the decision needs to change
State the Problem
J
Identify the Decision
I
Identify Inputs to the Decision
4
Define the Study Boundaries
4
Develop a Decision Rule
4
Specify Limits on Decision Error
4 I
Optimize the Design
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with time. If you cannot definitively answer a question in the process, sometimes the best
option is to make your best estimate and loop back to improve your plan once you have
more information. The following is a brief discussion of each of the seven steps in the
process. Further discussion of implementing the DQO process in your waste analysis
program is included in Sections 2.4 through 2.8.
DQO Step 1 - State the Problem: In Step 1 of the DQO process, you define the problem or
question you want to answer. In waste characterization, your problem may be defined by
the regulations. For example, you may need to determine if a waste is hazardous or if you
have met a treatment standard. Non-regulatory factors such as your company's standards
may also add additional factors that affect your decision. During Step 1, you also identify
who the key individuals] will be in making decisions and determine how you will gather
information. For larger projects, you may want to organize a planning team with a central
leader and decision maker that is composed of personnel representing all phases of work
(i.e., the waste generator, a chemist, the sampler, etc.}. For smaller projects, you may
streamline the planning effort to reduce costs and meet deadlines. One way you can do this
is by assigning a single individual to lead the project. The project leader, however, would
need to have the authority to make decisions and have access to the individuals with the
necessary information to make the decision.
DQO Step 2 - Identify the Decision: In Step 2, you define the specific decisions that you
want to make and identify the actions you may take based on the results. For example, you
may not only need to make a decision to determine if a solid waste is hazardous but also
how to proceed in handling the waste once it is deemed hazardous or nonhazardous. Your
goal in Step 2 is to formulate a decision statement that includes both of these components.
Depending on the question you are attempting to resolve, you may need to use a tiered
approach of several smaller decisions (for example, 1. determine if the material is not
consistent with the profile, then 2. characterize for hazardous nature and 3. determine if
reactive, flammable or corrosive and 4. characterize for toxic constituents}. If several
separate, decisions are involved, you might list the decisions in the order in which they will
be resolved. Below is a simple example of possible outputs for Step 1 and 2 for a new waste
that your facility has just received that may subject to regulation due to lead.
DQO Step 1 - State the Problem
Do you need to treat the new waste to land disposal restriction (LDR) limits before disposal due to elevated
levels of lead?
DQO Step 2 - Identify the Decision
Does the new waste contain lead at a concentration that exceeds the regulatory standard allowing it to be
disposed at a landfill?
DQO Step 3 - Identify Inputs to the Decision: In Step 3, you identify the type and source
of the information to answer the question from Step 2. For RCRA-related programs, you
typically need to collect samples, measure parameters, and integrate waste generation
acceptable knowledge. This should include identifying possible sample and analytical
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methods; but keep in mind that these methods may need to be revised as more information
is gathered. The potential source(s] of this information (e.g., laboratories] are also
identified. Discussions specific to selecting waste parameters, sampling methods, testing
methods, and identifying laboratories qualified to perform those methods are discussed in
detail in Sections 2.4 through 2.6. The output of Step 3 for the lead waste example is
outlined below.
DQO Step 3 - Identify Inputs to the Decision
Identify the type of information/sources needed to resolve the decision:
Measurement of the concentration of lead in leachate using the TCLP extraction technique.
Use of existing data from the generator to determine waste variability.
Identify the appropriate sample and analytical methods:
Sampling of the waste for lead per 40 CFR 261 Appendix I.
Use of the SW-846 TCLP Method 1311 to produce the leachate.
Use of the SW-846 Methods 3010 and 6010 to prepare and analyze the sample.
DQO Step 4 - Define Study Boundaries: In Step 4, you will define both the spatial and
temporal boundaries of the waste unit and determine any additional constraints on data
collection. The spatial and temporal boundaries help to determine the waste to which your
decision criteria apply.
Spatial boundaries define the physical area to which the data applies and the locations
where samples are taken.
Temporal boundaries describe the time frame the data represent and when the
samples are taken.
When waste is limited to a single container, the spatial boundaries are easy to determine,
as they are the physical boundaries created by the container. In other cases, the spatial
boundaries may be less clear. For example, it may be an area (e.g., an accumulation area}.
Even within a single container there may be other aspects to consider when defining the
spatial boundaries like how evenly (homogeneous] or unevenly (heterogeneous] the
hazardous constituents] are distributed. For example, you may need to sample a
heterogeneous waste much differently than a homogeneous waste to obtain a
representative sample.
The heterogeneous waste may in many cases warrant collection of additional samples. Two
examples of heterogeneous wastes include liquid wastes with multiple layers and a solid
waste that contains "hot spots." For a discussion of sampling strategies for both homo- and
heterogeneous wastes, see Section 2.5.
Temporal boundaries help determine the timeframe to which the decision applies. It may
be defined operationally (e.g., a "batch" of waste] or by a permit or regulation (e.g., waste
generated per day]. In addition to spatial and temporal boundaries, your project decision
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may also be bound by a threshold value, or "action level" that you can use to answer your
question. Specifically, the action level is a value that causes a decision maker to choose
between two actions. Your action level may be a regulatory threshold expressed as a
concentration for a hazardous constituent (e.g., an LDR numeric treatment standard] or it
may be defined by a property of the waste as defined in RCRA (e.g., corrosivity}. You may
also be bound by practical constraints that can include having limited physical access to the
waste being sampled or worker health and safety concerns. You should identify all
boundaries and practical constraints in DQO Step 4. The boundaries and constraints for the
lead waste example are defined below.
DQO Step 4 - Define the Study Boundaries
Spatial & Temporal Boundaries:
The container boundaries of the 10-cubic yard roll off box define the spatial boundaries.
The waste seems to be homogeneous based on existing data from the generator.
This is a new waste. The decision will apply to this load only.
Additional Constraints:
The LDR treatment standard (action level) is 0.75 mg/LTCLP for lead in leachate non-wastewater.
DQO Step 5 - Develop a Decision Rule: In Step 5, you take the output from the previous
steps and develop a decision rule. The decision rule is a single statement in which you
describe how to use the data to make a decision. In the decision statement, you should also
specify how to compare sample results to the action level. That is, compare each individual
sample result to the action level or use another method like comparing the mean of the
results to the action level. In the lead waste example scenario, as RCRA typically only
requires a single exceedance of the LDR treatment standard to make the waste ineligible
for landfill disposal under 40 CFR Part 268, you may need to compare the action level to
each sample individually. The decision rule for the lead waste example is outlined below.
DQO Step 5 - Develop a Decision Rule
If any individual sample result is greater than the LDR treatment standard (action level) of 0.75 mg/LTCLP for
lead in the leachate non-wastewater (F039), then the waste does not meet the LDR treatment standard and is
not eligible for land disposal under 40 CFR Part 268. Otherwise, the waste will be considered suitable for
landfill disposal for lead under 40 CFR Part 268.
DQO Step 6 - Specify Limits on Decision Error: In Step 6, you identify the certainty or
level of confidence that you need in your data, since you rarely have complete confidence
that your decisions are correct due to the non-homogeneity of most wastes and slight
differences in how you handle, sample, and analyze the waste. The appropriate degree of
certainty for each decision unit is unique and can be determined by considering the
consequences of making a wrong decision. If you consider a waste hazardous when it is not,
the consequences may be limited to increased cost of unnecessarily treating the waste
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before disposal. If, however, you consider a waste nonhazardous when it is in fact
hazardous the consequences may include potential future legal or financial liability
problems for the owner that are much more costly.
For these reasons you should evaluate your data to ensure that not only are sample results
below the action level but that you have an appropriate degree of certainty that any
subsequent sample collected from the decision unit would also be below the action level.
One way that you can express the degree of certainty in your data is by establishing a
confidence level. A confidence level indicates the degree of certainty of your data in terms
of a percent (i.e., 90% single tailed confidence level as specified in SW-846, Chapter Nine}.
For example, a 90% confidence level means that you are 90% certain (10% uncertain] that
any additional sample will also be below the action level. To apply a specific confidence
level to your data, you determine the confidence limits statistically. Confidence limits are
the upper and lower limits that your data need to fall within to meet a specific confidence
level. Most action levels will be based on regulatory standards that are not to be exceeded
(or equaled], so normally the upper confidence limit is used.
In the lead waste example, the action level is based on the LDR regulatory limit for lead in
leachate non-wastewater, which is 0.75 mg/L TCLP. As the potential negative consequence
for making a wrong decision is high in this instance (regulatory penalties for
noncompliance, etc.], a high level of confidence (90% certainty] in the data is needed.
Applying a 90% confidence level will reduce the chances of the facility being noncompliant
with regulations. For more detail on how to calculate the upper bound of a confidence limit,
please see the example in Section 2.7, Quantifying Data Uncertainty.
The output of Step 6 is a more detailed decision statement that expresses the decisions
with the confidence limit, which is sometimes referred to as the DQO Statement.
DQO Step 6 - Specify Limits on Decision Error
If any individual sample result in the leachate non-wastewater (F039) is greater than 0.75 mg/L for lead in TCLP
leachate or greater than the 90% upper confidence limit, then the waste does not meet the LDR treatment
standard and is not eligible for land disposal under 40 CFR Part 268. Otherwise, the waste will be considered
suitable for landfill disposal for lead under 40 CFR Part 268.
DQO Step 7 - Optimize the Design: Step 7 is the final step in the DQO process. In Step 7,
you review the outputs from the previous six steps and determine if you have all of the
appropriate information that you need or if there are still data gaps. For example, you
may need to revisit the analytical method you chose in Step 3 if you determine it is not
sensitive enough to meet your action level. After you have eliminated any remaining data
gaps, you can identify an optimal design for collecting your data in a cost-effective
manner to meet your DQO Statement. This will likely include finalizing the selection of
sampling and analytical methods and determining the appropriate number of samples to
collect. You should also document your decision and take the appropriate actions to
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ensure that all staff involved in sample collection and analysis understand and properly
implement the sample design.
Further information on systematic planning and the DQO process can be found in the
following sources:
US EPA Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA
QA/G-4, EPA 240-B-06-001, 2006. http://www.epa.gov/quality/qs-docs/g4-flnal.pdf
US EPA RCRA Waste Sampling Draft Technical Guidance, EPA 530-D-02-002, 2002.
http://www.epa.gov/epawaste/hazard/testmethods/sw846/samp guid.htm
For a more detailed discussion of the DQO Process - See Chapter Four entitled,
"Planning Your Project Using the DQO Process"
For more examples of applying the DQO Process to waste analysis - See Appendix I
entitled, "Examples of Planning, Implementation, and Assessment for RCRA Waste
Sampling."
2.4 Selecting Waste Analysis Parameters
An accurate representation of a waste's
40 CFR 264/265.13(b)(l) require that WAPs specify
parameters for which each hazardous waste, or non-
hazardous waste if applicable, will be analyzed and
the rationale for the selection of these parameters.
physical and chemical properties is critical
in determining viable waste management
options. Accordingly, facility WAPs should
specify waste parameters that provide
sufficient information to ensure:
Compliance with applicable federal regulatory requirements (e.g., LDR regulations
including underlying hazardous constituents, newly identified or listed hazardous
wastes]
Compliance with applicable state regulatory requirements
Conformance with permit conditions (i.e., ensure that wastes accepted for management
fall within the scope of the facility permit, and process performance standards can
be met]
Safe and effective waste management operations (i.e., ensure that no wastes are
accepted that are incompatible or inappropriate given the type of management
practices used by the facility}.
Attention to the above factors when developing a WAP should orient you toward the
major considerations for selecting waste analysis parameters. Your facility should
keep in mind that the parameter selection process can be an iterative process,
and that you may want to select final parameters with regulators. The following
discussion provides more definitive guidance to help you determine the specific
parameters to be incorporated into your WAP.
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Different Sampling and Analysis Objectives for Enforcement Agencies and Waste Handlers
"Proving the Positive" versus "Proving the Negative"
For enforcement agencies and waste handlers, the purpose of a sampling and analysis program is to identify
chemical constituents and characteristics in waste to adhere to or ensure adherence to regulations. Many
RCRA regulations contain concentrations that are not to be exceeded (or equaled) to comply with the standard.
Nonetheless, the sampling and analysis conducted by a waste handler can be different from that conducted by
enforcement agencies due to a difference in the objectives of each.
The objective for an enforcement official is to evaluate a waste handler's compliance with a "do not exceed"
standard. The enforcement official will likely initially collect one representative sample based on professional
judgment. The waste handler, however, wants to ensure that waste concentrations are low enough so that it
would be highly unlikely that any sample of the waste would exceed the regulatory standard.
The sampling and analysis objective of the enforcement official is sometimes called "proving the positive." That
is, the enforcement official determines whether a concentration of a specific constituent in some area of the
wastes exceeds the regulatory level. This only requires a single measurement above the regulatory level to
draw a conclusion, that the waste is hazardous. "Proving the positive" usually does not require low detection
limits, high analyte recoveries, or high degrees of precision. Per Federal Register preamble (see 55 FR 4442,
February 8,1990). It reads:
"If a sample possesses the property of interest, or contains the constituent at a high
enough level relative to the regulatory threshold, then the population from which the
sample was drawn must also possess the property of interest or contain that constituent."
The sampling and analysis objectives of a waste handler on the other hand may be "proving the negative." That
is, the waste handler wants to determine if a concentration of a specific constituent(s) exceeds the regulatory
level for any of the waste at any time. While it is never possible to have complete confidence in a
determination, the waste handler may try to demonstrate with a high level of confidence that the vast majority
of the waste is far enough below the regulatory standard so that an additional sample of the waste would be
unlikely to exceed the regulatory standard. "Proving the negative" is far more demanding than "proving the
positive" and thus encourages proper sampling design and good quality control. Per Federal Register preamble
(see 55 FR 4441, February 8,1990). It reads:
'The sampling strategy for these situations (proving the negative) should be thorough enough
to insure that one does not conclude a waste is nonhazardous when, in fact, it is hazardous."
Therefore, the waste handler may want to establish objectives using a systematic planning process, design a
WAP based on the objectives, collect and analyze the appropriate number of samples, and use the results from
the sample analyses for decision-making.
2.4.1 Criteria for Parameter Selection
Waste analysis parameters are designed to represent those characteristics necessary for safe
and effective waste management. Due to the diversity of hazardous waste operations and the
myriad of operating variables, the identification of the most suitable parameters to be
sampled and analyzed can be complex, especially for large TSDFs. To this point, relevant
waste analysis parameter selection criteria can be developed and reviewed systematically to
efficiently identify parameters of interest. Generally, these selection criteria may be
organized into the following categories:
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Waste identification
Identification of incompatible/ unauthorized wastes
Process and design considerations.
Each major category where selection criteria are to be applied is described in detail below.
Waste Identification
A prerequisite step in proper waste
management is the identification of hazardous
wastes in accordance with regulatory and
permit requirements. Generators and TSDFs
must evaluate (through testing or applying
acceptable knowledge] solid wastes to
determine if the wastes are hazardous in
accordance with state regulations and the
RCRA characteristics and listings set forth in 40
CFR Part 261, Subparts C and D. In addition,
because of LDR regulations, they must
determine whether hazardous wastes are
restricted from land disposal according to 40
CFR Part 268. If the generator determines that
his waste is subject to LDR requirements, he
must comply with the LDR notification and
certification requirements at 40 CFR §268.7.
Accordingly, an effective waste analysis plan
not only specifies the parameters that may be
necessary to ensure that wastes accepted by
the TSDF are accurately identified and fall
within the scope of the facility permit (where applicable], but also may include provisions
to ensure that applicable LDR requirements are fulfilled. Waste analysis requirements for
generators and TSDFs including LDR provisions for underlying hazardous constituents
(UHCs] are presented in Section 1.2.
TSDFs are still responsible for meeting the LDR treatment standards for all
constituents subject to the LDR requirements, regardless of the constituents
identified by the generator. TSDFs may consult a variety of reference materials
pertaining to the types of wastes to be managed when specifying parameters to
corroborate waste identification under RCRA, including:
40 CFR Part 261, Appendices VII and VIII (i.e., the basis for listing hazardous wastes,
and hazardous constituents, respectively]
Applicable state hazardous waste regulations
Characteristic Waste and
Underlying Hazardous Constituents (UHCs)
Characteristic hazardous waste (per 40 CFR
§§261.21-.24) must comply with the special
requirements set forth in 40 CFR §268.9. This
includes addressing UHCs.
When determining the LDR treatment standard for
the characteristic waste, you must consult the
table of standards in 40 CFR §268.40 to determine
whether you are responsible for meeting "§268.48
standards" and, if so, you must identify any
constituents that are reasonably expected to
qualify as UHCs at the point of generation.
If UHCs are identified, the waste cannot be
disposed in a landfill until the waste:
No longer exhibits the characteristic
Meets the concentration-based universal
treatment standard (s) in 40 CFR §268.48 for
each regulated constituent (i.e., UHC) in the
waste.
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Industry and trade association hazardous waste profile studies
EPA Background Documents, for RCRA listed and characteristic hazardous wastes.
Another consideration in selecting waste analysis parameters, especially if you are the
owner/operator of a TSDF that accepts waste from off-site facilities, is determining when
you may need to conduct a full waste characterization versus abbreviated or targeted
analysis, sometimes referred to as "fingerprint analysis." A full waste characterization may
be appropriate when:
A generator begins a new process or changes an existing process
Wastes are received by a facility for the first time
A generator has not provided appropriate waste profiles or laboratory information to
an off-site TSDF
A facility may want to verify generator supplied waste information (routine] is accurate
An off-site TSDF has reason to suspect that the wastes received were not accurately
identified by the generator (non-routine]
EPA changes RCRA waste identification/classification rules
Abbreviated or fingerprint analysis is conducted generally for parameters (e.g., specific
gravity, color, flash point, presence of more than one phase, pH, halogen content, cyanide
content, percent water] that will give information that can be used to help verify that the
waste generated, or received by an off-site TSDF, matches the expected characteristics for
that waste. For example, at an off-site TSDF, abbreviated analysis can be used to verify that
the waste received matches the description on the manifest, and that the waste matches the
waste type that the facility has agreed to accept. Where the owner/operator of a TSDF
already knows the detailed chemical and physical properties of a waste, appropriate target
or spot check parameters can easily be selected to verify that each waste arriving at the
gate of the TSDF matches its profile.
Sampling frequencies and waste re-evaluation frequencies are discussed in additional
detail in Sections 2.5.1 and 2.8, respectively.
Identification of Incompatible/Unauthorized Wastes
Regulatory requirements [40 CFR §§264/265.17] and good management practices dictate
that incompatible (e.g., acids and bases] or unauthorized wastes be identified prior to
waste management. If combined, incompatible wastes are capable of spontaneous
combustion, toxic gas generation, or explosions. Compatibility testing may include
determining water reactivity (e.g., foaming, generating heat, explosiveness]; oxidation-
reduction potential, spot tests for cyanide and sulfide, among others, with the objective to:
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Ensure compatibility of waste with accumulation/storage tanks and containers;
Determine compatibility of separate waste streams prior to commingling;
Avoid accumulating incompatible wastes in the same storage location; and/or
Ensure tanks/containers that were used to store a different wastestream have been
adequately cleaned.
Accepting wastestreams not authorized for your facility operations may violate permit
conditions. Examples of unauthorized wastes may include PCBs and listed dioxin wastes.
The selection of waste parameters therefore, must include measures to screen for and
identify these types of waste prior to acceptance.
Suitable parameters for identifying incompatible and unauthorized wastes will vary
according to facility-specific operating and permit conditions. To determine if particular
wastes or wastes and storage units are compatible, the RCRA regulations list some common
potentially incompatible wastes [40 CFR Part 264, Appendix V]. For compatibility of wastes
not listed in the regulations, the facility may need to test the waste and the unit for
compatibility. Parameters and analytical methods for ignitable and corrosive waste are
contained in chapters seven and eight of SW-846, respectively. The EPA document: "A
Method for Determining the Compatibility of Hazardous Wastes" (EPA 600-2-80-076} [An
electronic copy of this document can be downloaded from the National Service Center for
Environmental Publications (NSCEP] at http://nepis.epa.gov] contains guidance on
qualitatively evaluating the compatibility of various types of wastes.
Process and Design Considerations
The effectiveness of a facility's waste handling operations and associated management
units are subject to process and equipment design limitations. These operating constraints
determine the range of wastes and waste properties (e.g., constituent concentrations, pH,
etc.] that may be safely managed in a given process while maintaining regulatory and
permit compliance. Thus, the facility WAP may need to include provisions to ensure that
physical and chemical analyses provide the information needed to identify any waste
properties that may exceed technical/equipment design limitations as well as regulatory
and permit limitations (e.g., inorganic feed rates, BTU values, chlorine/metal content}.
Potential risks to facility personnel and structures, compliance status, and possible impacts
to off-site human health and the environment that may result from exceeding facility
operational limitations emphasize the need to identify relevant parameters affecting
treatment, storage, and disposal prior to acceptance for management. Similarly, because
waste composition may change while being managed at an on-site facility, processes and
designs should be reviewed for all phases of waste management (i.e., pre-process, in-
process, and post-process] when selecting waste analysis parameters. For example, where
multiple treatment processes are used, waste composition changes resulting from a
pretreatment process may preclude its subsequent management by certain other
hazardous waste units at the facility.
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Technical/equipment design operating constraints may determine the range of physical
and chemical properties that are acceptable for a given waste management operation.
Waste analysis parameters may need to be selected to provide both a qualitative and
quantitative measure of these conditions. Typically, these waste analysis parameters are
used to determine if (1] the waste composition is atypical of that normally handled by the
facility; and/or, (2} acceptance or further management (without pretreatment] of the
waste may compromise the performance goals of the waste management process.
In addition to selecting these waste analysis parameters, you may need to ensure that
applicable regulatory requirements and permit conditions are met while protecting waste
management unit performance goals and structural integrity. Major factors to consider
when selecting parameters for evaluating operational limits are listed below:
Types of waste to be managed
Volumes of waste to be managed
How waste was received from off-site, if applicable (e.g., drums, roll-offs]
Source of waste (i.e., on-site, off-site generator]
Method of storage, transfer or treatment, if applicable (e.g., stabilization]
Types of units in which the wastes will be managed
Construction materials of the unit
Location of the unit (e.g., proximity to property boundary]
This list is not exhaustive and, therefore, other operational factors applicable to your
facility may need to be considered.
2.4.2 Parameter Selection Process
As stated previously, a systematic evaluation of relevant waste analysis criteria (i.e., those
associated with waste identification, identification of incompatible/unauthorized wastes,
and process and design considerations] is useful for efficiently identifying waste
parameters. To this end, Figure 2-2 Waste Analysis Parameter Selection Process illustrates
a systematic process for selecting waste analysis parameter, which can be used to develop
a comprehensive inventory of applicable waste parameters. This tool is designed to be
applied to each hazardous waste management unit individually so that parameter
selections for each unit are developed through separate iterations of the flow process. In
addition, attention may need to be given to any pre-, in-, or post-process variables that may
require selection of additional or different parameters.
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FIGURE 2-2: Waste Analysis Parameter Selection Process
Waste Identification
Identify and classify hazardous
wastes generated or managed
according to EPA waste codes.
Determine any additional
responsibilities for waste
analysis under LDR (i.e..
verify whether wastes are
prohibited), and if applicable
UHCs.
Select appropriate waste
analysis parameters (e.g.,
hazardous constituents,
hazardous characteristics) to
identify RCRA waste
classification, and LDR
restricted wastes and if
applicable UHCs.
Proceed to Identification of
Incompatible/Unauthorized
Wastes.
I
Waste Identification
Parameter Inventory
Identification of
Incompatible/
Unauthorized Wastes
Identify appropriate waste
analysis parameters to measure
ignitability. reactivity, and
incompatibility, as well as
identify unauthorized wastes.
Determine special
incompatible waste
considerations based on
facility operations and the
profile of waste being
managed.
Define appropriate
measurement parameters .
Determine unauthorized
wastes (e.g.. unpermitted
wastes).
Proceed to Process/Design
Considerations.
Process/Design
Considerations
Identify the universe of
parameters that are necessary
to evaluate the range of process
and design limitations.
Determine the specific
parameters necessary to
identify waste acceptability
with respect to process and
design limitations, preferably
for each management unit.
For pre-process, in-process,
and post-process operating
variables, select parameters
which indicate changes in
waste composition that may
affect waste management
(e.g.. pH. specific gravity).
Proceed to Parameter
Evaluation
Prioritize parameters for
incorporation into the
WAP based on
capability to provide
best representation of
waste properties.
Identification of
Incompatible/Unauthorized
Waste Parameter Inventory
Process/Design
Consideration Parameter
Inventory
Parameter Evaluation
Eliminate parameters which:
Are duplicate parameters
selected during previous
parameter selection
process elements
Cannot be measured due
to technological or other
limitations
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2.4.3 Rationale for Parameter Selection
Along with identifying waste analysis parameters, the RCRA regulations [40 CFR
§§264/265.l(b](l}] require that the WAP provide the rationale for the selection of each
parameter. The rationale must describe the basis for waste analysis parameters and how
selected, and how each will measure physical and chemical waste properties such that
wastes are managed within regulatory, permit and process and design limitations. This
information will assist regulators and WAP users with evaluating the viability of parameter
selection, the appropriateness of incorporating parameters in the WAP, and may help
eliminate extraneous waste analysis parameters.
2.4.4 Special Parameter Selection Requirements
Where applicable, WAPs may also need to include procedures and parameters for
managing specialized wastes in particular hazardous waste management units as follows:
Facilities managing ignitable, reactive, or incompatible wastes
Bulk and containerized liquids wastes for landfills
TSDF process vents
Equipment leaks
Hazardous waste combustors [40 CFR §63.1209(c], §63.1208(b}(8], §§264/265.341,
§266.102(a], and §266.103(a], as applicable]
Sampling, analytical, and procedural methods that will be used to meet these additional
waste analysis requirements for specific waste management units must be included, where
applicable, in your WAP [40 CFR §§264/265.13(b}(6}]. For reference purposes, these
special requirements are discussed below.
Ignitable, Reactive, and Incompatible Waste Analysis Requirements
WAPs must include provisions to ensure that waste management units meet the special
requirements for ignitable, reactive, and incompatible wastes [40 CFR §§264/265.17].
Standard tests to identify ignitable, corrosive, and toxic wastes are contained in Chapter 8
of SW-846. You should identify reactive wastes as such if they exhibit at least one of the
eight properties identified in 40 CFR §261.23. As EPA does not currently have a set of
approved methods for determining reactivity, generators should use waste acceptable
knowledge to determine if their waste exhibits the characteristic of reactivity. Incompatible
wastes, if brought together, could result in heat generation, toxic gas generation, and/or
explosions. Finally, waste compatibility determinations can serve to establish compatibility
between wastes of interest for a given process. To determine if particular wastes or storage
units are compatible, consult the RCRA regulations list of some common potentially
incompatible wastes [40 CFR Part 264, Appendix V]. For compatibility of wastes not listed
in the regulations, the facility may need to test the waste and the unit for compatibility.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Further information on waste compatibility:
US EPA, A Method of Determining the Compatibility of Hazardous Wastes, EPA 600-2-
80-076, 1980. An electronic copy of this document can be downloaded from the NSCEP
site at http://nepis.epa.gov.
Design and Development of a Hazardous Waste Reactivity Testing Protocol. EPA-
600/52-84-057. U.S. Environmental Protection Agency, Municipal Environmental
Research Laboratory, Cincinnati, Ohio, 1984.
Special Requirements for Bulk and Containerized Liquids in Landfills
Owners/operators of hazardous waste
landfills must ensure that free liquids are not
placed into the landfill and that restrictions
r The WAP may need to include a requirement for
on containerized liquids are met [40 CFR
§§264/265.314]. Specifically, bulk and/or
non-containerized liquids or wastes
containing free liquids are not to be placed
into a landfill. In addition, containers holding
Considerations for Landfill WAPs
testing for free liquids in containers or, if free
liquids are not otherwise expected to be present
in a container, then a visual inspection. If the
visual inspection detects free liquids, appropriate
steps may be required (e.g., performance of free
free liquids should not be placed in a landfill '
unless all free-standing liquids: (1] have been
removed by decanting, or other methods; (2} have been mixed with a nonbiodegradable
absorbent or have been solidified so that free-standing liquid is no longer observed; or (3}
have been otherwise eliminated. Limited exceptions to the placement of containers holding
free liquids in landfills include, very small containers, containers designed to hold free
liquids for reasons other than storage (e.g., some batteries, capacitors], and lab packs. A
WAP should identify procedures to ensure that these requirements are met, and if
applicable, describe the procedures that will be used to determine whether a
biodegradable sorbent has been added to the waste in the container.
TSDF Process Vent Analysis Requirements
TSDF owners/operators are required to identify and meet specific technical requirements
for all process vents associated with distillation, fractionation, thin-film evaporation,
solvent extraction, and stripping processes that manage wastes with a 10 ppmw (ppm by
weight] or greater total organics concentration on a time weighted annual average basis
[40 CFR §§264/265.1034(d]]. The applicability of these process vent requirements is
established by measuring total organic concentrations in the waste using SW-846 Method
9060. The determination that relevant processes are managing organic waste below the
regulated threshold must be made as follows: (1] by the effective date that the facility
becomes subject to the requirements; and, (2] for continuously generated wastes, annually,
or whenever there is a change in the process or waste being managed.
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Equipment Leak Waste Analysis Requirements
TSDF owners/operators may need to determine if equipment contains or contacts organic wastes
with 10 percent or greater total organic content. This trigger threshold may be determined by
using the following: (1} methods described in ASTM methods D 2267-88, E 169-87, E 260-
85; (2} Method 9060 of SW-846; or, (3} applying knowledge of the nature of the hazardous
wastestream or the process by which it was produced. If the organic concentrations meet
these regulated levels, emission control and monitoring standards apply to each valve,
pump, compressor, pressure relief device, open-ended valve or line, flange or other
connector and associated air emission control device or system.
Hazardous Waste Combustors
Hazardous waste combustors (HWCs} are differentiated based on how the CAA defines
source categories and how the combustion unit is designed and operated. Certain types of
boilers and industrial furnaces (BIFs} and incinerators that burn hazardous waste are
examples of hazardous waste combustors. Hazardous waste combustors are subject to
applicable regulatory requirements pursuant to both the RCRA program and the Clean Air
Act (CAA} National Emission Standards for Hazardous Air Pollutants (NESHAP} program.
Prior to the adoption of the CAA Hazardous Waste Combustor (or HWC} NESHAP standards,
emissions from RCRA hazardous waste combustion units were regulated according to 40
CFR Parts 264 and 265 (for incinerators] and 40 CFR Part 266 (for BIFs}. Thus, for BIFs and
incinerators, the RCRA emission standards/limitations and related operating requirements
resided in the RCRA permit or interim status regulations, and all waste analysis
requirements to comply with the requirements were located in the waste analysis plan
(WAP}. Between 1999 and 2005, EPA established new CAA HWC NESHAP emission
standards, testing and operating requirements for incinerators, cement kilns, lightweight
aggregate kilns, boilers, and hydrochloric acid (HC1} production furnaces burning hazardous
waste. The CAA HWC NESHAP is codified in 40 CFR Part 63, supbart EEE.
In order to avoid (to the extent practicable} having duplicative coverage of emission
standards and operating requirements in the RCRA permit and the CAA notification of
compliance and Title V permit, EPA finalized a regulatory approach allowing a facility to
modify its RCRA permit to remove most or all emission standards and emission related
operating requirements that are covered by the CAA HWC NESHAP once the source
demonstrated compliance with the 40 CFR Part 63, supbart EEE. Under this approach, the
CAA HWC NESHAP emission standards and emission related operating requirements reside
in the CAA notification of compliance and Title V permit, while the other RCRA
requirements associated with the combustion unit and the facility remain in the RCRA
permit Examples of requirements that continue to be part of the RCRA permit for HWCs
include general facility standards, WAPs, closure plans, contingency plans, financial
assurance, corrective action, and RCRA omnibus provisions.
With respect to the RCRA WAP, it should not be confused with the CAA HWC NESHAP
feedstream analysis plan (FAP}. While there are separate waste analysis requirements for
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HWCs under the different statutory programs, the requirements are closely related and
should be coordinated to the extent practicable. (See the discussion of hazardous waste
combustors in Appendix D of this manual for a crosswalk table which highlights the
similarities between the RCRA WAP and CAA FAP and identifies sections of this manual
that may be of assistance in developing a CAA FAP.} As discussed in greater detail on the
following page and in section 2.9.2 (Procedures for Combustion Facilities], the RCRA WAP
would include, for example, general RCRA waste analysis requirements that ensure safe
receipt and management of wastes9 (inclusive of all non-combustion hazardous waste
management activities], as well as (if needed] waste analyses requirements necessary to
ensure compliance with more stringent (relative to MACT] emission and feedrate
limitations determined necessary as a result of a site-specific risk assessment. Specifically,
the RCRA WAP serves to screen the incoming waste to the facility which will be treated,
stored, and/or disposed, as well as to screen out wastes that are prohibited from going to
the combustion unit. The CAA FAP focuses on the waste before being fed to the combustor
to ensure compliance with the CAA HWC NESHAP emission standards and feedstream
related operating requirements.10 Thus, the FAP can be thought of as a subset of the RCRA
WAP, since the incoming waste affects what is ultimately combusted.
Note that there are other types of RCRA thermal treatment units that are not subject to the
CAA HWC NESHAP under 40 CFR Part 63, Subpart EEE. For example, carbon regeneration
units, open burn/open detonation units, and sulfuric acid production units, are not
regulated pursuant to the CAA HWC NESHAP requirements, and are rather regulated
pursuant to the applicable RCRA standards for Miscellaneous Units (see 40 CFR Part 264,
Subpart X] or BIFs (see 40 CFR §§266.102 and 266.103] As a result, facilities with these
sources are subject to all applicable RCRA WAP requirements, which include, among
others, RCRA WAP feedstream characterization requirements prior to treatment to ensure
compliance with applicable BIF or Subpart X pollutant feedrate and emission limitations.
Also, it is worth noting that some boilers and HC1 production furnances are not necessarily
subject to the full suite of CAA HWC NESHAP standards. Only boilers and HC1 production
furnaces that are determined to be "major sources"11 are required to comply with all CAA
HWC NESHAP standards. Boilers and HC1 production furnaces that are not major sources
are considered "area sources" and have the option to either comply with the full suite of
CAA HWC NESHAP standards or a mix of CAA HWC NESHAP standards and RCRA emission
9 See 40 CFR §§264.177, 264.198, and 264.199
Also, the CAA HWC NESHAP requires feedstream analyses that are specific to the comprehensive and
confirmatory performance tests to ensure these tests accurately quantify the levels and amounts of contaminants
that are fed into the combustion unit during these tests. See 40 CFR §63.1207(f)(iv).
11 As defined in the CAA, a major source is any stationary source that emits or has the potential to emit 10 tons per
year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP. An area source is a stationary
source that is not a major source. Generally, NESHAP standards do not apply to area sources. However, EPA chose
to regulate certain area source HWCs (incinerators, cement kilns and lightweight aggregate kilns) under the
NESHAP standards. Therefore, all incinerators, cement kilns, and lightweight aggregate kilns must comply with
NESHAP standards. A separate decision was made for boilers and HCI production furnaces such that those area
sources have the option to comply with all or some of the NESHAP standards. Lastly, EPA determined that all HWC
area sources are required to have a CAA Title V permit.
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standards. Specifically, area sources in these categories are subject to the CAA HWC
NESHAP standards for mercury, dioxin/furans, carbon monoxide/hydrocarbons, and
destruction and removal efficiency. RCRA standards under Part 266, Subpart H for
particulate matter, metals other than mercury, and hydrogen chloride and chlorine
continue to apply unless the area source elects to comply with the major source standards
for these pollutants in lieu of the RCRA standards. For additional information, see 40 CFR
§§266.100(b}(3}, 270.22, 270.66, and the final rule preamble (70 FR at 59433-34 (October
12, 2005}}. As a result, a RCRA WAP covering these pollutants would also be needed to
ensure compliance with RCRA feedrate limitations that are then used to ensure compliance
with the RCRA controlled emissions not covered by the CAA HWC NESHAP requirements.
A key point is that a RCRA WAP is still a required component of the RCRA permit for all RCRA
facilities that are also subject to the CAA HWC NESHAP standards for the following reason:
The RCRA WAP is needed to ensure the applicable general waste analysis requirements
found in 40 CFR §264.13 are being met for both on-site and off-site combustion sources
(e.g., verifying waste received from off-site sources matches the waste identified on the
manifest, identification of the hazardous constituents including the ignitable/reactive/
corrosive characteristics, and verifying the compatibility of the hazardous waste prior
to mixing that waste with other wastes in tanks or containers prior to further treatment
or disposal at the facility}.
In addition, there are limited circumstances in which a RCRA WAP may need to include waste
analysis requirements necessary to ensure compliance with emission-related limitations for
combustion units that are also subject to the CAA HWC NESHAP. This may occur when:
The RCRA permit review determines that the CAA HWC NESHAP standards are not
sufficient to protect human health and the environment for a specific facility. In that
case, the RCRA permit may include additional feedrate limitations/controls and the
WAP may include procedures to ensure compliance with them.
The owner/operator elects to comply with one of the "RCRA Options" in 40 CFR 270.235
for minimizing emissions during periods of startup, shutdown, and malfunction.
Boilers or HC1 production furnaces that are area sources under the CAA and elect to
comply with certain standards for particulate
matter, metals other than mercury, hydrogen
chloride and chlorine under RCRA Part 266,
Subpart H instead of the CAA HWC NESHAP
standards. (See 40 CFR63.1218(e}.}
2.5 Selecting Sampling Procedures
Sampling is the physical collection of a
representative portion of a waste or waste
treatment residual. To be representative, a sample
40 CFR 264/265.13(b) and (c) require that
WAPs address sampling methods which will
be used to obtain representative samples.
Note: Although this section includes
sampling information relevant to both
hazardous waste and LDR determinations,
the need for "representative sampling"
applies to hazardous waste, but not LDR,
determinations. For additional information,
refer to the LDR Phase IV final rule at
Federal Register 63:100 (26 May 1998) p.
28562.
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needs to be collected and handled in a way that preserves its original physical form and
chemical composition and prevents contamination. For a sample to provide meaningful
data, it is important that it reflect the properties of the waste from which it was obtained,
that its physical and chemical integrity be maintained, and that it be analyzed within a
dedicated quality assurance program.
Due to the diversity of hazardous wastes and the number of
possible generation (e.g., batch, continuous feed] and waste
management scenarios (e.g., drums, roll-off boxes, tankers,
and lugger boxes], the type(s] of sampling procedures will
vary. The following subsections discuss the proper
procedures and considerations for sample collection, sample
preservation, quality assurance/quality control (QA/QC], and
occupational health and safety.
TSD Facilities and Generators:
Refer to your state's
requirements that apply to you,
as they may be more stringent
and/or broader in scope than
the federal program.
Only the methods referenced in Appendix I to 40 CFR 261 are discussed in this guidance
manual. These methods have two sources: the American Society for Testing and Materials
(ASTM] methods and EPA's SW-846. In particular, SW-846 has been developed by EPA to
assist the regulated community in meeting analytical responsibilities under RCRA.
2.5.1 Sampling Strategies and Sampling Frequencies
Sampling Methods and
Quantities:
Although a single grab sample
is easy and inexpensive to
collect, it may not be adequate
to characterize a waste stream.
The sampling methods and
quantities used need to be
representative of the waste
stream being sampled as
required by regulation.
An accurate representation of a waste's physical and
chemical properties is critical in determining viable waste
management options. Accordingly, a facility's WAP must
specify waste parameters that provide sufficient
information to ensure:
Compliance with applicable regulatory requirements
(e.g., LDR regulations, newly identified or listed
hazardous wastes]
Conformance with permit conditions (i.e., ensure that
wastes accepted for management fall within the scope of
the facility permit, and process performance standards
can be met]
Safe and effective waste management operations (i.e., ensure that no wastes are
accepted that are incompatible or inappropriate given the type of management
practices used by the facility].
Sampling Strategies
The development and application of a sampling strategy is a prerequisite to obtaining a
representative sample capable of producing scientifically viable data. Strategies may need
to be selected or prepared prior to actual sampling to organize and coordinate sampling
activities, to maximize data accuracy, and to minimize errors attributable to incorrectly
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selected sampling procedures. A sampling strategy may need to address the following:
Objectives of collecting the samples
Types of samples needed (e.g., grab samples or composite samples]
Selection of sampling locations
Number of samples
Sampling frequency
Sample collection and handling techniques
In addition, the following factors may also need to be taken into consideration for the
wastes to be sampled since they can influence the sampling development process:
Physical properties
Chemical properties
Special circumstances or considerations (e.g., complex multi-phase wastestreams,
highly corrosive liquids, oily sludges] that may require the wastes be homogenized
prior to sampling or other techniques be used to obtain a representative sample.
Conversely, if a facility is conducting phase separation as a treatment of a waste, each
phase of the waste may need to be sampled and analyzed separately.
Based upon the data objectives and other considerations identified in the sampling
strategy, two major sampling approaches may be employed to collect representative
samples. These approaches are summarized as follows:
Authoritative Sampling - where sufficient historical, site, and process information is
available to accurately assess the chemical and physical properties of a waste, authoritative
sampling (also known as judgment sampling] can be used to obtain representative
samples. Sample locations are selected based on knowledge of waste properties (e.g.,
homogeneous process streams] and level of uniformity or waste distribution as well as
waste management units. The validity of authoritative sampling is dependent upon the
accuracy of the information used. The rationale for selection of sampling locations is
important and may need to be documented.
Random Sampling - due to the difficulty in determining the exact chemical and physical
properties of most hazardous wastestreams (needed for using authoritative sampling],
random sampling strategies are most commonly used. Random sampling is based upon
mathematical and statistical theories and can ensure that representative samples are
obtained from almost any waste. Generally, three specific techniques, simple, stratified,
and systematic random, are employed. Table 2-4 Sampling Approach Overview provides
a summary of both authoritative and random sampling definitions, applicability, and
limitations. Figure 2-3 Illustration of Random, Stratified Random, and Systematic Sampling
illustrates the typical sampling distribution associated with each of the individual types of
random sampling.
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TABLE 2-4: Sampling Approach Overview
Sample Strategy
AUTHORITATIVE
Definition
Technique where sample locations are
selected based on detailed knowledge
of the wastestream without regard to
randomization.
Applicability
Wastestreams of known physical/
chemical properties and
concentrations.
Advantages/Disadvantages
Requires in-depth knowledge of properties and
constituents of wastestreams. Rationale for sample
selection may need to be well documented and
defensible.
RANDOM
(Simple,
Stratified,
Systematic)
Simple
Random
Stratified
Random
Systematic
Random
Technique where sample selection and
location are determined through the
application of statistical methods.
All locations/points in a waste or unit
from which a sample can be obtained
are identified, and a suitable number
of samples are randomly selected.
Areas of nonuniform properties or
concentrations are identified and
stratified (segregated). Subsequently,
simple random samples are collected
from each stratum of the waste or unit.
The first sampling point is randomly
selected but all subsequent samples
are collected at fixed space intervals
(e.g. along a transect or time intervals.)
Used to collect representative
samples where data is insufficient to
justify authoritative sampling (e.g.
wastestreams of unknown or variable
concentration).
Used to collect representative
samples of wastes that are
heterogeneous throughout the entire
wastestream or unit (e.g. multiple
drums of unknown origin).
Used to collect representative samples
from waste or units that are known to
have areas of nonuniform properties
(strata) or concentration (hot spots)
[e.g. surface impoundments with
multiple waste layers].
An alternate procedure used to
collect representative samples from
modestly heterogeneous
wastestreams that provides for
simplified sample identification.
See discussions below for each respective random
sampling technique.
Advantages: Most appropriate where little or no
information is available concerning the distribution of
chemical constituents.
Disadvantages: May misrepresent wastestreams with
areas of high concentration or stratification.
Advantages: Provides for increased accuracy of
wastestream representation if strata or a typically high
or low concentration area is present.
Disadvantages: Requires a greater knowledge of the
wastestream relative to waste where simple random
sampling is used and may require sophisticated
statistical applications.
Advantages: Provides for easier sample identification
and collection relative to other techniques.
Disadvantages: May misrepresent wastestreams with
unknown areas of high concentration or stratification.
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FIGURE 2-3: Illustration of Simple Random, Stratified Random and
Systematic Random Sampling (e.g., Roll-off Boxes)
8
Simple Random Sampling
6
4
2
E
Q
m
Q
i i i i i
6 8 10 12 14
8
Stratified Random Sampling
6 -
o -
0
El
8 -
i
4
i i i i
8 10 12 14
Systematic Random Sampling
6
4
2
8 10 12 14
LEGEND:
Sample Area Boundary
Strata Boundary
Randomly Selected Sample Location
Sample Location Determined
Systematically
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An additional element in the design of an effective sampling strategy is the selection of
appropriate sample types. Based on the analytical objectives of sampling (e.g., initial waste
identification versus recharacterization], analytical considerations, and available resources
(for sampling and analysis], two basic types, grab and composite samples, can be
collected, as described in Table 2-5 Major Sample Types.
TABLE 2-5: Major Sample Types
Sample Type Definition
GRAB
A sample taken
from a particular
location at a
distinct point in
time.
Applicability
Most common type used
for random sampling.
Useful in determining
wastestream variability
(e.g. range of
concentration) when
multiple or frequent
samples are obtained.
Advantages/Disadvantages
Advantages: Simplest technique, best
measure of variability and range of
contaminant concentrations.
Disadvantages: May require a larger number
of samples relative to composite sampling to
obtain a representative sample.
COMPOSITE
A number of
random samples
are initially
collected from a
waste and
combined into a
single sample for
subsequent
analysis.
Used where average or
normalized concentration
estimates of a
wastestream constituents
are desired.
Note: If collecting samples
for compliance with LDR
or UHC treatment
standards you may not be
able to collect composite
samples Please check with
the regulations before
proceeding.
Advantages: Reduces analytical costs. May
reduce the number of samples needed to
gain accurate representation of a waste.
Disadvantages: Only provides the average
concentrations of a wastestream (i.e.
information about concentration range
is lost).
Note: You should generally not collect
composite samples if you are analyzing for
VOCs unless permitted by the regulations, as
these compounds can be lost during sample
mixing. If you are sampling for parameters in
addition to VOCs (e.g., metals), you may
composite samples for these other analyses
as long as the compositing procedure will
not alter the constituents.
A composite sample is a number of individual samples called aliquots collected from a
volume of waste that are combined into a single sample for analysis. Composite sampling is
an attractive option as it can help to reduce costs when used appropriately, and where it is
not explicitly prohibited by regulation such as for analysis for universal treatment
standards under 40 CFR §268.48(a]. A disadvantage of composite sampling is that "hot
spot" contaminant concentrations can become diluted. This problem may be alleviated by
dividing the action level, such as the maximum concentration of contaminants for the
toxicity characteristic in Table 1 of 40 CFR §261.24, by the number of aliquots comprising
the composite sample, resulting in a new lower action level. After this is done, it must be
ensured that the analytical detection limit is less than or equal to the newly adjusted
(lower] action level. Another factor that must be considered when compositing is that the
waste being sampled should be relatively homogeneous and that none of the anticipated
contaminants are volatile compounds since volatile substances may be lost during
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homogenization of the aliquots. Finally, it is very important to ensure that the individual
aliquots are all equal in volume before they are combined and homogenized.
A grab sample is a single sample from a
particular location within a volume of
waste at a distinct point in time. Grab
samples should generally be collected if
the integrity of the sample may be affected
by the physical mixing of samples during
the compositing process (e.g., volatile
constituents], and when determining
compliance with LDR requirements as
specified (e.g., compliance with UHCs is
measured by an analysis of grab samples
unless otherwise noted in the
regulations}. EPA established treatment
standards for unauthorized wastes based
on grab sampling as it reflects maximum
process variability, and thus reasonably
characterize the range of treatment
system performance.
Further information on sampling
strategies and the optimum applications
for each strategy are included in the
following guidance documents, methods,
and standards:
American Society for Testing and
Materials, RCRA Waste Management:
Planning, Implementation, and
Assessment of Sampling Activities,
Manual 42, 2000. http://www.astm.org/BOOKSTORE/PUBS/MNL42.htm
US EPA Guidance on Choosing a Sampling Design for Environmental Data Collection for
Use in Developing a Quality Assurance Project Plan (EPA QA/G-5S] EPA/240/R-02/005,
December 2002. http://www.epa.gov/quality/qs-docs/g5s-flnal.pdf.
US EPA Observational Economy Series, Volume 1: Composite Sampling, EPA-230-R-95-
005, 1995. An electronic copy can be downloaded from the NSCEP site at
http://nepis.epa.gov.
US EPA RCRA Waste Sampling Draft Technical Guidance, EPA 530-D-02-002, 2002.
http://www.epa.gov/epawaste/hazard/testmethods/sw846/samp guid.htm
Chapter 5: Optimizing the Design for Obtaining Data
Grab or Composite Samples?
It is imperative that you understand both the
applicable regulations and the intended use of the
sample data before determining whether to collect
either grab or composite samples.
For example, compliance with the LDR numeric
treatment standards for non-wastewaters typically is to
be determined using "grab" samples rather than
composite samples. Grab samples processed, analyzed,
and evaluated individually normally reflect maximum
process variability, and thus reasonably characterize the
range of treatment system performance. Typically, grab
samples are used to evaluate LDR non-wastewaters and
composite samples are used to evaluate LDR
wastewaters, except when evaluating wastewaters for
metals (D004 through D011) for which grab samples are
required [40 CFR268.40(b)].
For additional information, see the following:
Land Disposal Restrictions for Second Third
Scheduled Wastes. Federal Register 54:120 (June
23,1989). pps. 26605-26606. Treatment Standards
Based on Single Facility Data and Grab Samples
Versus Composite Samples.
Land Disposal Restrictions for Third Third Scheduled
Wastes. Federal Register 55:106 (June 1,1990). p.
22539. Treatment Standards Based on Single Facility
Data, Grab Samples Versus Composite Samples, and
Waste Analysis Plans.
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Chapter 6: Controlling Variability and Bias in Sampling
Appendix C: Strategies for Sampling Heterogeneous Wastes
US EPA Superfund Program Representative Sampling Guidance, EPA 540-R-95-141,
1995. An electronic copy can be downloaded from the NSCEP site at
http://nepis.epa.gov.
Volume 1: Soil
Volume 4: Waste
US EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods.
http://www.epa.gov/epawaste/hazard/testmethods/sw846/index.htm.
Chapter Nine: Sampling Plan
Sampling Frequencies
The RCRA regulations state that "waste analysis must be repeated as necessary to ensure
that it is accurate and up to date." [CFR §§264/265.13(a}(3}]
At a minimum, the analysis must be repeated as follows:
When the owner or operator is notified, or has reason to believe, that the process or
operation generating the hazardous wastes, or non-hazardous wastes if applicable
under § 264/265.113(d], has changed [40 CFR §§264/265.13(a](3}(i}].
For off-site facilities, when the results of the inspection (fingerprint analysis] required
in paragraph (a}(4] of 264/265.13 indicate that the hazardous waste received at the
facility does not match the waste designated on the accompanying manifest or shipping
paper. [40 CFR §264/265.13(a](3}(ii}]. An off-site facility must inspect and, if
necessary, analyze each hazardous waste shipment received to determine if it matches
the identity of the waste specified on the accompanying manifest or shipping paper. [40
CFR§§264/265.13(a}(4}]
Although there are no required time intervals for re-evaluating wastes, you need to
develop a schedule for re-evaluating the waste on a regular basis to ensure the analysis is
accurate and up to date [40 CFR §§264/265.13(b}(4}]. You may need to make an individual
assessment of how often waste analysis is necessary to ensure compliance with your Part B
permit operating conditions. Off-site combustion facilities may need to characterize all
wastes prior to burning to verify that permit conditions will be met (i.e., fingerprint
analysis may not be acceptable}.
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The Cost of Infrequent Analysis
Increasing sampling frequency may result in additional analytical costs. These costs may be minor in
comparison to penalties for non-compliance. Consider a situation where a hazardous waste is disposed of as
non-hazardous waste and the facility has been sampling the waste annually, a frequency they cannot justify.
Specifically, the facility:
Analyzes a new wastestream in January and determines that it is nonhazardous.
Disposes the waste monthly as non-hazardous based on the initial evaluation.
Re-analyzes the waste in December and finds it contains hazardous levels of cadmium.
Properly treats and disposes of the December waste based on the cadmium hazard.
The potential consequences:
The facility may be subject to penalties for improper disposal of the shipments from February through
November of that year. The RCRA penalty provisions can be found at 40 CFR 19.
The facility may be financially responsible for the clean-up of the improperly disposed waste.
The insurance premiums of the facility may increase.
When the regulations do not specifically stipulate sampling frequency, you may want to use
a tiered approach to waste re-evaluation. That is, you may conduct a thorough initial
characterization of each waste and then slowly reduce the frequency of re-evaluation over
time with each subsequent shipment as long as the hazardous constituents are safely below
the action level (defined in Section 2.3}. For example, if a site generates a new waste
stream during its manufacturing operations, the number of manufacturing batches
to sample should be determined through a sound statistical basis and with a
thorough understanding of the potential for variability in the waste stream. This is
important, as the waste handler can use the data from this initial shipment as a baseline to
evaluate data from the subsequent shipments. There are also a number of ways to use
historic waste data to determine re-evaluation frequencies. One possible approach is
detailed in Section 2.8. You do not need to use this specific approach but your WAP must
clearly state how you will determine re-evaluation frequencies based on waste data.
2.5.2 Selecting Sample Equipment
Four broad criteria relating to waste that may need to be considered when determining the
most appropriate type of sampling equipment to use for a given sampling strategy:
Physical parameters
Chemical parameters
Waste-specific criteria (e.g., oily sludges]
Site-specific factors (e.g., accessibility issues]
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Specific physical parameters affecting this selection include:
Physical State
Liquid (free flowing or highly viscous]
Solid (crushed, powdered, or whole] or environmental media (soil, sediment]
Distribution
Homogeneous
Heterogeneous (stratified/layered, hot spots]
Chemical parameters of the waste can also significantly affect the waste collection effort.
The person collecting the sample may need to ensure that the sampling equipment is
constructed of materials that are not only compatible with the wastes, but are not
susceptible to reactions that might alter or bias the physical or chemical characteristics of
the waste. Examples in which the sampling equipment material may potentially yield false
analytical results would be the release of organic compounds from certain plastics or of
heavy metals (e.g., cadmium, nickel, lead] from metal alloys used in sampling corrosive
wastestreams.
Waste- and site-specific factors may also affect the use of sampling devices. Examples of
waste-specific properties that may affect the use of common sampling equipment are the
collection of oily sludges or highly corrosive wastes. Examples of site-specific situations
involving complex sampling activities include the collection of representative samples from
waste management units with limited accessibility. In addition to determining the type of
sampling equipment used, the waste- and site-specific factors also may require
modification of the chosen equipment so that it can be applied to the waste.
Once the physical, chemical, waste- and site-specific factors associated with the
wastestream to be sampled have been identified and evaluated, appropriate sampling
equipment can be selected. The equipment most typically used in sampling includes:
Composite liquid waste samplers (coliwasas], weighted bottles, and dippers for liquid
wastestreams
Triers, thieves, and augers for sampling sludges and solid wastestreams
Bailers, suction pumps, and positive displacement pumps for sampling wells for
groundwater evaluations.
Liquid Samples
A coliwasa is most appropriate when sampling free-flowing liquids and slurries in drums,
shallow tanks, pits, and similar waste containers. The stream coliwasa consists of a glass or
plastic or metal tube equipped with an end closure that the sampler can open and close to
initiate and/or stop the sampling while the tool is submerged in the material to be sampled.
A weighted bottle or dipper may be used to obtain a sample of a free flowing liquid or
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slurry from areas with limited accessibility. See Figure 2-4, Samplers for Liquid
Wastestreams, for depictions of coliwasa, weighted bottle, and dipper samplers.
Solid Samples
A thief is suitable for sampling dry granules or powdered wastes whose particle diameter
is less than one-third the width of the slots in the thief. The thief consists of two slotted
concentric tubes. The outer tube has a conical pointed tip that allows the thief to penetrate
the waste you are sampling. The sampler then rotates the inner tube to a closed position so
that a sample can be retrieved from the wastestream. A sampling trier is a tube cut in half
lengthwise with a sharpened tip that allows penetration of the tube into adhesive solids
and allows the sampler to loosen granulated materials. Generally, the trier is 61 to 100 cm
long with a diameter between 1.27 and 2.54 cm. It is used to sample solids whose diameter
is less than one-half that of the trier. Augers are used to sample hard or packed solid
wastes and consist of sharpened spiral blades attached to a hard metal central shaft.
Augers can be one foot to several feet long. See Figure 2-5, Samplers for Solid
Wastestreams, for depictions of thief, trier, and auger samplers.
Table 2-6 Applicability of Sampling Equipment to Wastestreams presents examples of
common types of sampling equipment and their applicability for sampling various types of
Wastestreams. Waste-specific conditions at your facility may indicate that the
recommended equipment is inappropriate. Accordingly, it is best to develop a sampling
strategy with equipment that is tailored to your site. SW-846, Chapter 9 contains
additional guidance on the applicability of sampling equipment for different waste
matrices. Alternatively, consult with a knowledgeable EPA representative, a qualified
environmental testing laboratory or industry group if you are uncertain as to how to select
the appropriate equipment.
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FIGURE 2-4: Samplers for Liquid Wastestreams
Stopper
Coliwasa
(2 \!T)
152 cm (60")
Weighted Bottle
Varigrip Clamp
Dipper
r
Bolt Ho»es
Telescoping Aluminum Pole
2.5 to 4.5 Meters (8 to 15ft.)
Beaker
150 to 600 ml
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FIGURE 2-5: Samplers for Solid Wastestreams
Thief
Trier
60- 100cm
60- 100cm
1.27-2.54 cm
1 27-2.54 cm
Hand Augers
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2.5.3 Maintaining and Decontaminating Field Equipment
Some analyses, such as pH, can be performed at the facility using field equipment. In order
to provide accurate data to ensure data quality, this equipment should be properly
maintained and calibrated regularly. The maintenance guidelines set forth in the operator's
manual of each piece of equipment may help determine calibration frequency as proper
maintenance varies by model manufacturer. At a minimum, the facility may need to inspect
and calibrate the equipment prior to use and keep calibration records on file for review.
All equipment that comes in contact with the waste must be free of residual materials
which can influence (i.e., contaminate] the true physical or chemical composition of the
waste. Therefore, to minimize the potential for cross-contamination, all equipment and
containers may need to be cleaned thoroughly and decontaminated prior to use. All
sampling equipment may need to be decontaminated after each sampling event. These
procedures generally consist of an initial step to remove all loose debris and soil from the
sampling equipment, followed by a thorough cleaning process including washing with an
inert detergent solution (such as alconox}. As a final step, the equipment is rinsed with an
appropriate solvent (e.g., volatile alcohols, acetone, or hexane for organics; nitric acid for
inorganics] followed by several rinses with deionized water.
The level of decontamination that is necessary during and after sampling is dependent
upon the degree of contamination and the sensitivity of the analytical tests to be
performed. Where materials and equipment are to be reused, proper decontamination
procedures may need to be followed to diminish the potential for cross-contamination of
samples. If subsequent storage of the equipment does not preserve the cleanliness of the
decontaminated equipment, the equipment may need to be decontaminated prior to the
next sampling event.
Sample containers may be supplied by a laboratory equipment manufacturer or by your
analytical laboratory. For manufacturer-supplied containers, a certificate of analysis
alternatively, other documentation may be obtained which describes the contaminant
levels inherent to the sample containers. In either case, appropriate quality control
measures, as described in subsequent sections, may need to be taken. Furthermore, used
containers that have not been decontaminated generally should be avoided to reduce the
potential of cross-contamination.
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TABLE 2-6: Applicability of Sampling Equipment to Wastestreams
^^
Free-flowing
liquids and slurries
Sludges
Moist powders
or granules
Dry powders or
granules
Packed Sand or
powders and
granules
Large-grained
solids
Coliwasa
Trier
Trier
Thief
Auger
Large
Trier
PPUBJB
N/A
N/A
Trier
Thief
Auger
Large
Trier
Open Bed
TRUCK
N/A
Trier
Trier
Thief
Auger
Large Trier
Waste Locatii
Closed Bed
Truck
Coliwasa
Trier
Trier
Thief
Auger
Large Trier
Dn or Container
Storage Tanks
Or Bins
Weighted
bottle (a)
Trier
Trier
(b)
Thief
Large
Trier
Piles
N/A
(b)
Trier
Trier
Thief
Large
Trier
^JJIiE^B
Lagoons, Pits
Dipper
(b)
Trier
Thief
(b)
Large
Trier
^KJMjrfcOTij^H
Belt
N/A
(b)
Shovel
Shovel
Dipper
Trier
Dipper
(b)
Dipper
Dipper
Dipper
Dipper
a When the tank is adequately agitated or a recirculation line is accessible, samples can be collected through a side tap.
b This type of sampling situation can present significant logistical sampling problems, and sampling equipment must be specifically selected or designed based on-site and waste conditions. No
general statement about appropriate sampling equipment can be made.
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2.5.4 Sample Preservation and Storage
Once the sample has been collected, sample preservation techniques and holding times, if
applicable, need to be employed to ensure that the integrity of the waste remains intact
while the samples are in transport to an off-site laboratory and/or while stored at the
laboratory prior to analysis. Sample preservation is generally not applicable for highly
concentrated samples; however, low concentration samples needs preservation. If a sample
is not preserved properly, the constituents of concern in the sample may be chemically,
physically, or biologically altered through degradation or other processes (e.g.,
volatilization, oxidation}. Examples of typical sample preservation techniques include:
Preserving the sample with appropriate chemicals (e.g., adding an acid preservative to
suppress biological activity]
Refrigerating samples
Storing and shipping samples in the appropriate container and lid type (e.g., collecting
samples for light sensitive organic contaminants in amber glass bottles}.
Appropriate preservation methods allow samples to be stored without concern for physical
or chemical degradation for the time between sample collection and analysis. However, the
effectiveness of preservation diminishes over time, thereby potentially affecting the
sample's integrity. Accordingly, EPA has established standardized holding times, based
upon the chemical constituent of interest to ensure the integrity and validity of resulting
analytical data. For a detailed list of proper sample containers preservation techniques, and
holding times, if applicable, one may refer to SW-846, Chapter 2, or the individual SW-846
methods themselves.
2.5.5 Establishing Quality Assurance/Quality Control Procedures
Quality assurance (QA] is the process for ensuring that all data and the decisions based on
that data are technically sound, statistically valid, and properly documented. Quality
control (QC] procedures are the tools employed to measure the degree to which these
quality assurance objectives are fulfilled. As the first component of data acquisition in
relation to waste analysis, sampling techniques may need to incorporate rigorous QA/QC
procedures to ensure the validity of sampling activities. Since a facility's compliance with
applicable permitting and regulatory requirements may be based on a relatively few
number of analytical measurements, any event (e.g., unidentified contamination, dilution,
improper handling] that may compromise the collection and measurement of a
representative sample is significant. Thus, it is important for QA/QC procedures to be
established in the WAP and followed. Each facility will likely implement its own QA/QC
procedures because each facility will have its own unique QA/QC requirements.
Additionally, all persons involved in sampling activities may need to be aware of applicable
QA/QC procedures. More detail on what may be needed for QA/QC is provided in SW-846.
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Quality Assurance
In many ways, QA can only be measured qualitatively. For example, to assure that samples
are taken with the same level of precision each time, QA procedures can be as simple as
making sure that the personnel collecting the sample are trained and experienced.
Additionally, a chain-of-custody protocol is a useful qualitative tool for documenting the
time and location of sample collection activities. The WAP may need to provide facility-
specific procedures, including:
Sample strategy (including type of samples to be collected]
Sampling identification numbers and locations
Preservation reagents and techniques, as appropriate
Chain-of-custody procedures
Types of sampling equipment and sample containers
Analytical procedures
Decontamination procedures
Field and laboratory QC procedures (see related discussions below]
Relevant health and safety considerations.
It may be beneficial for facilities to document any deviations from the WAP and the reasons
for deviating from WAP procedures.
Quality Control
QC procedures, as tools to measure the attainment of QA objectives, lend themselves to be
measured more quantitatively. For example, one QC procedure involves taking samples in
duplicate or triplicate and sending them to the analytical laboratory. If the analytical results
of the duplicates are similar to the original sample, the original sample is assumed to be
representative (i.e., good QA procedures were followed]. However, if sample results are
highly variable, one could infer that the sample collection procedures are not adequate for
collecting a representative sample, or that one or more of the samples collected were
inadvertently contaminated. Highly variable analytical results indicate that you may need
to re-evaluate the sampling program (to include the collection of more samples], employ a
different sampling strategy due to unforeseen or special site conditions, or assess potential
for cross-contamination. QC measures that can be taken throughout the sampling process
to ensure the integrity of the overall program include:
Field Blanks are prepared in the field by filling a clean container with pure deionized
water and appropriate preservative, if any, for the specific sampling activity being
undertaken. If contaminants are found to be present in the field blank, it might be assumed
that environmental factors (such as airborne contamination], sampling procedures
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(causing cross-contamination], or equipment (that is contaminated] were contributing to
the levels of hazardous waste constituents that is measured.
Trip Blanks are sample containers that are prepared in the lab using the same type of
containers that are to be used for field samples. The containers are filled with an inert
material (such as deionized water] that are carried into and out of the field but are not
opened at any time during the sampling event. If the trip blanks were found to be
contaminated, the source of the contamination would be assumed to be the container itself,
the environment in which the trip blank was prepared, or some other source located
outside the sample area.
Equipment Blanks are prepared prior to sampling by running pure deionized water over
sampling equipment and collecting the water into a clean sample container. If the
equipment blank is found to be contaminated, the source of contamination could be
assumed to be from the equipment used during the sampling operations.
Field Split Samples are collected by actually splitting a sample volume in half and
submitting the samples to two different laboratories. Sometimes, split samples are
collected for enforcement purposes. The facility (sampler] splits samples with the regulator
as a check on the facility's own analytical program and data recordkeeping. Alternatively, a
facility may collect a split sample to verify that the analytical results determined at its on-
site facility lab can be verified at an independent laboratory.
Field Duplicates are independent samples that are taken from the same location at the
same time and are used to measure the effectiveness of obtaining representative samples.
The precision (reproducibility of analytical data] resulting from field duplicates provides an
accurate reflection of the variance inherent to the waste composition and the sampling
technique. If blanks and duplicates are collected for analysis, they generally should be
treated as regular samples, which would include conducting the same preservation and
storage techniques as well as completing the proper paper work (e.g., chain-of-custody
documentation] accompanying the samples. The facility should determine, based on its own
DQOs, what QC samples to collect, when to collect them, and at what frequency and include
a description of this in the WAP to be reviewed and approved by the permitting officials.
Chain-Of-Custody
It may be a good idea to specify chain-of-custody procedures, both internal and external, in
the WAP. These procedures involve documentation of the possession of samples from the
time they are obtained until they are disposed or shipped off-site for analysis. At a
minimum, the procedures may need to specify that the following information be recorded
when samples of waste or treatment residuals are collected: (1] the type of waste collected,
including a brief description and the manifest number, if applicable, and waste code(s]; (2]
names and signatures of samplers; (3] sample number, date and time of collection, and
designation as a grab or composite, including what type of composite; (4] names and
signatures of any persons involved in transferring samples; and (5] if applicable, the
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shipping number, such as an airbill number, for samples shipped to off-site laboratories. An
example chain-of-custody record is shown on Figure 2-6 Example Chain-of-Custody Record.
2.5.6 Establishing Health and Safety Protocols
Worker safety and health should be taken into consideration when preparing and
implementing the WAP at your facility and may need to be part of any personnel training
program as required by 40 CFR §§264/265.16. Employees who perform sampling activities
may need to be properly trained with respect to the hazards associated with waste
materials, as well as with any sampling and waste handling procedures that will assist in
protecting the health and safety of the sampler.
In addition, the employees may need to be trained in the proper protective clothing and
equipment that is used when performing sampling activities. Examples of the safety
procedures for which personnel at your facility may need to be trained, depending on-site-
specific situations, may include:
Training in the common routes of exposure (inhalation, contact ingestion] that might be
encountered when taking samples.
Instruction in the proper use of safety equipment, such as Draeger tube air samplers to
detect air contamination that employees potentially could be exposed to during
sampling.
Proper use of eye protection, impermeable gloves, protective clothing and footwear,
and respiratory equipment to guard against exposure.
Possible hazards associated with handling and sampling ignitable, corrosive, and
reactive waste.
You may want to consult the Occupation Safety and Health Act (OSHA}, pursuant to 29 CFR
§ 1910.120, to determine the required training that may be given to your employees.
Additionally, you may also want to consult the Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities (OSHA 1985, revised 1998], which was
developed through the joint efforts of OSHA, NIOSH, the US Coast Guard, and EPA to
address occupational safety and health issues specific to hazardous waste sites. It is
optional whether you include these procedures in your WAP. The inclusion of health and
safety procedures, however, enhances the use of the WAP as a hands-on operating tool at
your facility.
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FIGURE 2-6: Example Chain-of-Custody Record
PROJECT NO,
PROJECT NAME
SAMPLERS: (Signature)
FIELD
SAMPLE
NUMBER
DATE
TIME
(Printed)
STATION LOCATION
Relinquished by: (Signature)
DATE / TIME
Received by: (Signature)
Relinquished by: (Signature)
DATE / TIME
Received by: (Signature)
(Printed)
(Printed)
(Printed)
(Printed)
Relinquished by: (Signature)
(Printed)
DATE / TIME
Received for Laboratory by:
(Signature)
DATE /TIME Remarks
(Printed)
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2.6 Selecting a Laboratory and Laboratory Analytical Methods
2.6.1 Selecting a Laboratory
40 CFR 264/265.13 do not require
WAPs to address how laboratories will
be selected. However, this guidance
recommends that the rationale for
selecting a laboroatory be addressed in
the WAP.
The use of proper analytical procedures is important
in acquiring useful and accurate data. When selecting
an analytical laboratory you may want to consider if
the analytical laboratory has demonstrated
experience in performing waste sample analyses and
is capable of providing documentation of their proven
analytical capabilities, available instrumentation, and
standard operating procedures. Furthermore, you may want to consider selecting a
laboratory able to substantiate their data by systematically documenting the steps taken to
obtain and validate the data. The following discussion provides guidance on the factors to be
considered when selecting an analytical laboratory.
The analytical laboratory that demonstrates proficiency in the four major areas below is
more likely to provide accurate data:
Considerations for the Facility
Some amount of off-site independent
laboratory analysis is important
Frequent use of laboratory analysis
may be preferential instead of relying
heavily on generator knowledge alone
Learn if your state or federal EPA
program has a lab certification
program and find a certified lab
Comprehensive QA/QC programs (both qualitative
and quantitative]
Technical analytical expertise
Effective information management systems
Third party accreditation
The relevant considerations that may be used to
assess laboratory strengths in each of these areas
are described in more detail below.
Comprehensive QA/QC Programs
Along with sampling activities, a QA/QC program is an integral part of laboratory analytical
operations. Laboratory QA ensures that analytical methods generate data that are
technically sound, statistically valid, and documented. Individual QC procedures are the
tools employed to measure the degree to which these QA objectives are met. Accordingly,
you may want to ensure that the laboratory addresses the following program elements.
Qualitative QA/QC Elements
A good laboratory generally will have a laboratory QA plan, sometimes called a quality
systems or laboratory quality manual (LQM}, which you can request and review. The LQM
generally will detail the lab's procedures for important QA elements such as the
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organizational structure and management policies, sample handling and tracking
procedures, documentation procedures, internal audits, and proficiency testing.
The laboratory will generally also be able to
provide you with standard operating
procedures (SOPs} for any of the test methods
that they perform. This includes having SOPs
for SW-846 methods. SW-846 methods
contain only general information on how to
perform an analytical procedure or technique.
They do not detail the specific steps an analyst
performs to carry out the procedure.
Therefore, a laboratory generally provides
this information by generating its own
detailed SOP. The one exception to this is SW-
846 methods for method-defined parameters
(MDPs). An MDP is a regulated parameter or
property whereby a particular method is the
only one that is capable of measuring the
property (e.g., SW-846 Method 1311, the Toxicity
On-Site Facility Operated Labs
On-site testing capabilities can be handy to
confirm the physical properties of received waste
are the same as the waste profile.
However, EPA strongly discourages facilities from
performing anything beyond fingerprint analyses
unless they have:
Comprehensive QA/QC program
Technical analytical expertise
Effective information management systems
Seeking third party accreditation may be a useful
means of ensuring your on-site laboratory has an
adequate QA/QC program.
Characteristic Leaching Procedure}.
Quantitative QA/QC Elements
Besides the qualitative measures (e.g., chain-of-custody procedures], quantitative
measures may also be used by the laboratory to monitor QA/QC. These measures include
analysis of method blanks, duplicates, matrix spikes, and surrogate spikes. Table 2-7
Laboratory QC Techniques presents major QC techniques used by most laboratories to
ensure data quality. A well-qualified laboratory will routinely employ these QA/QC
procedures to evaluate precision and accuracy of its analytical instrumentation to assess if
contamination has occurred, or if other factors exist which could affect data quality.
Technical Analytical Expertise
Laboratories may demonstrate technical analytical expertise by being proficient in using the
established EPA analytical methods for hazardous waste determinations and possessing
knowledge of any current developments in analytical methods that could affect data quality.
To ensure that the required information regarding waste composition is provided, a good
laboratory generally will have a working knowledge of the regulatory levels and prescribed
analytical methods for routinely analyzed contaminants (e.g., TC constituents}.
When selecting an analytical laboratory, you also may need to consider its ability to achieve
the detection limits (i.e., the lowest level of quantification possible for a given analyte]
that you request. Detection limits may need to be adequate to ensure sufficiently low levels
of parameter identification to meet prescribed regulatory or permitting thresholds.
Laboratories that are equipped with only limited or outdated analytical instrumentation
maybe incapable of meeting analytical requirements of the regulations.
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QC technique
Method Blank
TABLE 2-7: Laboratory QC Techniques
Purpose
Ensure that any contamination
resulting from analytical
equipment or process is identified.
Description
Method blanks are artificial samples, usually
comprised of distilled deionized water that are
submitted to the same laboratory preparation and
analytical processes as your samples. If any
contaminants are present in this artificial sample
after preparation and analysis, it can be inferred
that previous samples or laboratory practices
caused erroneous or biased results.
Performed at least once each
analytical batch with a minimum
of once per 20 samples.
Duplicates
(Laboratory)
Evaluate the precision of the
analytical process.
Two samples of the waste are obtained from one
sample container and both are subjected to the
same preparation and analysis.
Performed at least once with
each analytical batch with a
minimum of once per 20 samples.
Matrix Spike
Evaluate the efficiency, accuracy,
and precision, of the method being
employed to analyze the samples.
Compounds of interest are "spiked" (added) into the
samples prior to any preparation methods. The
recoveries of the spiked compounds are then used
to evaluate the efficiency of the method in detecting
the compounds of interest.
Performed at least once with
each analytical batch with a
minimum of once per 20 samples.
Surrogates Spikes
Evaluate the methods' efficiency
and accuracy.
Organic compounds which resemble the analytes of
interest in chemical composition, extraction
properties, and chromatographic properties. The
recovery of the surrogate spike is used to indicate
the effectiveness of the analytical process.
Performed at least once with
each analytical batch with a
minimum of once per 20 samples.
Laboratory Control
Spike or Blank Spike
Evaluate the methods' efficiency
and accuracy.
A sample of known analyte composition and
concentration that is used as a benchmark standard.
Performed at least once with
each analytical batch with a
minimum of once per 20 samples.
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Information Management
The laboratory will generally maintain effective information management systems. These
systems ensure the availability of all relevant data generated in association with a given
sample set (e.g., chain-of-custody records, accuracy and precision information, and
analytical results}. Additionally, the ability of a laboratory to produce clean and concise
analytical reports may be advantageous and help you in maintaining sample
documentation. A credible laboratory will generally work with you to tailor its reports to
meet your specific requirements. This may be helpful to ensure that you use the
information correctly to verify regulatory compliance or evaluate process performance.
The laboratory may also be able to provide the information needed to prove data validation
Third-Party Accreditation
Accreditation of environmental laboratories may be a useful indicator in determining if a
lab is capable of providing accurate and defensible analytical data. The most common types
of environmental laboratory accreditation programs include state programs and the
National Environmental Laboratory Accreditation Program (NELAP}. NELAP or a state
governmental agency can accredit a laboratory if that state is a NELAP recognized
Accreditation Body. Additionally, some states have their own laboratory certification
programs independent of NELAP. When determining if a laboratory is qualified to perform
the analyses you need, in addition to the criteria above, it may also be useful to ask if they
hold any accreditations. If so, you may inquire what type of accreditation they possess and
if the accreditation applies to the methods that you want them to perform. If you are not
familiar with the accreditation program, you may want to research the accreditation
requirements to determine if the program is rigorous enough.
TABLE 2-8: Important QA Elements
QA Element
Organizational structure and
management
What to look for..
The lab clearly defines the roles and responsibilities of all personnel.
Sample handling and tracking
procedures
The lab explains how samples and sample extracts are processed, identified,
stored, and retrieved. This will help to ensure that lab personnel do not
mistake one sample for another and analyze your samples within the
holding time.
Documentation procedures
The lab has comprehensive documentation procedures for all phases of
operation.
Internal audits
The laboratory performs internal audits on a regular basis. During an internal
audit, the laboratory will rigorously assess whether their lab is attaining its
objectives as stated in the LQM.
Proficiency testing
The laboratory regularly participates in a proficiency-testing program.
Proficiency-testing programs give labs a chance to evaluate its analytical
performance by testing unknown samples provided by a third party. The lab
tests the samples and reports the results to the third party who then
compares the lab's results with the actual results (known only to the third
party). The lab is then scored based on how they perform.
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2.6.2 Selecting Laboratory Analytical Methods
40 CFR 264/265.13(b) (2) require that
WAPs address test methods which will
be used to test for selected parameters.
To be useful in sustaining regulatory and permit
compliance, the WAP must specify testing and
analytical methods. The selection of an appropriate
methodology is dependent upon the following
considerations to provide reliable data to ensure safe and effective waste management:
Physical state of the sample (e.g., solid, liquid, or multi-phase]
Analytes of interest (e.g., volatile organics, metals]
Data Quality Objectives (e.g., needed detection limits, 1/5 to 1/2 of the regulatory
thresholds and precision and accuracy criteria]
Information requirements (e.g., verify compliance with LDR treatment standards].
Analytical methods consist of two distinct phases -- a preparation phase and a
determination phase and for some methods an intermediate step, sample cleanup. The use
of an appropriate combination of preparation, cleanup, and determination procedures may
ensure the accuracy of data generated from your facility waste management program.
Preparation Phase
Preparation methods are selected based upon a consideration of the factors presented
above and any special requirements associated with the type of analytical determination
being performed. These procedures are designed primarily to accomplish one or more of
the following:
Extract the analytes of interest from the sample matrix
Adjust physical properties (e.g., pH]
Facilitate chemical conversions necessary for analysis
Concentrate analytes to allow trace determinations.
Cleanup Phase
Some samples intended for organics analysis that are either highly contaminated or contain
extraneous contaminants that are capable of adversely affecting the analysis may require
an additional procedure, known as a cleanup step, during sample preparation. These
cleanup procedures remove potential interferences from the sample, thereby making it
more amenable to subsequent analysis. The most common organic chemical cleanup
procedures are florisil column, silica gel column, or gel permeation. The decision to
perform a cleanup step usually is made by the analytical laboratory and often involves
sophisticated technical judgments concerning sample composition, chemical interactions,
and specific analytical limitations. Therefore, this manual will only reference sample
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cleanup procedures that may be used. If more information is required on the application of
a particular cleanup method, the information can be obtained from SW-846.
Determination Phase
The application of a sample preparation method and, where required, a cleanup step, is
accompanied by an appropriate determination procedure specific to the analytes of interest.
Analytes are divided into classes (e.g., metals, volatile organic compounds], and for each
analytical class, a standard method has been developed to identify and quantify them. For
example, organic compounds are typically analyzed by gas chromatography (GC] or gas
chromatography-mass spectrometry (GC-MS), while metals are analyzed by atomic
absorption spectroscopy (AA], inductively coupled plasma-atomic emission spectroscopy
(ICP-AES], and inductively coupled plasma-mass spectroscopy (ICP-MS}. Due to the number
of available preparation and determination options, Figure 2-7 Analytical Method Selection
Flowchart is presented to facilitate the selection of the most appropriate preparation and
analytical methods to use when performing waste analysis. For both inorganic and organic
determinations, this figure provides SW-846 methods that may be employed in the analysis
of wastes for hazardous constituents (i.e., 40 CFR Part 261, Appendix VIII}.
Once you have identified the determinative method(s] for the analytes you want to
quantify, you may need to consider the sensitivity of the analysis. Analytical sensitivity is
the smallest concentration of a substance that can be reliably measured by a given
analytical method. Analytical sensitivities for the same method and analytes can vary
greatly between laboratories and even between different instruments at the same lab with
different operating conditions.
The Detection Limit
A common measure of laboratory analytical
sensitivity is the detection limit.
The detection limit is the lowest amount of an
analyte that a particular laboratory can determine
for a specific method and sample matrix.
A good laboratory will analyze a calibration
standard containing the analytes at
concentrations equal to the detection limit to
demonstrate good recovery at these levels.
It is important to communicate your data
needs to your laboratory before having them
analyze your samples. The lab may be able to
suggest an alternate method of analysis or
may be able to make simple changes in the
preparation of the sample to achieve the
needed sensitivity. In particular, you may
want to ask the lab what their detection limits
are for the analytes and methods you want
them to analyze. The detection limit is the
lowest value that a laboratory reports for a
given analyte and is a reflection of the
analytical sensitivity. For example, if you want to know if your sample contains 5 mg/L
(ppm} lead and the lab can only detect to 10 mg/L, the analysis is not sensitive enough to
meet your needs. Also, since you rarely have complete confidence that your analytical data
are perfect (e.g., due to the non-homogeneity of most wastes, etc.], the detection limits may
need to be well below the RCRA regulatory levels. Low detection limits are also helpful
when determining the confidence level of your data and calculating re-evaluation
frequencies for each wastestream (discussed in Sections 2.7 and 2.8, respectively}. Lower
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detection limits below the regulatory level, may be required to ascertain waste variability
and calculate a confidence level.
FIGURE 2-7: Analytical Methods Selection Flowchart
SAMPLE*
±.
\
Aqueous
3010
Solids
3050
Analytical Determination
Organic
Organic
Analysis
Semi-
\
Volatile
Volatile
Aqueous
351 0/
3520
Solid
3540 /
3550
Oils
3580
Sludge
3520
ctively
jpled
sma
lysis
)10
I
ICP/MS
6020
Arsenic
7062/7063
I
Atomic
Absorption
Analysis
7000 Series
Flame &
Furnace
Chromium VI
7196/7197
IsSai
Clea
Need
Yes
nple
nup
ed?
Wo
1
SAMPLE CLEANUP
Alumina Column 3610
Alumina for Petroleum 361 1
Florisil Column 3620
Silica Gel column
Gel Permeation
Acid Base Partitioning
Sulfur
3630
3640
3650
3660
SulfuricAcid/Permangenate 3665
_L
GC/MS
Analysis
8270
GC ANALYSIS:
Phthalate Esters 8061
Organochlorine Pesticides 8081
Polychlorinated Biphenyls 8082
Polynuclear Aromatic Hydrocarbons 8101
Chlorinated Hydrocarbons 8121
Organophosphorous Pesticides 8141
Chlorinated Herbicides 8151
GC ANALYSIS:
Nonhalogenated Volatile Organics 8015
Aromatic & Halogenated Volatile Organics 8021
Acrylonotrile 8031
Acetonitrile 8033
"Sample refers to the actual waste or a leachate of the waste as required TCLP (SW-846 1311).
The methods referenced in the above figure are from SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods, Update IV. SW-846 methods are updated frequently. Please consult the current SW-846 Online for any subsequent
method updates or changes before selecting testing methods, http://www.epa.aov/osw/hazard/testmethods/sw846/online/
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Data Reporting
The owner/operator of each facility is required to track hazardous waste activity and maintain this
information in the operating record until the facility closes. A key component of the operating record is
maintaining all waste analytical results. The facility may want to not only maintain the actual analytical
results but also all information necessary to reconstruct the history of each sample so that the associated
data may be understood through the documentation.
This information includes but is not limited to:
All waste analytical results with the date of analysis, the lab sample ID, and corresponding manifest
number clearly identified.
All associated QC sample results.
Waste sample tracking information, including internal tracking documentation for samples analyzed on-
site and Chain-of-Custody documentation for waste samples sent offsite for analysis.
In addition, for facilities conducting waste analysis:
All raw data for each analysis (e.g., instrument readings and printouts, sample preparation and cleanup
protocols, sample weights, etc.).
Calibration records to include calibration criteria and the frequency at which the calibration is performed.
Standard operating procedures (SOPs) that accurately reflect current laboratory activities.
All performance standard and QC samples results and acceptance criteria (e.g., calibration standards,
blanks, reference samples, etc.).
Instrument maintenance and repair records.
40 CFR 264/265.13 do not specify
the method of quantifying data
uncertainty as described in
Section 2.7. However, facilities
should use methods for
quantifying data uncertainty that
result in an effective basis for
decision-making.
2.7 Quantifying Data Uncertainty
As part of the waste analysis process, you use your data to
make a decision and determine if the data is capable of
supporting that decision. For example, you analyze a
waste for organic halogens to determine if it is a candidate
for incineration and contains less than 500 ppm of organic
halogens. The decision you need to make is whether to
incinerate the waste and this is dependent on the organic
halogen concentration. At first glance, it would make
sense to use 500 ppm as your action level. An action level
is simply a value that causes the decision maker to choose between different alternatives.
That is, you would decide to incinerate the waste if the organic halogen result is less than
500 ppm but would not if the result is 500 ppm or greater. The problem with this approach
is that you rarely have complete confidence that your analytical data are correct due to the
non-homogeneity of most wastes and slight differences in how you handle, sample, and
analyze the waste. This creates a degree of uncertainty in what seems like a simple yes or
no decision. Even when your analytical result is lower than an action level, the uncertainty
may result in some possibility that the true concentration in the waste is actually higher
than the action level, especially if the analytical result is nearing the action level. This will
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vary by situation and may need to be determined by considering the consequences for
making a wrong decision (e.g., determine a waste is not hazardous when it is hazardous}.
The consequences of incinerating waste with elevated levels of organic halogens are
extensive and include potential damage to the incinerator, regulatory penalties for non-
compliance, and adverse impacts on public health. Due to the significance of the
consequences, you will likely want to minimize uncertainty that the true organic halogen
concentration is greater than 500 ppm to justify a decision to incinerate the waste even
when the analytical results are less than 500 ppm. This may be accomplished by
establishing a confidence level for the data. A confidence level indicates the degree of
certainty in the data in terms of a percent. For example, data meeting a 90% confidence level
can be interpreted that it is 90% certain (10% uncertain] that the true organic halogen
concentration is below 500 ppm. To apply a specific confidence level to your data, you need
to determine confidence limits statistically. Confidence limits are the upper and lower limits
that your data need to fall within to meet a specific confidence level. Since most action levels
will be based on regulatory standards or permitted concentrations/feedrates that must not
be exceeded (or equaled], the upper confidence limit is calculated. If all analytical results are
below, for example, an upper confidence limit of 90% then we can say we are 90% certain
that the true concentration of organic halogens in the waste is below 500 ppm.
It is easier to demonstrate to regulators that your facility has made a good faith
effort to characterize a waste, even if the characterization is found to be in error, if
you have data with a confidence level of 90% or above (less than a 10% statistical
probability of being wrong).
You can determine the 90% confidence limit if your data are normally distributed using the
method presented here. If you do not have normally distributed results, you may still
determine confidence limits for your data but you will need to use a different
statistical method. See the example on the next page and consult the references below for
additional information.
US EPA RCRA Waste Sampling Draft Technical Guidance, EPA 530-D-02-002, 2002.
http://www.epa.gov/epawaste/hazard/testmethods/sw846/samp guid.htm
Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous
Waste Sites, U.S. Environmental Protection Agency, OSWER 9285.6-10. December 2002.
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Calculating the 90% Upper Confidence Limit (UCL)
Assume we received the following set of analytical data for the sample discussed above:
Organic Halogen Results
Composite Sample A: 410 ppm
Composite Sample B: 427 ppm
Composite Sample C: 424 ppm
Since the data are normally distributed*, the upper bound of the 90% confidence level may be calculated in the
following manner:
STEP 1: Calculate the sample mean:
Where, A, B, and C are the individual sample results and n is the number of sample results.
Sample Mean = (A + B + C)/n
Sample Mean = (410 + 427 + 424)/ 3 = 420
STEP 2: Compute the sample standard deviation"1:
Standard Deviation = 9.07
STEP 3: Use the Critical Values of Student's t Distribution table to look up the value of t*:
t Value = 1.886
STEP 4: Calculate the 90% Upper Confidence Limit:
90% UCL = Sample Mean + (T Value x Standard Deviation/Vn)
90% UCL = 420 + (1.886 X 9.07/^3) = 429**
The upper bound 90% confidence limit of the analytical results (429 ppm) was below the action limit of 500
ppm. The data sufficiently demonstrates that the waste is acceptable for incineration
*For simplicity in the example above, we have used sample results that are normally distributed and have not
presented the full calculations for determining the standard deviation calculate or given an explanation of
how to look up the "t" value using Critical values of Student's t Distribution table. If your sample results are
not normally distributed, you may need to apply different statistical techniques or you do not know how to
calculate the standard deviation or use the t- table. Please see the references listed at the end of the section
for more information.
** US EPA Office of Emergency and Remedial Response, Calculating Upper Confidence Limits for Exposure Point
Concentrations at Hazardous Waste Sites, OSWER 9285.6-10, December 2002.
http://www.epa.gov/oswer/riskassessment/pdf/ucl.pdf
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2.8 Determining Re-Evaluation Frequencies
As discussed in Section 2.5.1 Sampling Strategies and Sampling Frequencies, RCRA
regulations clearly stipulate some specific circumstances when waste should be re-
evaluated, including:
When the TSDF is notified, or has reason to believe
that the process or operation generating the
hazardous wastes has changed [40 CFR §264/
,,-, -,rT-,r.-,n waste re-evalutation frequencies
265.13(a](3](i]l. . fti. .
*- J^ J^ JJ are left to owner/operator
When the results of the TSDF's fingerprinting does Judgement. Section 2.8
recommends an approach for
40 CFR 264/265.13 specify waste
re-evaluation frequencies in certain
situations. In other situations,
determining re-evaluation
frequencies when owner/operator
judgement is needed.
not match the waste on the accompanying manifest or
shipping paper (the generator may be requested to
re-evaluate the waste] [40 CFR §264/265.13(a]
(3}(ii}]. Off-site combustion facilities may need to
characterize all wastes prior to burning to verify that permit conditions will be met (i.e.,
fingerprint analysis may not be acceptable]
Additionally, an off-site facility must inspect and, if necessary, analyze each hazardous
waste movement received to determine if it matches the identity of the waste specified
on the accompanying manifest or shipping paper. [40 CFR§ §264/265.13(a] (4}]
RCRA regulations do not specify, however, when it comes to the re-evaluation of waste that
does not fit into the above categories. RCRA simply states, "waste analysis must be
repeated as often as necessary to ensure that it is accurate and up to date. "[CFR
§§264/265.13(a}(3}]. In your WAP, you should identify how you will determine re-
evaluation frequencies to ensure data accuracy.
It may be helpful to take a tiered approach to waste re-evaluation. That is, you may want to
conduct a thorough initial characterization of each waste and then slowly reduce the
frequency of re-evaluation over time with each subsequent shipment as long as the
hazardous constituents are safely below the action level. For example, if a site generates a
new waste stream during its manufacturing process, it may be a good idea to analyze
samples from multiple batches during initial characterization of the waste. This
could result in a better sense of waste variability. This is important, as the waste
handler may use the data from this initial shipment as a baseline to evaluate data from the
subsequent shipments. There are also a number of ways to use historic waste data to
determine re-evaluation frequencies. The method described in the paragraph below
demonstrates one possible approach. You do not need to use this specific approach but you
should state in your WAP how you will determine re-evaluation frequencies based on
waste data.
In this example approach, you compare the average of the previous and current waste
analysis results and then base the re-evaluation frequency on the relative percent difference
(RPD) of this value and the action level. This method necessitates that your facility keep
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accurate data records so that previous data is accessible for comparison to current data.
Ideally, you would have access to all data starting from the initial characterization to the
present. You might evaluate the data in two ways. First, you might verify that none of the
sample results exceed the action level. If the data do not exceed the action level in the initial
characterization but did exceed the action level in the subsequent shipment, you may want to
leave the re-evaluation frequency at 100%. Second, assuming the data did not exceed the
action level, you could calculate the average of the previous results and calculate the RPD
between this value and the action level. Finally, you could determine the re-evaluation
frequency based on a fixed schedule like the one used in the examples below and presented
in Table 2-9 for shipments of waste received at least monthly:
The following are two examples of how you may want to determine re-evaluation
frequencies using historic data for a wastestream.
Determine Re-Evaluation Frequencies Using Historic Data - Example A
Assume that you received the following data from the initial characterization and first re-evaluation of a waste
containing toxaphene. Data from the initial characterization and subsequent shipment are provided below:
Initial Characterization Results (1st Shipment)
Batch Average (XI): 0.44 mg/L
Note: No single result exceeded the action level (L) for toxaphene of 0.50 mg/L.
Re-Evaluation Result (2nd Shipment)
ResuIt (X2): 0.40 mg/L
Number of Shipments (n) = 2
Average of Shipments (A):
= (XI + X2)/n
= (0.44 + 0.40)/2 = 0.42 mg/L
Relative Percent Difference (Shipment Average and Action Level):
= (L-A)/((L+A)/2) X100
= (0.50-0.42)/((0.50+0.42)/2) X 100 = (0.08/0.46) X 100 = 17.4%
Re-evaluate the waste quarterly since RPD = 17%
Once quarterly data is collected, recalculate the average using all three sets of data and determine the RPD
between the new average and the action level.
Adjust the re-evaluation frequency as needed based on the new RPD.
Please note, it may be advisable to consult a statistician if you are uncertain as to the choice of an appropriate
parameter, limit, etc.
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TABLE 2-9: Re-Evaluation Frequencies
If the average is:
Within 10% of the action level (RPD < 10%)
Recharacterize each shipment
Between 10 and 25% of the action level (RPD >10% but < 25%)
Recharacterize quarterly
Between 25 and 50% of the action level (RPD > 25% but < 50%)
Recharacterize semi-annually
Greater than 50% of the action level (RPD > 50%)
Recharacterize annually
Determine Re-Evaluation Frequencies Using Historical Data -Example B
Assume that you received the following data from the initial characterization and subsequent re-
evaluations of a waste containing arsenic. Data from the initial characterization and subsequent shipments
are provided below:
Initial Characterization Results (1st Shipment)
Average of Batch Results (XI): 4.7 mg/L
Note: No single result was above the action level (L) of 5.0 mg/L
Re-Evaluation Result (2nd Shipment)
Result(X2):4.8mg/L
Re-Evaluation Result (3rd Shipment)
Result(X3):4.3mg/L
Number of Shipments (n) = 3
Average of Shipments (A):
= (XI + X2 + X3)/n
= (4.7 + 4.8 + 4.3)/3 = 4.6 mg/L
Relative Percent Difference (Shipment Average and Action Level):
= (L-A)/((L+A)/2) X 100
= (5.0 - 4.6)/((5.0 + 4.6)/2) X 100 = (0.4/4.8) X 100 = 8%
Re-evaluate each shipment, as RPD is 8%
Once data for the next shipment is collected, recalculate the average using all four sets of data and
determine the RPD between the new average and the action level.
Adjust the re-evaluation frequency as needed based on the new RPD.
Please note, it may be advisable to consult a statistician if you are uncertain as to the choice of an
appropriate parameter, limit, etc.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.9 Special Procedural Requirements
2.9.1 Procedures for Receiving Wastes Generated Off-Site
40 CFR 264/265.13(c) require WAPs to
specify procedures which will be used to
inspect and, if neccesary, analyze each
movement of hazardous waste received at
the facility to ensure that it matches the
manifest. Sections 2.9.land 2.9.2 address
some of these procedures, as specifed.
Off-site hazardous waste management facilities
may be required to comply with regulations
regarding screening and analysis to ensure that
the facility does not accept incorrectly identified
or unacceptable waste shipments. The off-site
facility's WAP must specify the waste analysis
data that the generator of the waste shall provide
to substantiate its waste determination [40 CFR
§§264/265.13(c}]. It is important the WAP include descriptions of the procedures to be
taken by the TSDF to determine how well the generator's data represents the wastes to be
managed. The TSDF should determine whether recharacterization of the waste is necessary
if a shipment of a particular waste is determined, for example, through pre-acceptance
screening, to be significantly different from the waste as characterized and identified from
the pre-shipment sample and/or waste manifest. These procedures and waste
recharacterization procedures must be specified in the WAP [40 CFR §§264/265.13(c}].
Alternatively, the owner/operator may reject the entire shipment of waste and return the
waste to the generating facility.
An off-site facility may be required, at a minimum, to visually inspect and compare the
contents of each shipment to the accompanying manifest to identify the wastes. The
shipment received on-site may need be sampled and analyzed to the extent necessary to
verify that it meets permit specifications and regulatory requirements. Some off-site
facilities accomplish this by performing a systematic process of screening and analysis that
allows for monitoring key indicator parameters. In some cases, however, more stringent
waste analysis may be required. Figure 2-8 Shipment Screening provides a methodology
that can be used to screen waste shipments.
Shipment screening is especially necessary for off-site facilities given the variety of wastes
typically managed. The level of screening that may be required for an off-site facility is a
function of the facility operator's knowledge about the generation process. Therefore, it
may be advantageous for off-site facilities to require the generator to provide detailed
information regarding:
The process that generates the waste
The physical and chemical description of the waste
The analytical procedures and results used to characterize the waste or acceptable
knowledge documentation
EPA hazardous waste codes
Certifications and notifications as applicable to LDR wastes.
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As discussed in Section 1.1, as a pre-acceptance procedure, most commercial TSDFs will
require that the generator provide this information in the form of a Waste Profile Sheet
(WPS}. An example of a WPS is provided in Figure 2-9 at the end of Part Two.
FIGURE 2-8: Shipment Screening
Waste Shipment Arrives
I
Compare Shipment
Externally to Its Manifest
I
Visually Inspect Shipment
I
Sample Waste
±
Analyze Waste for Key
Parameters and Compliance
with Part 268 Treatment
Standards, If Applicable
Evaluate Analytical Data
Accept Waste Shipment
(TSDF is Ultimately
Responsible for Accepting
Waste)
Discrepancy
Contact Generator
Discrepancy
Contact Generator
Reject Waste
Shipment
Recharacterize Waste
(TSDF or Generator)
I
Evaluate Analytical Data
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The off-site facility may need to determine procedures for conducting full waste
recharacterization if the waste received is significantly different from the waste
characterized and identified during pre-acceptance procedures. These procedures for
waste recharacterization should be detailed in the WAP. Alternatively, the owner/operator
of the off-site facility may reject the entire shipment of waste back to the generator.
2.9.2 Procedures for Combustion Facilities
As discussed in Section 2.4.4 (Hazardous Waste Combustion], hazardous waste
incinerators, cement kilns, lightweight aggregate kilns, boilers, and hydrochloric acid
production furnaces are subject to applicable regulatory requirements pursuant to both the
RCRA program and the CAA NESHAP program. A RCRA WAP continues to be a required
component of the RCRA permit for all HWCs; however, the combustor-specific feedstream
analysis requirements that ensure compliance with CAA HWC NESHAP emission standards
and (feedstream related] operating requirements are found in the feedstream analysis plan
(FAP] and now reside in the CAA HWC NESHAP (40 CRF Part 63 subpart EEE]. There may
be limited cases where a RCRA WAP continues to contain combustor-specific feedstream
analysis requirements,12 but for many HWCs, the RCRA WAP and the CAA HWC NESHAP
FAP (or CAA FAP] are maintained as separate documents in separate programs. This does
not imply however, that the two documents are exclusive of one another.
Specific to HWCs, the RCRA WAP serves to, among other things, identify the incoming
waste and screen out wastes that are prohibited (e.g. metal-bearing wastes prohibited from
dilution per Appendix XI to 40 CFR Part 268, radioactive wastes, reactive/explosive wastes,
etc.] from going to the combustion unit. The CAA FAP focuses on the waste before being
fed to the combustor to ensure that the feedstream is adequately characterized and the
concentration of feedrate-limited pollutants (e.g., chlorine] in the feedstream are known.
This allows for corrective action to be taken if monitored emissions are approaching non-
compliance with CAA HWC NESHAP emission standards and other feedstream related
operating requirements. Thus, the CAA FAP can be thought of as a subset of the RCRA
WAP, since the incoming waste affects what is ultimately combusted. The key point is that
the RCRA WAP and the CAA FAP should complement one another to ensure safe handling
of the waste and the efficient operation of the HWC.
State and EPA Regional offices vary in organizational structure and program responsibility
for implementing the CAA HWC NESHAP. The potential for regulatory overlap, or even
oversight, for HWCs exists due, in part, to applicable requirements under both RCRA and the
CAA. This can be especially true for the RCRA WAP and CAA FAP requirements. It is
important to emphasize that, in most cases, it is not appropriate for the RCRA WAP to simply
12 A RCRA WAP may retain some of the combustor-specific feedstream analysis requirements where: (1) pursuant
to RCRA omnibus authority, the RCRA permit writer required emission and (emission related) operating
requirements that are more stringent than the CAA MACT requirements (such as a limitation on mercury emissions
and feedrate); or (2) a HWC elects to comply with one of the RCRA options in 40 CFR §270.235 for startup,
shutdown, and malfunction; or (3) area source boilers and HCI production furnaces elect to comply with certain
RCRA emission standards in lieu of the full suite of MACT standards.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
reference the CAA FAP requirements, and not include details in its RCRA WAP regarding
waste analysis procedures used to ensure compliance with the RCRA requirements. The
opposite is also true. In most cases, it is not appropriate for the CAA FAP to simply reference
the RCRA WAP requirements and not include details in its CAA FAP about feedstream
analysis procedures used to ensure compliance with the CAA requirements. Each program
has its own set of regulatory requirements for waste analysis that are applicable to
HWCs. In some cases, a permit authority and HWC may agree to combine the RCRA WAP
and the CAA FAP requirements into one document. This may be preferred for when, for
example, the RCRA program has retained authority for reviewing and determining
compliance with the CAA HWC NESHAP. Regardless of the approach taken, it is strongly
encouraged for permit officials from both programs, along with their HWC facilities, to work
together to coordinate the RCRA WAP and CAA FAP requirements. (See the discussion of
hazardous waste combustors in Appendix D of this manual for a crosswalk table which
highlights the similarities between the RCRA WAP and CAA FAP and identifies sections of
this manual that may be of assistance in developing a CAA FAP.}
Despite the fact that the regulatory requirements for sampling and analysis of the
combustion unit feedstream are primarily now under the CAA HWC NESHAP, many of the
concepts in this guidance can still be useful and applied as needed to both the RCRA WAP
and CAA FAP for a HWC. One example is sampling frequency. The regulatory requirement
under the CAA HWC NESHAP at 40 CFR 63.1209(c)(2)(vi) is nearly identical to the
requirement under RCRA at 40 CFR §264.13. Therefore, the regulated community and
permit officials may wish to review the discussion in this guidance to assist in determining
how often a HWC feedstream should be sampled and analyzed.
The regulatory requirements for a CAA FAP are at 40 CFR §63.1209(c}. This section
currently states that:
(c) Analysis offeedstreams(1) General. Prior to feeding the material, you must obtain an analysis of
each feedstream that is sufficient to document compliance with the applicable feedrate limits
provided by this section.
(2) Feedstream analysis plan. You must develop and implement a feedstream analysis plan and record
it in the operating record. The plan must specify at a minimum:
(i) The parameters for which you will analyze each feedstream to ensure compliance with the
operating parameter limits of this section;
pi) Whether you will obtain the analysis by performing sampling and analysis or by other methods,
such as using analytical information obtained from others or using other published or documented
data or information;
(iii) How you will use the analysis to document compliance with applicable feedrate limits (e.g., if you
blend hazardous wastes and obtain analyses of the wastes prior to blending but not of the blended,
as-fired, waste, the plan must describe how you will determine the pertinent parameters of the
blended waste);
(iv) The test methods which you will use to obtain the analyses;
(v) The sampling method which you will use to obtain a representative sample of each feedstream to
be analyzed using sampling methods described in appendix IX, part 266 of this chapter, or an
equivalent method; and
(vi) The frequency with which you will review or repeat the initial analysis of the feedstream to
ensure that the analysis is accurate and up to date.
(3) Review and approval of analysis plan. You must submit the feedstream analysis plan to the
Administrator for review and approval, if requested.
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(4) Compliance withfeedrate limits. To comply with the applicable feedrate limits of this section, you
must monitor and record feedrates as follows:
(i) Determine and record the value of the parameter for each feedstream by sampling and analysis or
other method;
(if) Determine and record the mass or volume flowrate of each feedstream by a CMS. If you
determine flowrate of a feedstream by volume, you must determine and record the density of the
feedstream by sampling and analysis (unless you report the constituent concentration in units of
weight per unit volume (e.g., mg/rj); and
(iii) Calculate and record the mass feedrate of the parameter per unit time.
(5) Waiver of monitoring of constituents in certain feedstreams. You are not required to monitor levels
of metals or chlorine in the following feedstreams to document compliance with the feedrate limits
under this section provided that you document in the comprehensive performance test plan the
expected levels of the constituent in the feedstream and account for those assumed feedrate levels in
documenting compliance with feedrate limits: natural gas, process air, and feedstreams from vapor
recovery systems.
To summarize, feedstream sampling and analysis protocols (e.g., sampling frequency, sample
size, sample analytical procedure and analytical constituents] to comply with applicable
feedrate limits must be outlined in detail in the HWC's CAA FAP and recorded in the
operating record.13 These characterization protocols are site-specific and waste-specific.
Determination of feedstream sampling frequency may depend on considerations such as:
(1} trends in historical waste data (waste variability}; (2} confidence and extent of
knowledge of process; (3} potential for changes in waste composition; (4} expected
hazardous air pollutant (HAP] levels in the feedstream; and so forth. Periodic sampling is
required for all feedstreams to ensure the analysis is accurate and up to date,
however, the actual frequency will be site-specific.
Characterization of waste streams based on acceptable may be permitted on a site-specific
basis when it can be demonstrated that knowledge is sufficiently accurate to ensure: (1} the
waste can be safely handled at the treatment facility; and (2} the treatment facility is
complying with its applicable feedrate and emission limitations.14 For well-known and well-
characterized wastes that exhibit little historical variation in composition, the sampling and
analysis frequency would be lower. "One-time only" sampling and analysis likely would be
appropriate only for very select cases. An example would be where the composition of the
waste is very well known and/or changes in waste composition are not possible. Even in
such cases, procedures should be in place to monitor for changes in composition.
In cases where it is dangerous, impractical, or unnecessary to use direct sampling and
analysis, characterization based on knowledge should be used to the fullest extent possible.
Materials that are considered dangerous can pose extraordinary health, safety or
environmental hazards. Examples of dangerous materials can include those that are
extremely toxic or reactive, sharps, and biological wastes. It can also be impractical and/or
unnecessary to directly sample, or obtain a representative sample of the waste because of
13 Again, it may be possible to combine both RCRA WAP and CAA FAP requirements into one document. However,
14 Generator or process knowledge can encompass a variety of sources such as analytical information, product
the FAP requirements must be recorded in the HWC's operating record.
14 Generator or process knowledge can encompass a variety of source
label information, safety data sheets, and manufacturer information.
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the physical nature of the waste, or because the composition of the wastes are known.
Examples of impractical (or unnecessary] materials can include lab packs and lab wastes,
"RCRA" empty used containers, cylinders, aerosols, household hazardous wastes, mixed
Pharmaceuticals, and unused commercial products/chemicals.
Use of knowledge alone is not always appropriate. This is especially true for waste streams
that come from multiple generators. These waste streams tend to be highly variable and
are received by off-site or commercial HWCs. Analyses of representative samples are
necessary to generate a detailed profile of the chemical and physical characteristics of the
waste for compliance with applicable feedrate limits. Therefore, the frequency of analysis
is often higher at off-site HWCs relative to on-site HWCs who can often rely on knowledge
and minimal sampling and analysis.
The selection of parameters to be analyzed in the feedstream will vary according to the
type of HWC, alternate mode(s] of operation, and the wastes received. Parameters for
HWCs can include ash content, total chlorine, mercury, total metals (combination of semi-
volatile and low-volatile metals], heat of combustion, and total halogen. A typical
feedstream analysis scenario may include a prequalification analysis (prior to processing],
a fuel blending analysis (to inform fuel blending decisions], and batch analysis
(representative samples of blended waste for each burn tank or batch].
2.9.3 Procedures for Ignitable, Reactive, and Incompatible Waste
WAPs for all facilities must include provisions to ensure
that waste management units meet the special
requirements for ignitable, reactive, and incompatible
wastes [40 CFR §§264/265.17]. Incompatible wastes, if
40 CFR 264/265.13(b)(6) require
WAPs, where applicable, to specify
the methods that will be used to
brought together, may result in heat generation, toxic meet the waste analysis
requirements for ignitable, reactive,
and incompatible waste at
§§264/265.17.
gas generation, and/or explosions. Therefore, a WAP
must address measures to identify potentially ignitable,
reactive, and incompatible wastes. The information
provided by the waste manifest and fingerprint testing can be supplemented with other
testing to identify incompatible wastes. Standard tests to identify ignitable, corrosive, and
toxic wastes are contained in Chapter 8 of SW-846. You should identify reactive wastes as
such if they exhibit at least one of the eight properties identified in 40 CFR § 261.23. As EPA
does not currently have a set of approved methods for determining reactivity, generators
will need to use waste acceptable knowledge to determine if their waste exhibits the
characteristic of reactivity. Finally, waste compatibility determinations can serve to
establish compatibility between wastes of interest for a given process. An EPA document,
"A Method of Determining the Compatibility of Hazardous Wastes" (EPA-600/2-80-076]
[This document can be obtained from the National Technical Information Service (NTIS]
(Document No. PB-80221005]] contains procedures to evaluate qualitatively the
compatibility of various categories of wastes.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.9.4 Procedures for Complying with LDR Requirements
40 CFR 264/265.13(b)(6) require
WAPs, where applicable, to specify
the methods that will be used to
meet the waste analysis
requirements for the LDR program
at §268.7.
Generators and TSDFs have special waste analysis
requirements under the LDR program. Regulations in
40 CFR §268.7 require generators and TSDFs to conduct
waste analysis to determine the regulatory status of
wastes with respect to the treatment standards in 40
CFR Part 268, Subpart D. Generally, hazardous wastes
must meet applicable treatment standards prior to land
disposal. These treatment standards are expressed in two ways: as constituent
concentrations in the waste (either an extract of the waste as determined by the TCLP, or in
the total volume of the waste referred to as a total waste analysis] or as specified treatment
technologies. Wastes with concentration-based treatment standards must be evaluated to
determine if applicable constituent concentration levels have been attained. This can be
accomplished by applying waste analysis procedures as either (1} testing the waste, or (2}
using knowledge of the process or materials used to produce the waste (for generators
only}. For acceptable knowledge, this knowledge should be supplemented with analytical
data on the regulated constituents.
For treatment standards expressed as concentrations in the waste extract [40 CFR
§§268.40], the TCLP (EPA SW-846 Method 1311} must be employed, except as noted in the
rules, to obtain an extract of the waste [there are certain exceptions where Method 1310,
the Extraction Procedure Toxicity Test, can be used as an alternative for certain arsenic-
and lead-containing waste codes listed in 40 CFR §268.40(a}]. The extract will then be
tested subsequently for the specific constituents associated with the treatment standard.
Treatment standards based on total waste concentrations in 40 CFR §268.40 should use an
appropriate total waste analysis procedure for its respective constituents. Please note that
many wastes have treatment standards expressed as both extract concentrations and total
waste concentrations.
For wastes with treatment standards expressed as specified technologies in 40 CFR
§268.42, and for hazardous debris treated to meet the alternative debris treatment
standards in 40 CFR §268.45, verification through analysis is not necessary. Instead,
compliance with these treatment standards should be documented in the facility operating
record to verify that the appropriate treatment technologies have been employed prior to
land disposal.
2.10 Discrepancy Policy
Two types of discrepancies that can arise during
waste acceptance include 1} manifest discrepancies
and 2} discrepancies between the incoming waste
shipment and its profile. Therefore, it may be a
good idea for the facility to state its discrepancy
policy and include detailed procedures in the WAP
40 CFR 264/265.13 do not require WAPs to
include discrepancy policies or procedures.
However, this guidance recommends that
such policies and procedures be
established and described in the WAP.
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for handling both types of discrepancies promptly and effectively. Discrepancies generally
indicate that an error has occurred in analyzing and/or describing the waste and that
corrective and preventative action measures may be needed to prevent its re-occurrence.
Facility personnel may also need to decide whether to accept or reject the waste. Because of
this, it is advisable for the facility's discrepancy policy to be coordinated with its rejection
policy discussed in Section 2.11.
2.10.1 Manifest Discrepancies
40 CFR §§264/265.72 defines manifest discrepancies as:
Significant differences between the quantity or type of hazardous waste designated on
the manifest or shipping paper, and the quantity and type of hazardous waste a facility
actually receives. Significant differences in quantity are, for bulk waste, variations
greater than 10 percent in weight, for batch waste, any variation in piece count, such as
a discrepancy of one drum in a truckload. Significant differences 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.
Rejected wastes, which may be a full or partial shipment of hazardous waste that the
TSDF cannot accept; or
Container residues, which are residues that exceed the quantity limits for "empty"
containers set forth in 40 CFR §261.7(b}.
The facility's policies should be consistent with the requirements of 40 CFR §§264/265.72,
as applicable. For example, upon discovering a significant difference in quantity or type, the
facility may need to attempt to reconcile the discrepancy with the waste generator or
transporter (e.g., with telephone conversations}. If the discrepancy is not resolved within
15 days after receiving the waste, the facility must immediately submit to EPA or the
authorized state a letter describing the discrepancy and attempts to reconcile it, and a copy
of the manifest or shipping paper at issue.
The facility needs to decide if the waste can be accepted despite the discrepancy. This
involves a determination whether the facility can manage the waste on-site in a manner
that is safe, effective and in accordance with the provisions of its permit. If the waste
cannot be accepted, the facility may need to reject it in accordance with its rejection policy.
In addition, the facility may need to evaluate whether the manifest discrepancy reflects a
deeper issue than simply a clerical error (e.g., has the generator's waste changed since pre-
acceptance?}. If a deeper problem is suspected, the facility may need to re-evaluate the
waste profile to determine if a new or revised profile is necessary. This could involve
sending the waste profile to the generator for re-evaluation and re-certification. For these
deeper issues, the generator may need to prepare a corrective action plan describing the
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issue and how it will be prevented in the future. The facility may also want to maintain
records of each manifest discrepancy.
2.10.2 Discrepancies Between Incoming Waste and Profile
Some Consideration for the Facility
The facility may need to perform a
"discrepancy review" whenever the
waste acceptance testing shows an
unacceptably high variance (trigger level
to be negotiated with the permit agency)
from the waste profile data (e.g., for BTU
value, require a discrepancy review if the
Btu value varies more than 15%).
As discussed elsewhere in this guidance (e.g.,
Section 1.2], the facility may need to closely
compare each incoming waste to its waste profile to
ensure it is receiving the waste that had originally
been approved during pre-acceptance. It is common
for a generator's commercial processes to change,
thereby resulting in a new or modified waste
stream. New wastes, as well as modified waste
streams that no longer meet the waste profile, may
need to be subject to pre-acceptance, so that the
facility can consider whether it can manage the waste safely and effectively.
During acceptance, facility personnel may need to perform visual inspections of opened
containers (e.g., to confirm basic physical properties, such as color and waste form] and
chemical screenings as necessary to determine if new and/or modified wastes have been
shipped to their facility. The chemical screenings may need to include one or more
parameters with a tolerance limit (e.g., pH limits}. A discrepancy occurs if the waste falls
outside the range or otherwise does not match other aspects of its profile.
The facility's policy on discrepancies may also need to detail the facility's actions for
addressing it. For example, the facility may need to attempt to resolve the discrepancy by
calling the generator and requesting additional information. The facility will need to decide
whether to accept or reject the waste despite the discrepancy. This involves a
determination whether the facility can manage the waste on-site in a manner that is safe,
effective and in accordance with the provisions of its permit. The policy may also need to
indicate how long the waste will be kept on-site pending a decision (unlike manifest
discrepancies, the federal regulations do not specify a time limit for discrepancies related
to waste profiles}.
If a decision is made to reject the waste, the facility would then follow the procedures of
its rejection policy. If the waste is not rejected and the discrepancy cannot be resolved,
the facility may want to perform a comprehensive analysis of the waste. The results will
help to determine if it is a new or modified waste. If it is newly generated or modified, a
new or revised waste profile may be needed. In all cases, the generator may need to be
asked to submit a corrective action plan that describes the reason for the discrepancy
and actions to be taken to prevent re-occurrence. The facility should maintain records of
each discrepancy.
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40 CFR 264/265.13 do not
require WAPs to include
rejection policies or
procedures. However, this
guidance recommends that
such policies and
procedures be established
and described in the WAP.
2.11 Rejection Policy
It may be advisable for a facility to have a rejection policy
that is closely coordinated with its discrepancy policy
because some discrepancies may lead to rejection. The policy
also should ensure that all applicable federal and state
requirements for rejections (e.g., 40 CFR §264.72} are
followed. For example, the policy should specify that the
facility will obtain or confirm the generator's directions on
where to forward the rejected waste or residue (i.e., either
back to the generator or to an alternative TSDF}. While the shipment is waiting to be
returned or sent to another TSDF, the facility should ensure that it is properly stored in a
secure manner. This could include, for example, storing the waste in a fenced area with
drainage and protection from weather. The facility must send the rejected waste or
residue off-site within 60 days (as required for manifest discrepancies}. The facility must
ensure that the rejected load or residue is re-manifested in accordance with applicable
manifest provisions. The facility should maintain records of each rejection (e.g., reason
for rejection and disposition of the waste}.
V^
2.12 Recordkeeping
40 CFR 264/265.13 do not require WAPs to
address recordkeeping. However, this
guidance recommends that recordkeeping
related to waste analyses and evaluations
be addressed in the WAP.
Recordkeeping is an essential aspect of waste
analysis, as it documents whether the analyses
were done in accordance with required and
acceptable procedures. In addition, the analytical
results can be used to determine compliance with
federal and state requirements (e.g., LDR
treatment, if applicable} as well as ensure safe and effective management of the waste.
Therefore, the facility may need to develop a well-organized system for recordkeeping that
provides the easiest, most straightforward way for addressing these objectives.
Because of the volume and frequency of waste receipts, it may be advisable for a TSDF to
maintain an electronic system for keeping track of generators, wastes, and analytical data.
This system can address both the facility's business needs and regulatory obligations for
record retention. Systems commonly used by TSDFs include a database of customers and
shipping partners, basic account information, and information on their wastes (e.g., profile
data}. Such information can assist the facility in arranging for shipments and tracking
shipments (e.g., using bar codes, manifest tracking numbers, etc.} to and from the facility. The
databases maintain information on a range of parameters of relevant to the waste analysis
process (e.g., quantity/types of hazardous wastes of each generator}. It may also be helpful to
have systems track each shipment of waste received from receipt at the facility through its
ultimate disposition or re-shipment off-site. Examples of information include:
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Basics of shipments received (e.g.,
time/date, quantity, waste type,
customer};
Any significant manifest or other
discrepancies and other problems
noted at receipt (e.g., a rejection};
Management method used on-site for
each waste (e.g., stabilization, etc.};
Other waste-specific information
related to its disposition (e.g., was it
sent off-site for further treatment};
Summary-level results of waste
analyses performed on-site (e.g.,
frequency at which waste treated at
your site passed and failed tests
during the year and the steps taken to
address failed tests};
Information on other problems and
issues that occur before or after waste
acceptance (e.g., summary-level data
on the frequency of discrepancies
between incoming shipments and their waste profiles and how they were resolved}.
In addition, the regulations give very wide latitude for maintaining information in your
operating record. In 40 CFR §264.73, for example, states that a facility operating record
should include "records and results of waste analyses and waste determinations performed
as specified in 40 CFR §§264.13, 264.17, 264.314, 264.341, 264.1034, 264.1063, 264.1083,
268.4(a}, and 268.7." Because it is broadly written, there are few if any constraints in the
type or amount of information that you may be asked to retain under this requirement.
In this regard, you may want to retain records of all analyses required under your WAP.
This includes, for example, analyses during pre-acceptance, acceptance (e.g., inspections
and fingerprint analyses}, and analyses of on-site management (e.g., residuals from on-site
treatment or storage}. You may need to retain records of analyses that both your facility
personnel and, if applicable, on-site laboratory perform.
Similarly, if you are a generator, you should determine the best system for developing and
keeping records of your test results and other determinations. Generators are required to
keep records of their hazardous waste determinations as required by §262.40(c} and their
LDR determinations as required by §268.7(a}(6}. The text box, below, gives some
suggestions on information that generators should retain on their hazardous waste and
LDR determinations.
Features of an Effective Recordkeeping System
A facility's records are one of the most important tools
for regulatory inspectors to evaluate compliance and
for facilities to demonstrate compliance.
A facility's recordkeeping system (including electronic
system) may need to be designed to provide
inspectors with the desired, timely, and
accurate/complete information. Important system
features include:
Ability to produce summary-level reports on
compliance and implementation problems
encountered during the period (e.g., frequency of
and reason for occurrence), including statistical
analyses
Ease in tracking compliance and implementation
problems to their cause (e.g., a specific waste
shipment or an inadequate stabilization recipe) and
tracking samples through acceptance
Ability to demonstrate that the facility resolved
problems that were encountered during the period
Ability to demonstrate that the facility performed
its analyses consistently and in accordance with the
WAP (e.g., use of internal checklists and audits)
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Some Suggested Recordkeeping for Generator Hazardous Waste Determinations (§262.11)
and LDR Determinations (§268.7(a)(l))*
List or inventory of all waste streams generated at the site that were subjected to testing or acceptable
knowledge under §262.11 and§ 268.7
Helps the generator and regulators determine if all solid wastes onsite are being properly evaluated and
managed under RCRA
Should be kept up to date
Information to be retained for testing determinations under §262.11 and§ 268.7
Sampling method (e.g., grab vs. composite; number of samples, etc.), rationale for the number of
samples collected (e.g., statistical basis), date of samples
Parameters analyzed
Test methods used, SOPs, credentials of lab that performed the test, date of test
Test results, data validation/interpretations, determination
Quality control data (e.g., sampling QC data)
Information to be retained for acceptable knowledge determinations under §262.11 and§ 268.7
Explanation of determination (e.g., explanation of extrapolations or calculations using SDS, date of
determination, etc.)
Background information used in the determination (e.g., industry documents, process information, SDS)
* Generators are required to keep records of their hazardous waste determinations as required by §262.40(c)
and LDR determinations as required by §268.7(a)(6) and (8). Records must be kept for at least 3 years, as
specified.
Finally, generators and TSDFs may want to consult their regulatory agency to learn more
about the records that they should retain and/or submit. For example, as a TSDF, you may
need to submit records of off-site laboratories that are used (e.g., Quality Assurance Plans,
analytical results, etc.}. As part of the permitting process, the agency may request that you
retain (and include in your permit application] many of the standard operating procedures
(SOPs) that you use to perform your waste determinations and analyses.
2.13 Corrective and Preventative Action Measures
It may be helpful for your facility to establish a waste analysis
corrective and preventative action program, which could be
included in the WAP. Corrective and preventative action, in
this context, is defined as the steps that a facility will take to
action measures. However,
40 CFR 264/265.13 do not
require WAPs to include
corrective and preventative
this guidance recommends
that such measures be
established and described
in the WAP.
eliminate the cause(s] of a nonconformity or undesirable
situation due to a deficiency in current practices. This may
include deviations from using proper sampling techniques or
out of control quality control data that may affect overall data
quality. The purpose of corrective and preventative action is
to prevent the recurrence of the nonconformity or undesirable situation by eliminating the
cause. Some elements that you may want to include in your corrective and preventative
action program include:
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How will deficiencies be identified and reported
How will a remedy to the deficiency be determined
What are the timeframes/deadlines for determining the remedy, instituting the remedy,
and verifying that the remedy has been properly implemented
Who is involved in each of the above steps and who is responsible for each item
If you use subcontractors (e.g., labs], do they have their own corrective and
preventative action program and is it sufficient to meet the needs of your facility.
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FIGURE 2-9: Example Waste Profile Sheet
Waste Profile #:
EPA Facility ID #:
GENERATOR INFORMATION
1. Generator Name:
2.
3.
4.
5.
6.
EPAIDtt:
Mailing Address:
Plant Address:
Business Contact:
Technical Contact:
Phone #:
Phone #:
The following information is requested pursuant to 40 CFR 264/265.13 General Waste Analysis (RCRA).
GENERAL WASTE INFORMATION
7. Waste Material Name:
8.
9.
10.
11.
12.
13.
14.
Generator Code (Optional):
Describe process that generates waste:_
NAICS Code:
Is your company the original generator of the waste? No
generator:
Yes
If not, provide the name of the original
If this waste is a still bottom, are you the original generator of the feed stock? No.
Rate of Generation: Current Accumulation: Drums:
Check all types of containerization for which you request quotation:
Yes
_Bulk(gal.):_
55-gallon steel drum
30-gallon steel drum
_ 85-gallon Steel drum (w/o inside container)
85-gallon salvage drum (w/drums inside)
Palletized small containers
55-gallon fiber drums
5-gallon pail
bulk (waste viscosity must be < 5000 cps)
other:
Overall dimensions of material on pallet: _
Dimensions of pallet only: _
What are the small containers on the pallet?_
X
.(IXwXh)
_ (IXwXh)
(1 qt. bottles, 8 oz. aerosol cans, etc.)
WASTE STREAM CHEMICAL COMPOSITION**
15.
Components Including 40 CFR 261 Appendix
VII Hazardous Constituents
Concentration
Range (units)
to
to
to
to
to
Average %
(must total
100%)
TLV (if published)
ACGIH
OSHA
* If applicable, this Waste Profile Sheet is a new revision of a previously submitted Waste Profile Sheet dated: .
Attach to the Form any additional information which must be known to treat, store, or dispose of the waste in accordance
with RCRA §§264/265.13, including but not limited to data developed under RCRA Part 261, Laboratory Analysis Technical
Publications or Materials Safety Data Sheets.
**40 CFR 261 Appendix VIII constituents should be identified for combustion facilities, even if not present in high enough
concentrations to significantly contribute to the 100% composition.
PART TWO: Documenting and Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
IV. SPECIFIC ANALYSIS OF WASTE
16. Method used to obtain a representative sample of the analyzed waste (i.e., grab, composite, etc.). Sampling
methods are described in RCRA 40 CFR 261 Appendix I:
Generator's Knowledge & SDS - in completing the next two items, do not leave blanks. If the specific element is
not present, indicate "None."
Organic Bound
Sulfur
Chlorine
Fluorine
Bromine
Iodine
Nitrogen
Phosphorus
Concentration Range
to
to
to
to
to
to
to
Average
17.
Metals (Actual Content) - Base % WT on
Arsenic (ppm)
Barium (ppm)
Cadmium (ppm)
Chromium (ppm)
Lead (ppm)
Aluminum (%)
Magnesium (%)
Mercury (ppm) ^^^T
Nickel (ppm)
Selenium (ppm)
Silver (ppm)
Thallium (ppm)
Silicon (%)
Sodium (%) T ^fl
V.
18. Does this waste contain PCBs > 50
If yes, give the concentration rega
19. Does this waste contain insecticide
If yes, identify each and the conce
(Include the SDS for each)
20. Does this waste contain dioxin?
21. Does this waste contain free cyani
22. Does this waste contain free sulfid
TOXICITY
23. Check Applicable Data
Eye
Inhalation
Dermal
Ingestion
Other
Carcinogen (suspected or known)
ppm? No Yes
dlessof amount and
>s, pesticides, herbici
itrations (ppm):
de>250 ppm?
e>250 ppm?
attach supporting documentation:
des. or rodenticides? No Yes
No Yes
No Yes
No Yes
Explain
VI. PHYSICAL PROPERTIES
24.
25.
26.
Physical state/viscosity at 70° F:
Viscosity (cps):
liquid semisolid solid slurry sludge gas
Is material pumpable?
Is waste multilayered?
Top (%):
Next (%):
Next (%):
No Yes If varies, explain
No Yes If yes, please describe and quantify each layer below:
27. Dissolved Solids (%WT)
28. Suspended Solids (%WT)
29. BTU Value/lbs
30. Ash Content (% WT)
31. Flashpoint (^F)
32. Vapor Pressure at 70^F
33. Specific Gravity
34. pH
35. Corrosivity
36. Color
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
37. What is the Reactivity Group Number(s) for this waste?
(in accordance with Design and Development of Hazardous Waste Reactivity Testing Protocol, EPA-600/2-84-057,1984)
38. Is this material stable? No Yes If no, explain:
39. Is this material shock sensitive? No Yes If yes, explain:
VII. EPA INFORMATION
40. Is this waste hazardous as defined by RCRA 40 CFR Part 261?
No
Yes
If yes, list the applicable EPA
Hazardous Waste Number(s) and explain why you have assigned the number(s). For example, if you assign D001,
the reason for selection is that the flash point is less than 140° F. If you assign F002, the reason for selection may be
that the waste is the still bottom from the recovery of methylene chloride.
EPA Hazardous Waste Numbers
Reason for Selection
41. If the answer to #40 is yes, list CERCLA reportable quantities found in 40 CFR Part 302.4:
42. If the waste is not hazardous as defined by federal regulations but is hazardous as defined by state regulations in
which the waste was generated, please provide the state hazardous waste number(s). Also, provide any state
hazardous number(s) that are not included in the federal regulations:
State Hazardous Waste Numbers
Reason for Selection
VIM. SAMPLING INFORMATION
43. Sample source (e.g., drum, lagoon, pond, tank, vat, etc.):
Date Sampled: Sampler's Name/Company:_
44. Generator's Agent Supervising Sampling:
If no sample required, provide rationale:_
IX. LAND DISPOSAL RESTRICTIONS INFORMATION
45. Identify all characteristic and listed EPA hazardous waste numbers that apply (as defined by 40 CFR Part 261). For
each waste number, identify the subcategory (as applicable, check none, or write in the description from 40 CFR
268.40).
EPA
Hazardous
Waste Code(s)
Subcategory
(enter subcategory or none if
not applicable))
Description
None
Applicable Treatment Standards
Performance Based (check
as applicable)
268.41(a)
268.43(a)
Specified Technology
(enter 268.42 Table 1
codes)
268.42
Management
Restrictions
(Designate A-D
per below)
To list additional EPA waste numbers and categories, use additional page and check here: _
If this waste includes any RCRA Codes D001 through D043, can this waste reasonably be expected to exceed the 40
CFR 268.48 Universal Treatment Standards (UTS) for any Underlying Hazardous Constituent(s)? No Yes .
If yes, include an attachment that identifies each constituent expected to exceed the UTS.
PART TWO: Documenting and Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Management under the land disposal restrictions:
A. Restricted waste requires treatment? No_
Yes
Bl.
B2.
B3.
C.
Restricted waste treated to performance standards? No Yes Method:
Restricted wastes for which the treatment standard is expressed as a specified technology (and the waste has
been treated by that technology)? No Yes Method:
Good faith analytical certification for incinerated organics No Yes
Method:
Restricted waste subject to a variance? No Yes
Date/Type:
Yes
D. Restricted waste can be and disposed without further treatment? No
X. DOT INFORMATION
In accordance with the Department of Transportation 49 CFR Parts 171 through 177, complete the following:
46. DOT Proper Shipping Name:
47. DOT Hazard Class:
48. DOT UN or NA Number:
49. Container Label(s) - for containers of 110 gallons or less:
50. Placards:
51.
(Generator's hazardous waste shipments must also comply with the labeling requirements of RCRA 40 CFR Part 262)
Is this waste a soil and/or debris? No Yes, Soil: Yes, Debris: Yes, Both:
52. Complete Only for Wastes Intended for Fuels or
Incineration (Total)
Antimony as Sb (ppm)
Beryllium as Be (ppm)
Potassium as K (ppm)
Sodium as Na (ppm)
Bromine as Br (ppm)
Chlorine as Cl (*ppm or %)
Fluorine as F (*ppm or %)
Sulfur as S (*ppm or %)
"indicate ppm or %
53.
A.
B.
C.
D.
E.
F.
G.
H.
1.
J.
Reclamation, Fuels or Incineration Parameters
(provide if information is available)
Heat value range (BTU/lb.): to
Water:
Viscosity (cps): @ ° F 100° F 150° F
Ash (%):
Settleable Solids (%):
Vapor Pressure @ STP (mm/Hg):
Is this waste a pumpable liquid? L No J Yes
Can this waste be heated to improve flow? 1 No 1 Yes
Is this waste soluble in water? F No 1 Yes
Particle Size: Will the solid portion of this waste pass
through a 1/8-inch screen? E No D Yes
54. Special Handling Information:.
XI. ACCOUNTABILITY STATEMENT
55. I hereby certify that all information in this and all attached documents contains true and accurate descriptions of
this waste. Any sample submitted is representative as defined in 40 CFR 262 Appendix I or by using an equivalent
method. All relevant information regarding known or suspected hazards in the possession of the generator has
been disclosed. I authorize ( ) to obtain a sample from any waste shipment for
purposes of recertification.
Authorized Signature
Date
Printed (or typed) Name and Title
PART TWO: Documenting and Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
PART THREE:
Checklist*
Comments
1. Facility Description
a. Are all processes that generate hazardous waste
identified?
b. Is sufficient information provided for each process to
confirm that all hazardous wastes are identified?
c. Have all hazardous waste management units been
identified?
d. Are descriptions of all hazardous waste
management units provided?
e. Have all hazardous and solid wastes been
identified for each unit?
f. Have the methods of waste management (e.g.,
stabilization) been described for each unit?
g. Are process design limitations defined for
each hazardous waste management unit?
h. Have operational acceptance limits been established for
each hazardous waste management unit?
i. Are procedures in place to determine whether wastes are
outside of their respective acceptance ranges?
j. Do operational acceptance limits include
applicable regulatory restrictions?
2. Systematic Planning
a. Does the WAP incorporate a process for systematic
planning, such as the Data Quality Objectives (DQO)
process?
b. Do personnel training records (located in the permit
application) demonstrate that facility personnel supervising
and conducting waste sampling and analysis have
received appropriate training in systematic planning?
3. Selecting Waste Parameters
a. Are parameters for waste analysis identified (and, if
applicable, included in the WAP)?
b. Does the WAP identify a rationale for the selection of each
waste analysis parameter?
c. Does the WAP include parameters for the special waste
analysis requirements 40 CFR §§264/265.17,
264/265.314, 264/265.341, 264/265.1034 (d), and
266.102(b), if applicable?
PART THREE: Checklist
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
d. Have operational acceptance limits been defined as they
related to waste properties and process?
e. Do operational acceptance limits include regulatory
restrictions?
f. Do waste analysis parameters address applicable
operational acceptance limits?
Comments
4. Selecting Sampling Procedures
a. Has the number of sampling locations been identified?
b. Are sampling procedures for each waste type identified?
c. Are descriptions and justifications provided for any
modified or non-standard procedures approved by EPA?
d. Have decontamination procedures for sampling equipment
been developed?
e. Have sampling strategy techniques (e.g., grab, composite)
been specified?
f. Are procedures for sampling multi-phase wastes
addressed, if applicable?
g. Has all sampling equipment been identified?
h. Have the number and types of sampling containers been
specified?
i. Have sample preservation techniques been specified?
j. Are sampling quality assurance and quality control
procedures been documented?
k. Are proper packing and shipping procedures documented?
1. Have procedures for the maintenance of all sampling
equipment been documented?
m. Are the precision and accuracy of all sampling equipment
been documented?
n. Are health and safety procedures for the protection of
sampling personnel specified?
5. Selecting a Laboratory and Laboratory Analytical Methods
a. Are laboratory analytical methods specified for each waste
managed at the facility? If, not, is other information (i.e.,
acceptable knowledge) used to demonstrate waste
analysis?
b. Has a rationale been specified for each analytical method?
c. Do the selected analytical methods meet all regulatory
requirements for the identification of each hazardous
waste (e.g., each hazardous waste characteristic)?
d. Are descriptions and justifications provided for any
modified or non-standard methods, as approved by EPA?
PART THREE: Checklist
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
e. Have chain-of-custody procedures for samples been
specified, if necessary?
f. Does the laboratory have an adequate QA/QC program?
g. Have QA/QC procedures for each analytical procedure
been identified?
Comments
6. Quantifying Data Uncertainty
a. Does the WAP incorporate a process for quantifying data
uncertainty so that laboratory results are capable of
supporting the facility's waste management decisions (i.e.,
is there an appropriate level of certainty in the results)?
7. Selecting Waste Re-Evaluation Frequencies
a. Have site-specific criteria for waste re-evaluations been
specified?
b. Is re-evaluation accomplished with adequate frequency?
c. Are mechanisms in place for re-evaluating the sampling
program each time the waste generating processes
change?
d. Do the re-evaluation procedures specify criteria for the
acceptance of wastes received from off-site generators?
e. Do you notify off-site facilities (i.e., TSDFs) of changes in
waste characterizations due to process changes and other
factors?
8. Special Procedural Requirements, Where Applicable
a. Are procedures in place to verify the sources of the
information provided from off-site generators or TSDFs?
b. Have criteria been established for the pre-acceptance
procedures of wastes based on information from off-site
generators or TSDFs?
c. Are procedures for waste inspections in place?
d. Have fingerprint analysis parameters been developed?
e. Have criteria been established for the acceptance of
wastes based on the results of fingerprint analysis?
f. Is there a methodology for identifying ignitable,
incompatible, or reactive wastes?
g. Are procedures in place to conduct testing to determine
whether wastes are incompatible with each hazardous
waste management unit on-site?
h. Have all wastes restricted under the LDRs been identified?
i. Are procedures in place to ensure that wastes met
applicable LDR treatment standards prior to land disposal?
PART THREE: Checklist
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Comments
9. Discrepancy Policy
a. Are procedures in place to resolve discrepancies between
incoming shipment and its manifest?
b. Are the procedures in compliance with applicable manifest
discrepancy regulations (Part 264/265, Subpart E)?
c. Are procedures in place to resolve discrepancies between
incoming shipment and its waste profile?
d. Do these procedures include a process for re-
characterizing the waste and revising or preparing a new
profile when needed?
10. Rejection Policy
a. Are procedures in place to reject a waste in accordance
with applicable RCRA regulations (Part 264/264,
Subpart E)?
b. Are these procedures coordinated with the discrepancy
policy as necessary?
11. Recordkeeping
a. Does the WAP clearly identify all of the types of records
that will be kept?
b. Does the WAP indicate the length of time that records will
be kept and are these timeframes in compliance with
applicable regulations?
c. Will the facility produce summary-level reports based on its
records, to describe its compliance with applicable WAP
requirements (e.g., on LDR compliance testing)?
d. Will the facility's recordkeeping systems produce records
to on-site inspectors in a timely and organized fashion?
12. Corrective and Preventative Action
a. Is a corrective and preventative action program in place to
identify and eliminate the cause(s) of nonconformities and
undesirable situations due to deficiencies in current
laboratory practice?
b. Does the WAP describe how deficiencies will be reported
and remedies determined?
c. Does the WAP spell out the timeframes for reporting and
resolving problems?
d. Are responsible personnel identified (e.g., by position)?
* Refer to Part Two of this manual for additional information on these checklist items. Note that some items are mandatory and others are
recommended.
PART THREE: Checklist
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
PART FOUR:
Sample WAPs
This chapter presents two WAPs that EPA has compiled from different types of TSDFs. The
examples are intended to give permit applicants and permit writers ideas and issues to
consider when preparing or approving a WAP. However, as discussed below, the examples
are not complete or approvable as presented and should be used only as a learning tool. An
occasional call-out box is included in the WAPs to highlight certain issues. As a permit
applicant, you should not simply "copy and paste" text from the examples into your
WAP. Rather you should carefully understand how to develop your WAP in
accordance with the regulations and ensure that it is appropriate for your own
facility. Furthermore, it is important that you carry out and implement the
necessary procedures, as outlined in your WAP, to satisfy the regulatory WAP
reqirements. Every WAP is different and should account for facility- and state-specific
considerations and comply with all applicable requirements.
The following WAPs are presented:
Example 1 belongs to ACE Chemical Services, which is a commercial treatment and
disposal facility. It receives hazardous waste shipments from offsite, performs
stabilization and other forms of treatment, and landfills the treated waste onsite.
Example 2 belongs to Container Management Incorporated (CMI], which is a
commercial storage facility. It receives shipments from offsite customers, performs
minimal waste handling (e.g., consolidation], and ships the waste offsite for further
management and disposal.
Although the federal regulations are cited in the examples, you should consult and
reference your own state's regulations when preparing your WAP. States may require
more and/or different information.
Please note that the example WAPs have been edited as follows:
The name of the actual TSDF and other identifying information have been removed or
changed; and
The WAPs have been edited to reduce their overall length and modify content. For
example, some of their text, graphics and/or attachments may have been shortened,
simplified or removed. This was done solely to facilitate their presentation in this
guidance. Notations have been inserted to indicate when text has been shortened from
its original version. Any WAP submitted by a permit applicant must include all required
and appropriate text, graphics, and attachments.
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Example WAP 1: Waste Analysis Plan for
ACE Chemical Services
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Table of Contents
A. Waste Analysis Plan 4-5
A-l Introduction 4-5
A-2 Pre-acceptance Procedure 4-6
A-2.1 Generator-Supplied Information 4-6
A-2.2 Initial Review and Analysis 4-7
A-2.3 Disposal Decision Process 4-8
A-2.4 Re-Evaluation Process 4-8
A-3 Acceptable Waste Codes ^^^ ^ 4-9
A-4 Analyses during Waste Acceptance and Process Operations 4-9
A-4.1 Verification of Incoming Shipments 4-12
A-4.1.1 Visual Inspection 4-12
A-4.1.2 Chemical Screening 4-12
A-4.1.3 Discrepancy Resolution 4-15
A-4.1.4 Supplemental Verification 4-15
A-4.1.5 Final Acceptance 4-15
A-4.2 Process Operations Procedures 4-16
A-4.2.1 Storage 4-16
A-4.2.2 Stabilization 4-17
A-4.2.3 Landfill Disposal 4-18
A-5 Restricted Wastes 4-20
A-6 Rejection Policy 4-20
A-6.1 Authority 4-21
A-6.2 Safety 4-21
A-6.3 Scheduling 4-21
A-6.4 Documentation 4-21
A-6.5 Notification 4-21
A-6.6 Rejection 4-22
A-7 Discrepancy Resolution 4-22
A-7.1 Manifest Discrepancy 4-22
A-7.2 Discrepancies Between Waste Received at Facility and Waste Profile 4-22
A-8 Sampling Methodology 4-23
A-8.1 General Methods and Equipment 4-24
A-8.2 Specific Methods and Equipment 4-24
A-8.2.1 Containers and Tanks 4-25
A-8.2.2 LDR "Grab" Sampling 4-25
A-9 Parameters and Analytical Methods 4-26
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
A-10 Quality Assurance/Quality Control 4-28
A-10.1 Introduction 4-28
A-10.2Sampling Program 4-28
A-ll Data Reporting 4-29
A-12 Recordkeeping 4-29
A-13 Corrective Action 4-31
Appendices 4-32
Appendix A-l Waste Profile Sheet 4-32
Appendix A-2 Overview of the Pre-Acceptance Process 4-32
Appendix A-3 Overview of the Incoming Load Process 4-32
Appendix A-4 Aqueous Waste Treatment 4-32
Appendix A-5 Landfill and Stabilization 4-32
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
A. Waste Analysis Plan
In accordance with the regulatory requirements set forth in 40 CFR 264.13, ACE Chemical
Services, L.L.C. (ACE] has developed this Waste Analysis Plan as an integral part of the
permit application for its treatment, storage and disposal facility. The procedures set forth
in this plan dictate that this facility will be in compliance with all requirements of 40 CFR
264.13. A copy of this plan will be available at the facility at all times.
A-l Introduction
The purpose of this Waste Analysis Plan (WAP] is to identify and document the necessary
sampling methodologies, analytical techniques and overall procedures which are
undertaken for all wastes that enter this facility for storage, treatment or disposal.
Specifically the plan delineates the following:
Pre-Acceptance Procedures - Section A-2 outlines the procedural steps ACE will take to
evaluate the acceptability of a candidate waste stream pursuant to permit conditions
and operating capabilities prior to shipment and acceptance of the waste for
management at the site, including re-evaluation frequency.
Acceptable Waste Codes - Section A-3 summarizes the wastes that ACE facility is
approved to accept.
Waste Analyses Performed by ACE Facility - Section A-4 describes the analyses
performed on incoming shipments and wastes in process operations.
Restricted Wastes - Section A-5 summarizes wastes that ACE facility is not approved to
accept.
Rejection Policy - Section A-6 discussed the policy and procedures that ACE will use for
the acceptance or rejection of waste received by the facility.
Discrepancy Policy - Section A-7 discusses ACE facility's procedures for resolving
manifest discrepancies and discrepancies between incoming waste shipments and their
waste profile.
Sampling Methodology - Section A-8 outlines the proper sampling method(s] for a
given waste type (solid, sludge, liquid] and containment (drum, tank, impoundment
pile, etc.}. ACE personnel can then obtain waste identification samples to help ensure
accurate analytical results when a waste is analyzed.
Analytical Parameters. Techniques and Rationale - Section A-9 outlines the parameters,
rationale and methods ACE will utilize to determine or identify certain waste properties
to ensure proper management of the waste at the site.
Quality Control Policy - Section A-10 outlines the quality control policy this site will
follow to achieve high quality analytical results.
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Data Reporting - Section A-ll identifies the data that
ACE facility will supply to the state Director under
this WAP.
Recordkeeping - Section A-12 identifies the records
that ACE facility will retain on site related to waste
analyses performed under this WAP.
WAP Accountability
Consider identifying those individuals,
by title, who are ultimately responsible
for ensuring WAP compliance. This will
increase accountability.
Corrective Action - Section A-13 describes the procedures that ACE facility will take to
resolve issues, needs or problems that may arise in connection with its laboratory
operations.
The Approvals Manager, Laboratory Manager, Technical Manager, General Manager or
their designees are individually and collectively herein referred to as "ACE site
management".
A-2 Pre-acceptance Procedure
ACE has developed a series of control procedures to determine the acceptability of specific
wastes for management at the site, referred to as the "Pre-acceptance Procedures." The
pre-acceptance procedures include the following steps:
Generator-supplied information is what a customer must provide to enable ACE to
make an initial decision regarding the appropriateness/acceptability and possible
management of a candidate waste stream.
Initial review and/or analysis of the generator-supplied material allows ACE to conduct
an initial evaluation for management capabilities at the facility.
Disposal decision is the process of reviewing all the documentation supplied by the
generator and/or ACE and documenting the acceptance or rejection of the candidate
waste stream.
Re-evaluation process determines the frequency a waste stream will be re-evaluated
once it has been accepted.
A-2.1 Generator-Supplied Information
The waste generator will supply ACE with the following information and materials for each
new candidate waste stream, except where noted herein.
Waste Profile Sheet. (WPS], which will contain pertinent chemical and physical data. At
a minimum, the generator supplies all the information required by 40 CFR 264.13(a](l]
needed to characterize the waste for proper treatment, storage, or disposal. ACE may
assist the generator in completing information provided by the generator based on its
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
evaluation. The complete package is reviewed and approved by the generator at the
completion of the approval process.
A standard profile is a profile that is used for multiple waste streams that are similar
in physical and chemical characteristics. Standard profiles will be used only for wastes
that share the same:
Generating process. The generating process should be described in sufficient
specificity. For example, for electroplating, this would include an indication of type
of electroplating (zinc electroplating, chromium electroplating, etc.] and a narrative
description of the generating process.
Raw ingredients used in the generating process. The waste profile should include a
complete list of the ingredients used in the process that generates the waste; and
Onsite management method. If two wastes require different management methods
at the ACE facility (e.g., pre-treatment vs. no pretreatment before stabilization], they
require different waste profiles.
A representative sample is required of all waste streams, with limited exceptions. Refer
to Sections A-4 and A-9 of this WAP for parameters to be analyzed during pre-
acceptance. No representative sample is required for the following:
Labpacks. Lab pack chemicals are managed in
accordance with all applicable state regulations
based on certifications presented.
"Empty" containers of waste materials.
Commercial products or chemicals. This applies
, , . , . , , , . , compliance requirements for
to a portable container which has been emptied treatment or djsposa|/ such as LDR
numerical limits).
Sampling During Pre-Acceptance
Analysis of a sample may be
necessary during pre-acceptance
(e.g., if the receiving facility has
but which may hold residues of the product or
chemical (e.g., portable tanks, drums, barrels,
cans, bags, liners, etc.}. A container shall be determined RCRA "empty" according to
the criteria specified in 40 CFR Part 261.7.
Land Disposal Restriction Notification/Certification Information and/or Data (40 CFR
Part 268}.
Other supporting documentation such as additional analytical results or a safety data
sheet (SDS}, as necessary to provide additional waste characterization.
A-2.2 Initial Review and Analysis
Once ACE receives the generator-supplied information and it is reviewed, a determination
will be made if further analyses by the generator or ACE are required. All waste samples
will be subjected to the analyses identified in Section A-4, as appropriate. Additional testing
may also be requested by the site management if needed.
If, during the pre-acceptance procedure, ACE determines that the waste information
indicated by the testing does not completely conform to the information on the WPS, the
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
generator is notified of the apparent inconsistency. If the inconsistency is resolved, the pre-
acceptance procedure continues. The waste may be rejected or accepted during this phase
of the procedure.
A-2.3 Disposal Decision Process
The pre-acceptance procedure is concluded when the review of the generator supplied
information and any appropriate mandatory analyses is complete. At this time, ACE makes
a "disposal decision" on the candidate waste. Disposal decisions are based on:
Management methods available.
Conditions or limitations of existing permits and regulations.
Capability to safely manage the waste.
WPS description of the process generating the waste.
Knowledge of the waste generating process.
WPS description of the chemical and physical properties of the waste.
Any additional documentation supplied by the generator (e.g., LDR certifications}.
Results of any verification analyses.
Results of any analyses of process operations procedures.
Management's technical experience and judgment.
A-2.4 Re-Evaluation Process
In accordance with 40 CFR 264.13(a}(3], a waste profile
re-evaluation will be conducted when one of the
following occurs:
WAP Performance Evaluation
Consider including provisions in the
WAP for the facility to evaluate their
A generator notifies ACE that the process generating WAP Performance continually and
., ..ii j keep records. This will promote on-
the waste has changed;
The results of inspection or analysis indicate that the
waste received at the facility does not match the
going improvements and assist
regulators during compliance
identity of the waste designated on the accompanying
manifest (or shipping paper] or pre- acceptance documentation (See Discrepancy Policy
in Section A-7}; or
At the end of each calendar year for all wastes received and managed during the year, as
follows:
PART FOUR: Sample WAPs
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
ACE will conduct a comprehensive annual review of all wastes accepted onsite by
comparing the results of fingerprint analyses (which are maintained in ACE's in-
house waste tracking system] to the WPSs to identify any pattern of discrepancy
(e.g., pH of fingerprinted waste that falls outside its tolerance limits (as described
herein] more than 20% of the time].
ACE will conduct an annual evaluation of its post-treatment results to identify
instances where the treatment standards were not met and treatment had to be
repeated. In these cases, ACE will evaluate the incoming waste to determine if their
WPSs are accurate or if they should be re-characterized and WPSs revised to
provide better information to enable more effective treatment.
ACE will send all WPSs to the generators annually for their review, revisions if
needed, and re-certification. Generators will be asked to re-evaluate each WPS to
determine if the generation process (e.g., raw ingredients, generating process] or
waste (e.g., waste codes] has changed such that a new or revised WPS is needed.
A-3 Acceptable Waste Codes
In brief, this facility accepts waste codes D001 through D043, F001 through F039 (except
F020 through F028], K001 through K172, P001 through P205, U001 through U411 (except
as otherwise noted in Section A-5 of this WAP regarding restricted waste]. Refer to the
latest version of this facility's RCRA permit (dated December 2011] for a complete list of
the RCRA waste codes that this facility is approved to accept and manage onsite. The list in
the permit supercedes the language in this WAP.
A-4 Analyses during Waste Acceptance and Process
Operations
As discussed in Section A-2, ACE site management
samples each waste that undergoes the pre-
acceptance procedures, with limited exceptions.
When a shipment of hazardous or non-hazardous
waste is received at the ACE facility, verification of
the shipment is performed. Verification activities an* gArapfhics are hf lpfcuL hSee Tables A^
r r and A-2 for example. Subsequent sections
include container receipt inspection. It also
includes chemical screening according to the
frequencies specified in this section. Any Note that this WAP does not summarize
testing of wastes generated by ACE;
Summary of All Analyses Performed
It is recommended that a summary of all
sampling/analysis performed at the facility
(e.g., parameters and testing frequency) be
presented in one place in the WAP. Tables
of the WAP can go into greater detail.
however, there should be some discussion
of this.
discrepancies between the verification results and
waste profile must be resolved in accordance with
the Discrepancy Policy discussed in Section A-7
before the shipment can be accepted at the facility. In addition, process operations
procedures are performed to ensure that the waste is managed safely and in accordance
with applicable regulations.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Table A-l summarizes the parameters that are examined for each of these screening
analyses. Parameters for waste analysis during pre-acceptance are shown in Column 2.
Once the waste is approved during pre-acceptance, all incoming shipments are subjected to
mandatory verification, including inspections and chemical screening (Column 3 A}. In
addition, supplemental analyses may be performed to resolve discrepancies between the
verification results and waste profile (Column 3B). Finally, analyses are performed as
necessary for process operations that are conducted onsite (Columns 4A-C). Specifically,
for incoming wastes that will be placed into storage, ACE performs the mandatory
verification in Column 3A to determine appropriate storage procedures, such as
segregation of incompatible waste (Column 4A). For incoming wastes to be stabilized, ACE
performs the mandatory verification in Column 3A to determine appropriate treatment
(Column 4B}. Finally, ACE performs "Suitability for Landfill" analyses (e.g., TCLP to ensure
compliance with 40 CFR part 268 treatment standards] for any waste to be landfilled at the
ACE facility (Column 4C}. This includes (1} incoming wastes for which the generator or
treater has certified compliance with all applicable treatment standards and (2} wastes
stabilized onsite by the ACE facility. Note that ACE's onsite treatment is designed to
address only the inorganic constituents of the waste; it does not treat organics. Table
A-2 summarizes the frequency by which each of these analyses must occur. Refer to ACE's
SOPs for additional information on sampling frequency.
TABLE A-l: Analyses Performed by ACE Facility3
1. Indicati
Parameters
Physical Description
Incoming Shipments
pH Screening
PCB Screening
Suitability for Landfill
Water Mix Screening
Flammability Potential
Screening
Sulfide Screening
Radioactivity
Screening
Ash Screening
Compressive Strength
Conductivity
Acceptance
X
X
O
O
O
4. Process Operations Procedures
Storage of B. Stabilization
ncoming of Incoming
uppiememai
X
icommg
lipments
X
NAC
Shipments C. Landfill
O
NA°
O
O
O
O
O
O
O
O
O
a. X = parameters that are examined for each waste.
O = parameters that are examined as necessary. NA = not applicable.
b. This column applies to the following that are destined for the ACE landfill: (1) stabilized wastes received from offsite that have been certified
by the generator or treater as meeting all applicable LDR treatment standards and (2) wastes that have been stabilized onsite by ACE facility.
The table shows that such wastes are subject to the "Suitability for Landfill" analyses (e.g., TCLP) before disposal. Other analyses may also be
performed at site management's discretion. ACE facility also implements an Additional Review Program described in Section A-4.2.3.
c. Incoming wastes to be placed in storage will be subject to mandatory verification in Column 3A.
d. Incoming wastes to be stabilized before onsite disposal will be subject to mandatory verification in Column 3A.
NOTE: Table A-l has been shortened in order to reduce the overall length of this example WAP. This was done
solely for purposes of presentation in this guidance document.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
TABLE A-2: Summary of Frequency of Analysis
On each waste
undergoing pre-
acceptance, except
as otherwise
specified
On each incoming shipment as
follows:
Visual inspection of each
shipment, including
inspection of opened
containers to confirm
physical description
Chemical screening of each
bulk load
Chemical screening of each
container shipment as
determined by ACE site
management. See Section
A.4.1.2ofthisWAPfor
additional information.
Whenever a
discrepancy between
waste and WPS is
found that cannot be
resolved by generator
and ACE
For incoming
wastes to be placed
in storage, see the
frequency for
Mandatory
Verification
Process Operations Procedures
abilization
For incoming waste
to be stabilized, see
the frequency for
Mandatory
Verification
For stabilized waste that is shipped to ACE
for which the generator or treater has
certified full LDR compliance: each shipment
will be analyzed for Landfill Suitability. This
frequency can be decreased, as follows, if 10
successive shipments meet all applicable
LDR standards:
1 in 10 shipments is analyzed for all
required parameters; and
Every shipment is analyzed for an
indicator parameter (e.g., pH) to confirm
treatment effectivenessb
For waste that has been stabilized by ACE
onsite: each batch will be analyzed for
Landfill Suitability
ACE will also visually inspect each waste
before placement in the landfill to ensure
that no free liquids are present. A paint
filter test (or comparable test) will be
performed if there is any question, the
liquids will be removed, the test will be
repeated.
a This column applies to (1) wastes received from offsite that have been certified by the generator or treater as meeting all applicable LDR treatment standards and are destined for the ACE landfill
and (2) wastes that have been stabilized onsite by ACE facility and are destined for the ACE landfill.
b If any shipment fails to meet the treatment standards, 100% testing must be resumed, as specified in this WAP, until a subsequent set of 10 successive shipments meet all applicable
LDR standards.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
The following sections provide more information on the analyses that ACE site
management will perform.
A-4.1 Verification of Incoming Shipments
Verification of incoming shipments involves inspection of containers and chemical
screening. As part of the facility's training program described in the Part B permit,
personnel will be taught how to perform the verification procedures effectively and safely.
A-4.1.1 Visual Inspection
The container receipt inspection is a mandatory
element of the confirmation process. Therefore, 100
percent of the incoming shipments are inspected and
physically verified for damage and to ensure the waste
containers are those indicated on the documentation.
This activity is a mechanism for identifying any to view their contents. This is
, ,. . , , . i r important for confirming the physical
document discrepancies or damaged containers before
Visual Inspection of Containers
This WAP requires visual inspection
of 100% of shipments received,
including opening some contaainers
description of the waste and
supplementing the chemical
screening, which is peformed on only
a subset of containers.
acceptance. The container receipt inspection is
performed by ACE management, who will ensure that
the shipment: (1] is received in good condition and does
not include bulging or other irregularities, (2} is the
waste indicated on the manifest or shipping papers, and (3} is complete. In addition, at
least one container from each profiled waste in a shipment will be opened and its contents
will be visually inspected to confirm it matches the physical description on its profile. The
visual inspection will address color, viscosity, and waste form (e.g., debris, PPE, sludge], at
a minimum.
^L
A-4.1.2 Chemical Screening
Chemical screening is considered an additional verification element. Selection and
interpretation of the appropriate chemical screening methodfs] are conducted by
personnel who are qualified as described in the permit. The objective of chemical screening
is to obtain reasonable assurance that the waste received by the TSD unit is consistent with
the description of the waste on the waste profile and to provide information that will be
used to safely manage the waste at the TSD unit. After chemical screening is done, tamper-
resistant seals are applied over the container opening on each outer container screened.
As shown in Table A-2, each bulk load (i.e., truck] will be screened chemically. Samples
from the front, middle and back of each load will be obtained and composited, if possible.
However, composite samples across separate loads will not be taken.
Container shipments will be chemically screened according to the Performance Evaluation
System (PES] and associated procedures, described below.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Chemical Screening Frequency for Container Shipments. Shipments of containers received
by ACE will be chemically screened as follows:
Chemical Screening Frequency
This approach to chemical screening
may appeal to some facilities because it
allows a gradual reduction in frequency
for certain shipments. However, the
approach raises some issues:
Is it acceptable to chemically screen
certain shipments only once or
twice per year? What if the
generator's waste changes mid-year
and the facility is not notified. How
would this change be detected?
Does the screening approach give
too much discretion to the facility
to determine initial frequencies and
reductions?
If each container in a shipment holds a different
profiled waste, each container will be chemically
screened as follows:
Once per year: No concerns identified.
Once every 6 months: Concern(s] identified in
one criterion.
Once every 3 months: Concerns identified in two
or more criteria.
However, if multiple containers in a shipment (i.e., 2
or more] hold the same profiled waste, one or more
samples will be collected from them and chemically
screened. Based on the identification of concerns
during the Performance Evaluation System
(described below], ACE site management will
establish the initial chemical screening frequency for
multiple containers based on the following criteria:
If no concerns are identified: Initial chemical screening frequency of, at a minimum,
10 percent.
If concerns are identified in one criterion: Initial chemical screening frequency of, at
a minimum, 20 percent.
If concerns are identified in two or more criteria: Initial chemical screening
frequency of 30 percent.
For example, if ACE receives a shipment of 2 to 10 containers holding the same profiled
waste, ACE would sample one of them, assuming no concerns were identified. If ACE
receives a shipment of 11 to 20 containers holding the same profiled waste, ACE would
sample two of them, assuming no concerns were identified.
Composite samples will not be taken across containers holding different profiled
wastes.
Description of Performance Evaluation System (PES). The PES is used to determine the
initial chemical screening frequency of each generator's containerized waste streams. This
includes determining the number of concerns we have regarding each waste. We organize
our concerns under "criterion." We revise the criteria and concerns annually based on
operating conditions, regulatory requirements, and other relevant considerations.
Examples of criteria include:
Historical performance of the generator (e.g., has the generator's performance in
characterizing its wastes been satisfactory, and if not, what concerns have been
identified?};
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Nature of the waste (e.g., is it a novel/unknown waste stream, and if so, what potential
concerns are associated with its management at this facility?}; and
Elapsed time since generator's last shipment (e.g., has the generator made a shipment
within the past year, and if not, is there a concern, such as potential changes in its waste
generating processes that we may be unaware of).
PES provides a periodic status of an individual generator's performance for containerized
waste received. Also, PES provides a mechanism for determining corrective actions,
resolving waste acceptance issues, and chemical screening frequency adjustments when a
problem has been discovered.
In addition, an annual performance evaluation is used to trend a generator's performance
and is used to raise the generator's overall group of streams chemical screening frequency
based on the type of issue. The evaluation should be objective and should consider the
discrepancy issues documented during the pre-acceptance and verification functions. The
ACE site management will: (1} perform annual evaluations based on deficiencies and
discrepancy issues identified, (2} evaluate unsatisfactory performance for corrective
actions, and (3} adjust chemical screening rates accordingly.
Process for Reducing the Chemical Screening Frequency for Multiple Containers Holding
Same Profiled Waste. After the initial screening frequency for a given waste profile has
been established or increased, the chemical screening frequency can be reduced in
accordance with the following process.
The chemical screening frequency will be reduced gradually, as shown in Table A-3.
Reduction is based on the ability to demonstrate that five containers from the profiled
waste in question pass verification. In addition, reduction to the minimum frequency
requires that the ACE site management documents an acceptable evaluation of the
corrective action plan, if applicable. At no time will the chemical screening frequency be
reduced below 10 percent for waste received from offsite.
Table A-3 shows that, for containers for which no concerns were identified during the PES,
a 10 percent screening is established. This frequency cannot be reduced further. For
containers for which concerns were identified in one criterion, the initial screening of 20
percent will be reduced to 10 percent after 5 containers pass verification. For containers
for which concerns were identified in two or more criteria, the initial screening of 30
percent will be reduced to 20 percent after 5 containers pass verification and to 10 percent
after 10 containers pass verification.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
TABLE A-3: Reduced Chemical Screening Frequency3
Concerns Identified
None
litial Scree
Frequency
10%D
Reduced Frequency Reduced Frequency
A*ter 5 Containers After 10 Containers
Pass Verification Pass Verification
N/A
N/A
Concern(s) identified in one criterion
20%
10%D
N/A
Concerns identified in two or more criteria
30%
20%
10%D
a This table applies to multiple containers holding the same profiled waste. N/A = not applicable.
b 10 percent is the minimum screening frequency allowed.
A-4.1.3 Discrepancy Resolution
Discrepancy issues identified during verification of any shipment (i.e., bulk or container]
could result in a waste container that does not meet ACE waste acceptance criteria. If a
possible discrepancy issue is identified, the actions described in Section A-7 of this WAP
must be taken.
A-4.1.4 Supplemental Verification
If the mandatory verification of incoming shipments identifies a discrepancy with the WPS,
and the discrepancy cannot be resolved by the generator, then ACE will perform
supplemental analysis of the waste, reject the waste back to the generator, or ship the
waste to an alternate treatment, storage, or disposal facility. ACE will notify the state
Director of any wastes rejected back to generators. A supplemental analysis includes tests
for the parameters shown in Table A-l in Section A-4.
Any waste that is subject to a supplemental analysis will be quarantined until the
discrepancy with the WPS is resolved.
Supplemental analysis will be subcontracted to an independent state certified or NELAC
laboratory that uses ASTM and/or SW-846 analytical and test methods. The results of all
supplemental analyses will be documented in a log maintained as part of the facility
operating record.
A-4.1.5 Final Acceptance
Upon verification that a containerized waste or bulk waste is consistent with the
corresponding WPS, the waste will be moved from the receiving area to an appropriate
storage cell. Movement to an appropriate storage cell shall occur within the time
limitations required by the state's regulations (e.g., 24 hours] after off-loading waste from
the transport vehicle.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Any waste that does not conform to the corresponding WPS will be quarantined until the
discrepancy is resolved with the generator. Upon resolution of the discrepancy, the waste
will be moved to an appropriate storage cell by the end of the work shift.
A-4.2 Process Operations Procedures
NOTE: Some portions of Section A-4.2 have been removed in order to shorten the overall length of this
example WAP. This was done solely for purposes of presentation in this guidance document.
Many of the analyses needed for the storage, treatment, and disposal functions are
performed during incoming load identification. These are not repeated unless it is known
or believed that the waste characteristics may have changed during storage or processing
and monitoring of the changes is necessary. Existing and anticipated process operations at
the facility, for which current and periodic sampling and analyses is important, include
the following:
Storage;
Stabilization; and
Landfill disposal.
The analytical procedures for each of these processes are described separately below.
A-4.2.1 Storage
When waste is received at the ACE facility, a verification analysis is performed to determine
its physical and chemical properties (e.g., pH, flammability, etc.}. ACE site management will
review the results of the verification analyses to determine the safe management of waste
to be placed in storage.
Based on the verification analysis, the site management will determine the compatibility of
the waste with the storage unit materials of construction and with wastes already stored
therein. In addition, stored containerized liquid and solid wastes will be segregated with
respect to ignitability, reactivity, corrosivity, and compatibility. Liquid wastes which are
transferred from drums, portable tanks or tank trucks may be bulked and placed in bulk
storage prior to further treatment.
Waste in Containers (Drums). Stored containerized wastes are segregated with respect to
ignitability, corrosivity, reactivity, and compatibility. Appendix V of Part 265, as well as the
U.S. Department of Transportation (DOT] Hazardous Precedence List (49 CFR Part 173.2}
and the Segregation and Separation Chart of Hazardous Materials (49 CFR Part 177.848},
shall be employed for the initial determination of compatibility. The following table lists
DOT hazard classes with incompatible hazard classes for wastes in drum storage areas.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
TABLE A-4: Incompatible Hazard Classes
Hazard Class
Flammable Liquid
Flammable Solid
Oxidizer or Organic
Peroxide
Corrosive
Incompatible Hazard Classes
Oxidizer, Organic Peroxide
Corrosive, Oxidizers
Corrosive, Flammable Liquid,
Flammable Solids
Oxidizer, Organic Peroxide Flammable Solids
Based on the initial hazard determination and final identification of the waste, the
drummed waste is organized into segregated storage areas. Flammable, corrosive and
oxidizing waste materials are kept separate from incompatible materials by storage in
separated, walled off/bermed areas within the drum storage unit.
Waste in Tanks. Liquid wastes delivered in bulk form by tank trucks or decanted from
drums or portable tanks are placed in bulk storage tanks or directly into reactors prior to
further treatment. Prior to transferring any different waste(s] into a storage tank, the
compatibility of the waste with the material already in the tank will be determined by the
liquid waste compatibility test. Following routine screening, specific storage and process
compatibility will be determined. The parameters that will be used to determine
compatibility are as follows:
Stratification - The general miscibility of the materials will be examined. If stratification
would appear to create a problem, the materials will not be combined.
Heat Generation - Materials that upon mixing would generate sufficient amounts of
heat or undergo exothermic reactions strong enough to exceed the design capability of
the storage unit shall not be combined.
Gas Evolution - Materials that upon mixing liberate flammable, explosive or toxic
vapors, fumes or mists in quantities of concern, shall not be combined unless the
storage unit is designed with appropriate engineering controls.
Undesirable Reactions - Materials that upon mixing result in the formation of a large
amount of precipitate or in the solidification or gelling of the mixture shall not be
combined.
A-4.2.2 Stabilization
For the purpose of this discussion, treatment will include, at a minimum, stabilization of
waste, and in some instances, will include a pre-treatment step prior to stabilization. The
pre-treatment may include using other reagents such as oxidizing or reducing agents to
chemically convert constituents into a form more suitable for stabilization.
Incoming wastes to be stabilized before disposal will be subjected to the mandatory
verification. The pre-treatment analyses also will include a bench scale development of a
recipe suitable for achievement of these standards. This recipe will be analyzed using the
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
appropriate test method (e.g. TCLP., etc.] to demonstrate that the LDR waste can be
treated to meet the appropriate standard of prohibition and to establish the treatment
guideline to be used on the waste. In addition, compression strength testing may be
performed to demonstrate the strength of the treated waste. The treatment guidelines,
established during the procedure, demonstrated to achieve the appropriate treatment
standard, will be used to treat that LDR waste. In lieu of bench scale recipe development a
previously developed and established recipe may be identified for use (e.g., recipe
utilized on a similar waste}.
Stabilization operations may involve combining multiple waste streams or shipments, i.e.,
to optimize treatment volume. Wastes to be combined will be selected based on their
chemical matrices, EPA codes and recipe requirements. For waste tracking purposes, the
treatment residue will carry all waste stream identities (profile numbers and shipment
identities, i.e., work order number, manifest number, etc.}. For batches with multiple EPA
codes, the combined most restrictive standards will apply to the treated residue.
A-4.2.3 Landfill Disposal
A sampling/analysis program is an integral part of this phase of operation. The results of
this program serve to evaluate compliance with site permit conditions, confirm disposal
method selection, and determine safety constraints. Incoming wastes for which the
generator or treater has certified compliance with the LDR standards, as well as batches
that have been stabilized onsite by ACE facility, will be subjected to the "Suitability for
Landfill" analyses. See Table A-l in Section A-4 for these analyses. The "Suitability for
Landfill" testing is conducted to assure that the treatment process continues to be effective
in meeting the treatment standards.
For wastes that have been stabilized by ACE onsite, each batch will be analyzed for Landfill
Suitability.
For stabilized waste that is shipped to ACE for which the generator or treater has certified
full compliance with LDR treatment requirements, each shipment will be analyzed for
Landfill Suitability (i.e., 100% testing of shipments}. This frequency can be decreased if 10
successive shipments or batches meet all applicable LDR standards. Specifically, it can be
decreased such that 1 in 10 shipments is analyzed for all required parameters and every
shipment is analyzed for an indicator parameter to confirm treatment effectiveness.
However, if any shipment fails to meet the treatment standards post-treatment, 100%
testing must be resumed until 10 successive shipments meet all applicable LDR standards.
ACE will identify the specific offsite sources and waste profiles associated with the failed
shipment and ensure that 100% testing is applied to them.
An Additional Review Program (ARP} is used to further monitor incoming waste shipments
destined for the ACE facility landfill. Ten percent of shipments per month will be selected
randomly by on-site personnel as requiring additional review (not to exceed 20
shipments/month}. In addition onsite personnel may request additional review using the
sampling and analytical protocols from the ARP listed in this permit. Any additional request
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
will be justified by the state Director in writing. For the bulk solids, a composite will be
taken as described in Section A-8. The sample will be of sufficient volume to allow a split
sample to be supplied to the state Director. If a shipment of containers is selected, a 10%
composite of each profile destined for the ACE facility landfill on the load may be identified
for additional review. Further compositing of similar waste streams may be allowed with
state Director approval.
The Additional Review Program (ARP} samples are analyzed as follows:
RCRA Hazardous Wastes with Numerical (Concentration Based) LDR Treatment Standards
Sample will be analyzed for constituents listed for each EPA code associated with the
shipment for which numerical LDR standards have been promulgated. Additional
analyses may be requested by site management if justified, to address areas of concern.
Examples of these analyses include:
- TCLP metals
- PCB
Volatiles
Semivolatiles
Wastes that are to be stabilized on-site will have their compliance with LDR standards
verified according to the frequency specified in this WAP.
Loads destined for stabilization will be managed under site SOP for testing stabilized
residuals. Loads not requiring stabilization will be tested for LDR TCLP metals and
volatiles (e.g., Method 8240} with routine site detection limits. Other organics of
concern may be requested based on agreement by site management and state Director.
Due to the extensive listing of constituents, F039 ARP samples will be tested for routine
volatiles, semivolatiles and the characteristic TCLP metals.
Non-Hazardous Waste and Waste Without LDR Standards
TCLP metals: lead cadmium and chromium -these are very frequently found industrial
metals and a broad random screen is justified. The other five regulated TCLP metals
may be requested by site management if there is a concern about their presence based
on information on the waste profile.
PCB oil bearing waste as determined by a review of the waste profile will be tested.
2% Organic Limit Analysis (OLA] - a GC/FID screen is run for priority pollutants except
on oil bearing wastes. If petroleum hydrocarbons are identified in the scan, they may be
quantified by calculation as nonane. GCMS analysis may be used for confirmation as
needed. Alternately, other approved organic analysis methods, such as volatiles by
GCMS may be used to determine the concentration of the organic constituents. Organic
analysis to verify < 2 % is not required if the state Director has authorized a higher
percentage on a case-by-case basis as prescribed.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
If unexpected results are obtained during the ARP testing, the generator will be contacted
and we will attempt to resolve the issues. Questions will be raised as to the appropriate
hazard code classification and application of LDR standards. An update of the profile and
the disposal decision may be considered. If the analysis indicates that LDR standards have
been exceeded for wastes that are either stabilized off-site or certified as meeting the
treatment standards as generated, it shall be reported to the state Director.
No Free Liquids in Landfills
Under no circumstances will ACE allow the placement of bulk or non-containerized liquid
hazardous waste or hazardous waste containing free liquids in its landfill. ACE site
management will visually inspect each container to ensure that no free liquids are present.
If free liquids are detected, the facility will perform a paint filter test (or comparable test
required by the state] to confirm the absence or presence of free liquids. If the test
indicates their presence, ACE will remove them and perform the test again if necessary.
ACE site management also will determine the cause of the free liquids and make needed
adjustments to ensure they do not occur again.
A-5 Restricted Wastes ^k^r ^
ACE does not accept, for treatment or disposal, any current production waste or outdated
products which are listed as hazardous waste by EPA because it contains, as a hazardous
constituent (see 40 CFR Part 261, Appendix VII], a form of polychlorinated-dibenzo-dioxin
(PCDD] or polychlorinated-dibenzo-furan (PCDF] (e.g., F020, F021, F022, F023, F026,
F027, etc.}.
ACE also does not accept:
^L
Radioactive wastes.
Military or civilian ordance.
PCB wastes, as defined by TSCA (greater than or equal to 50 ppm}.
Gaseous wastes in high-pressure cylinders.
A-6 Rejection Policy
The purpose of this section is to set forth the policy and procedures that ACE will use for
the acceptance or rejection of waste received by the facility.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
A-6.1 Authority
ACE site management has the responsibility of insuring that the appropriate testing of each
incoming shipment of waste has been performed. They have the authority for acceptance
or rejection of each shipment.
A-6.2 Safety
The transporter delivering waste to the facility will abide by ACE's safety and operational
rules and regulations. Transporters will use trucks equipped with safely items and other
necessary equipment so the unloading of the materials can be accomplished safely.
Inadequate or unsafe equipment is reason for rejection of any shipment.
A-6.3 Scheduling
All incoming shipments of alternative fuels must be scheduled with ACE in advance. A
shipment arriving without the necessary pre scheduling may be rejected or significantly
delayed.
A-6.4 Documentation
All shipments of incoming waste materials may be accompanied by:
A manifest that complies with state and federal hazardous waste regulations.
Any other documentation required for the transport of said materials to the facility.
Incoming shipments arriving without the necessary documentation may be rejected.
Exceptions to this case may exist if material handled is shipped by rail and the manifest is
mailed separately.
A-6.5 Notification
In the event that an incoming shipment must be rejected, the onsite personnel will give
notification to the following entities:
ACE site management
Generator
Transporter
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
A-6.6 Rejection
A rejected shipment at ACE's facility shall be returned to the generator or the generator's
designated alternate facility. The generator will be notified that the shipment has been
rejected.
A-7 Discrepancy Resolution
As used in this WAP, a "discrepancy" is either:
A manifest discrepancy per 40 CFR 264.72, which includes significant differences
between the quantity or type of waste designated on the manifest or shipping paper, and
the quantity or type of waste the facility actually receives. Significant discrepancies are:
For bulk wastes, variations > 10% difference in weight.
For containerized waste, variation in piece count.
Variations in type discovered by inspection or waste analysis.
Rejected waste.
Container residue.
A discrepancy between the chemical or physical properties of a waste received at the
facility and its waste profile (e.g., pH that falls outside of its tolerance limits,
flammability, etc.}. Refer to Section A-9 of this WAP for information on the parameters
verified for incoming shipments and examples of discrepancies.
A-7.1 Manifest Discrepancy
All attempts will be made to resolve manifest discrepancy issues with the generator.
Resolution will be noted in the operating record. Unresolved discrepancies will be
submitted to the Regional Administrator by letter within 15 days from receipt of the
incoming shipment.
There may be situations where ACE will accept unmanifested waste shipments. Please refer
to 40 CFR 264.76.
A-7.2 Discrepancies Between Waste
Received at Facility and Waste Profile
If a discrepancy between the waste received at the
facility and its waste profile is identified, ACE will
perform the following before acceptance:
Discrepancies
Include provisions in the WAP for both
resolving discrepancies and ensuring
they do not recur, such as determining
if a new or revised waste profile is
needed and requiring the generator to
submit a corrective action plan.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
The generator is notified and requested to supply additional knowledge to assist in the
resolution of the concern(s}. If the generator supplies information that alleviates the
concern(s] identified, no further action is required.
The ACE site management and the generator discuss the discrepancy issue and identify
the appropriate course of action to resolve the container/shipment in question, i.e., pick
another sample set, return the container/shipment, divert the container/shipment to
another TSD unit that can accept the container/shipment and resolve the issue, or the
generator resolves the issue at the TSD unit. If the discrepancy issuefs] results in the
failure of a shipment, the chemical screening frequency for all streams that could
exhibit a similar issue(s] from the generator are adjusted to 100 percent until the
issuefs] adequately can be addressed.
On resolution of the initial discrepancy issue, ACE site management requests the
generator to provide a corrective action plan (CAP] that clearly states the reason for the
failure and describes the actions to be completed to prevent re-occurrence. The
generator could request a reduction in verification of additional streams that the
generator believes are unaffected. This request must be accompanied by a justification
that identifies why this stream(s] would not exhibit the same discrepancy issue.
ACE site management reviews the CAP and stream justification for adequacy. If the
stream justification is adequate, ACE site management could provide an alternative
frequency. ACE site management documents these actions and keeps this
documentation in the operating record in accordance with Section A-12.
A-8 Sampling Methodology
NOTE: Some portions of Section A-8 have been removed in order to shorten the overall length of this example
WAP. This was done solely for purposes of presentation in this guidance document.
Sampling is performed by the ACE facility and by (or as directed by] the waste generator at
the generator's facility. Specific sampling procedures are dependent on both the nature of
the material and the type of containment. SW-846 states that, "a less comprehensive
sampling approach may be appropriate if information regarding the distribution of waste
components is known or assumed." This section presents sampling methodologies to be
utilized on-site by ACE personnel.
When a waste arrives at the facility for management, a determination has previously been
made by the generator that the waste is either:
1. a listed hazardous waste in 40 CFR Part 261, Subpart D;
2. a characteristic waste as defined in 40 CFR Part 261, Subpart C; or
3. a non-hazardous waste.
The generator-supplied characterization provides ACE with information concerning both
the distribution and nature of the waste components (see Section A-2 for discussion
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
regarding the information or data to be supplied by the generator}. The purpose of the
inspection, sampling or analysis when a waste material arrives at the site is to ensure that
the shipped waste matches the description of the waste designated on the accompanying
manifest or shipping paper and WPS.
Therefore, ACE can often use a less comprehensive sampling approach, as described in
Sections A-8.2.1, to yield a waste identification sample (see EPA documents SW-846 "Test
Methods for Evaluating Solid Waste", Third Edition, September 1986, Chapter Nine}.
A-8.1 General Methods and Equipment
As practicable, the sampling techniques used for specific types of waste correspond to
those referenced in 40 CFR 261, Appendix I and presented in Table A-5. Because Appendix I
sampling methods have not been formally adopted by the EPA Administrator, ACE may
modify the technique as necessary to obtain a representative sample. Any changes made
after final permitting will be forwarded to the state Director for review and acceptance. The
sampling equipment and procedures described in this WAP represent the facility's
recommended sampling protocol for general types of waste material and containment.
Specific waste materials or shipments may require different sampling techniques.
Therefore, deviations from the recommended protocol do not constitute an excursion from
acceptable sampling practices or the conditions of this WAP. All methodologies will be
updated and revised as the references are updated and revised.
A-8.2 Specific Methods and Equipment
In addition to ASTM and EPA sampling procedures, ACE has instituted specific
methodologies for taking samples from various containment sources. The type of container
may be transportable (e.g., such as drums}, portable transport units (e.g., tanks, roll-off
boxes}, and tanker or dump trucks; or stationary, such as tanks, in-process sources, waste
piles, and containments. The sampling devices are selected depending on the size and type
of containment and on the specific material involved. The device to be used in each
situation is described below.
Access to any type of container will influence the location within the container from which
samples can be taken. Samples will be taken to address vertical variations in the waste
because there is a much greater tendency for wastes to be heterogeneous in a vertical
rather than a horizontal direction, and horizontal variations are generally easier to detect if
examination indicates strata in the waste, then each layer may be composited in proportion
to its estimated volume or sampled individually.
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TABLE A-5: Sampling Methods and Equipment
terial (or waste type
Extremely viscous liquid
Crushed or powdered material
Soil or rock-like material
Soil-like material
Fly ash-like material
Containerized liquids
ASTM DI40a
ASTME300a
ASTMD346a
ASTME300a
ASTMD420a
ASTM E300a
ASTM D1452a
ASTM E300a
ASTM D2234a
ASTME3003
SW-846B or
ASTME3003
Tubing, thief or Coliwasa
Tubing, trier, scoop, or shovel
Tubing, trier, auger, scoop, or shovel
Tubing, trier, auger, scoop, or shovel
Tubing, trier, auger, scoop, or shovel
Coliwasa, tubing, weighted bottle,
bomb, or tank sampling port
a American Society for Testing Materials. Annual Book of ASTM Standards. Philadelphia, PA. 1982 or most recent edition.
b Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Third Edition, U.S. Environmental Protection Agency, Office
of Solid Waste, Washington, DC, September 1986, as amended by all recent updates.
A-8.2.1 Containers and Tanks
A container is a portable device in which a material is stored, transported, treated,
disposed of, or otherwise handled. The sampling of small containers (e.g., drums, cartons,
and other small units] varies with the physical nature of the waste material. For
flowable materials, the sampling device of choice is either a Coliwasa unit or open tube
sampler, which is used to draw a full vertical section. Drums of aqueous and organic
liquids are sampled with a four foot glass tube. A composite sample may be obtained by
mixing equal portions of each container included in the sampling lot. Solids or sludges or
other small containers are sampled with a scoop (disposable plastic or using the bottle
itself) or a shovel if a heavy digging tool is required. If the material on top appears non-
representative (e.g., "speedi-dry, "oil dry", etc.], a subsurface sample will be obtained. The
top portion may be transferred to another container in order to obtain a subsurface
sample. Alternately, a metal sample thief, trier or tubing (a piece of conduit or small
diameter pipe] may be used to obtain a core sample of the drummed solid.
A-8.2.2 LDR "Grab" Sampling
The Land Disposal Restrictions, 40 CFR 268, have specified the use of "grab" sampling for
most of the compliance demonstrations to the Land Disposal Restrictions BOAT treatment
standards.
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A-9 Parameters and Analytical Methods
NOTE: The text and table in this section have been shortened in order to reduce the overall length of this
example WAP. This was done solely for purposes of presentation in this guidance document.
The parameters which constitute the analyses performed by ACE facility are identified in
Table A-6. ACE will use either SW-846 or ASTM methods for each parameter, as shown in
the table. ACE has its own laboratory SOPs which the laboratory follows. The analytical
parameters and techniques used by ACE through its operating experience have been
chosen for their ability to provide the information required to properly manage a waste.
TABLE A-6: Analytical Parameters, Reference Methods, ACE Method, and Rationale
Physical Description
pH Screening
PCB Screening
Suitability for Landfill3
Water Screening Mix
Flammability Potential Screening
Reference Methods
Not applicable
SW-846 9045
ASTM D4980
SW-846 3580
SW-846-8000
SW-846 8082
SW-846 1311
ASTM D4982
ASTM 505
ACE Method #
Visual Inspection
ACE-4
ACE-3
ACE-6
ACE-10
ACE-7
Verification and system
compatibility
Verification and system
compatibility
Prohibited material
Verification and system
compatibility
Verification and system
compatibility
Verification and system
compatibility
a Suitability for Landfill involves mandatory verification, a leachable metals assessment if the waste contains metals, as well as additional tests
if needed (e.g., tests for cyanides). This row of the table addresses only to the leachable metals assessment (i.e., Toxicity Characteristic
Leaching Procedure).
Following is a discussion of the methodfs] and rationale for each parameter:
Physical Description is used to determine the
general physical characteristics of the waste
(e.g., color, waste form}. This facilitates
subjective comparison of the waste with prior
waste descriptions or samples.
pH Screening is undertaken to indicate the pH
range and the general corrosive nature of the
waste. pH screening may not apply to certain
waste types, e.g., organic waste, or insoluble solid waste. For each approved waste
stream, tight tolerance limits (e.g., +/- 2 pH unit change] will be established based on
the operating requirements of the relevant treatment and disposal systems at the
facility and other relevant considerations. If the pH of an incoming shipment falls
Tolerance Limits for Fingerprint Tests
The purpose of the fingerprint tests is to
verify that the shipment matches its
manifest and waste profile. Consider
establishing tolerance limits for one or
more parameters such that verification can
be made objectively (see pH screening).
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outside of this range, re-qualification will take place to review the waste and update
its WPS.
PCB Screening is used to ensure that no materials are stored or used at the facility that
would require a Toxic Substances Control Act permit. PCB wastes, as defined by TSCA
(greater than or equal to 50 ppm], will not be accepted at the facility.
Suitability for Landfill is a testing program that assesses the acceptability of the
stabilized waste for land disposal. All stabilized wastes to be disposed of in the ACE
landfill are subjected to mandatory verification, a leachable metals test if applicable, as
well as additional tests deemed appropriate. Waste streams that are to be land disposed
after being stabilized are classified into general categories.
1. Inorganic solids and sludges with no RCRA metals (e.g., calcium fluoride, sulfate, and
phosphate mixture]
Mandatory verification.
2. Inorganic process sludges and solids with metals (e.g., WWT sludges with F and
D codes]
Mandatory verification.
Leachable metals assessment.
3. Soil or other inorganic solids with metals (e.g., fly ash with lead, 0 code materials]
Mandatory verification.
Leachable metals assessment.
4. Inorganic solids with cyanide, which may include metals (e.g., potliner]
Mandatory verification.
Leachable metals assessment may be performed.
If cyanide screening is positive, analyze for cyanides amenable to chlorination or
total cyanide to determine whether the waste qualifies for land disposal.
Water Mix Screening is used to determine whether the waste has a potential to
vigorously react with water to form gases or other hazardous products, or whether it
generates significant heat. This testing does not apply to wastes that are already in
contact with excess water, or for which sufficient analytical data exist that indicate no
potential reactivity with water.
Flammability Potential Screening is used to indicate the fire-producing potential of the
waste. This testing can be applied to all waste liquids, semi-solids, but need not be
applied if other information (e.g. WPS in conjunction with the results of the other
screens, SDS, etc.] indicates the waste is not ignitable.
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A-10 Quality Assurance /Quality Control
A-10.1 Introduction
The following Quality Assurance/Quality Control (QA/QC] information for the ACE facility
is being provided as required by 40 CFR 270.30(e] and in accordance with the following
EPA guidance documents.
QA/QC procedures are applicable to both sampling procedures and analytical techniques.
QA/QC information for these two elements of the waste analysis program has been
included in this Waste Analysis Plan (WAP] as recommended in the waste analysis plan
guide manual.
This section does not provide specific performance standards or quality control procedures
for individual sampling and analysis techniques. Such specifics are defined on a corporate-
wide basis for all ACE facilities. The specific performance standards are dynamic and are
revised as warranted to reflect technological advances in sampling and analytical
techniques. ACE QA/QC policies are found in the corporate Quality Assurance and Control
Policies, portions of which have been extracted and included in the following sections. The
performance standards will be available for review at the facility.
A-10.2 Sampling Program
Sampling procedures for specific facility operations are described in Section A-8 of the
WAP. The selection of the sample collection device depends on the type of sample, the
sample container, and the sampling location. The selection and use of the sampling device
is supervised by the QA Manager, who is thoroughly familiar with both the sampling and
analytical requirements. The type of device to be used in the various sampling situations is
speed in Section A-8.2, Specific Methods and Equipment.
Sampling equipment is constructed of non-reactive materials such as glass, PVC plastic,
aluminum, or stainless steel. Care is taken in the selection of the same pier to prevent
contamination of the sample and to ensure compatibility of materials. The specific material
of construction to be used for each sampling activity is specified in Section A-8.2.
Sampling is performed for each waste stream in a manner that ensures the samples are as
representative as possible under the conditions of the sampling event. Full vertical sections
are drawn from tanks and containers, where appropriate and where access allows, as
described in Section A-8.2.
With a few exceptions, all bulk and containerized waste loads will be sampled (see Section
A-4}. Container samples that are related to one generator and waste profile may be
composited prior to analysis, provided that individual samples are similar in physical
appearance. Precautions are taken to minimize loss of volatiles.
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All samples must be appropriately labeled. No field notebook is used in sampling
hazardous waste shipments or process samples. Anything unusual noted during sampling
would be noted in the comments area of the label. No chain of custody form is employed
within the plant. The samples are turned directly into the lab. A chain-of-custody will
accompany any sample being sent to a contract lab. Sampling information is entered into
the facilities operating record.
Hazardous waste samples are generally not amenable to preservation. For samples
collected at ACE for organic analysis, the preservation and holding times will be in
accordance with Chapter 4 of SW-846. Samples for 2% Organic Limit Analysis screen will
generally be analyzed within 14 days. For treated wastewater samples from the plant,
metals aliquots are preserved by the addition of HN03 to pH <2 and cyanide aliquot is
preserved by the addition of NaOH to pH > 12. After TCLP extraction for leachable metals
an aliquot for metals is fixed by adding HN03 to pH < 2.
A-ll Data Reporting
ACE will report discrepancies to EPA if they are not resolved within the timeframes
specified at 40 CFR 264.72. In addition, ACE will supply any analytical data to EPA when
requested. This includes the following information, which must be kept at the facility:
Receiving Papers - Date, time, sample ID, customer name, stream ID, and sample
receipt/delivery.
Worksheet Raw Results - For each test (instrument readings, sample weights, etc.],
date, initials of analyst, and sample ID.
Sample Master Logbook - Date, sample ID, type, initials, result, etc.
Calibration and Performance Sample Results - Initials, result, results of calibrations,
duplicates, known standards, blanks, blind samples, and reference samples. QC results
are compiled and each set of results will be compared with QC limits, and records
should show the basis for QC limits.
Instrument Maintenance and Repair Record On the Following Analytical Systems -
ICPs, GCs, calorimeters, ion chromatographs, and Hg analyzer.
A-12 Recordkeeping
ACE maintains the Laboratory Information Management System (LDMS} to automate the
waste disposal process using comprehensive application software packages. The system
automates the major aspects of waste treatment and disposal (waste analysis data,
discrepancies, corrective actions, etc.] to improve the efficiency and minimize data errors.
Waste tracking, laboratory data management and process control interface are major
components of waste disposal that are automated by the LDMS.
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A complete set of records will be maintained at the facility for each generator, including
information generated during pre-acceptance, acceptance, and waste treatment. This
information will include, but not be limited to:
WPS
Pre-qualification analysis
SDSs (if available]
Generator laboratory analysis (if available]
Sample log sheets
Photocopy of each manifest
Records demonstrating compliance with, and decisions made under the analyses
performed by ACE facility. In particular, a record of all analyses will be maintained by
ACE for each waste sampled/analyzed, as part of the facility operating record. The
mandatory and supplemental analyses records will include:
A copy of the chain of custody document
Copies of all applicable analytical and test results and lab reports including the
results of the mandatory analysis
A copy of the original (incoming] manifest
A copy of the original WPS
Documentation of any discrepancies identified by verification analyses
If applicable, a copy of any written or correspondence with the generator related to
resolving a WPS discrepancy and documentation of relevant conversations with the
generator regarding same.
If applicable, copies of any written correspondence with the generator and state
Director related to resolving a manifest discrepancy and documentation of relevant
conversations with the generator or state Director regarding same.
If applicable, a copy of the revised WPS
Records documenting ACE's records to resolve discrepancies between an incoming
waste and its waste profile.
In addition, ACE will produce bi-annual reports that
summarize the following for state inspector review:
The frequency at which incoming shipments do not
conform to their waste profiles. The report must
indicate the steps taken by the facility to evaluate
and resolve the discrepancies, including if new or
revised WPSs were produced.
Facility-Prepared Reports
When perparing the WAP, include
provisions to assist regulators during
compliance inspections, such as
facility-prepared reports summarizing
key problems and difficulties
encountered.
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The frequency at which treated wastes do not meet the LDR treatment standards. The
report indicates the steps taken by the facility evaluate the incoming wastes and
treatment process to resolve failures.
All waste analysis records will be kept as a part of the facility operating record and will be
maintained as required by law.
A-13 Corrective Action
While the goal of the ACE QA/QC program is to provide sufficient training, equipment,
facilities, technical support, and supervisory oversight to avoid inadequate measurements
or data, it is recognized that data quality can fall outside established limits for a variety of
reasons. The program provides for reporting and reviewing procedures that permit early
and effective corrective action should it be needed. Specifically:
All samples are registered and tracked via an electronic Laboratory Data Management
System (LDMS} to ensure that the necessary analyses are performed.
Data generated each day are entered into appropriate logbooks and the LDMS tracks
each sample. These systems provide an opportunity for quick review of the data to see
if the various results are internally consistent. Apparent discrepancies are brought to
the attention of site management.
The site management reviews completed data information on all samples prior to shipment
receipt. This data is then filed for future reference.
If problems are found, several corrective actions are considered depending on the apparent
source. These include, but are not limited to:
Re-sampling
Re-analysis of the sample
Performance audit of the analyst
Systems audit
Inter laboratory comparison study
Review of SOP for error or inadequacy.
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Appendices
NOTE: The information in the appendices has been omitted to reduce the overall length of this example WAP.
This was done solely for purposes of presentation in this guidance document.
Appendix A-1 Waste Profile Sheet
The waste profile sheet (WPS] has been removed from this WAP. See Figure 2-9 of this
manual for an example of a WPS.
Appendix A-2 Overview of the Pre-Acceptance Process
The overview has been removed from this WAP. See Section 1.2 of this manual for a
discussion of the pre-acceptance process.
Appendix A-3 Overview of the Incoming Load Process
The overview has been removed from this WAP. See Section 2.9 of this guidance for a
discussion of procedures for handling incoming loads.
Appendix A-4 Aqueous Waste Treatment
The diagram of aqueous waste treatment has been removed from this WAP.
Appendix A-5 Landfill and Stabilization
The diagram of landfill and stabilization has been removed from this WAP.
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Example WAP 2: Waste Analysis Plan of
Container Management Incorporated (CMI)
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Table of Contents
1.0 General Overview 4-36
2.0 Waste Prequalification Procedures 4-37
2.1 Waste Information Profile ("WIP") 4-37
2.2 Determination of Outbound Designated Facility 4-38
2.3 Lab Pack Waste 4-38
3.0 Acceptable Waste Codes 4-38
4.0 Analysis and Acceptance 4-38
4.1 Level I Analysis 4-40
4.2 Level II Analysis: 4-41
4.3 Level III Analysis: 4-42
4.4 Final Acceptance and Placement of Waste in Storage 4-43
5.0 Restricted Wastes 4-43
6.0 Rejection Policy 4-43
7.0 Discrepancy Policy 4-44
7.1 Manifest Discrepancies 4-44
7.2 Discrepancies Between the Waste and WIP 4-45
8.0 Outbound Waste Screening Procedures 4-45
9.0 Waste Sampling 4-46
9.1 Sampling Methods 4-46
9.2 Sam pie Tracking Documentation 4-46
9.3 Sampling Personnel 4-46
9.4 Sample Labels 4-46
10.0 Parameters and Rationale 4-47
11.0 Test Methods 4-48
12.0 Quality Assurance and Quality Control 4-52
12.1 Sampling Program 4-52
12.2 Analytical Program 4-52
12.3 Conclusion 4-53
13.0 Recordkeeping and Reporting 4-53
14.0 Corrective Action 4-54
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Appendices 4-55
Appendix C: Standard Operating Procedures for Opening and Sampling Containers 4-56
Appendix D: Bulk Consolidation Tracking Sheet 4-57
Appendix F: Example Level I QA/QC Report 4-58
Appendix G: Level ll/lll QA/QC Checklist 4-59
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1.0 General Overview
Pursuant to 40 CFR 270.14 (b}(3}, a hazardous waste management facility is required to
develop and follow a Waste Analysis Plan (WAP] that meets the requirements of 40 CFR
264.13 (b} and (c}. This waste analysis plan establishes the following:
The procedures for qualifying, accepting and analyzing the contents of each waste
container managed at Container Management Inc. ("CMI"}.
The waste analyses and supplemental information that hazardous waste generators or
their authorized agent (customers] will supply.
The frequency at which analysis of waste will occur to ensure that waste is
characterized accurately.
Procedures for handling discrepancies and rejected shipments.
The methods used to obtain a representative sample of waste to be analyzed.
The parameters for which each waste will be analyzed and the rationale for selecting
these parameters.
The test methods used to test for each parameter.
A quality assurance/quality control (QA/QC} program for waste sampling and analysis,
along with a corrective action program.
The recordkeeping and reporting procedures associated with this WAP.
Emphasis is placed upon obtaining accurate information about the chemical and physical
makeup of each waste received by CMI. This information, which is to be detailed in a waste-
specific Waste Information Profile (WIP} maintained as part of the facility record, may be
based on the generator knowledge of the waste and/or chemical and physical analyses of a
representative sample of the waste.
CMI accepts "containerized" and "bulk" waste for storage prior to consolidation and/or
shipment off-site. Wastes managed by CMI may be regulated under the Resource
Conservation and Recovery Act (RCRA}, the Toxic Substances Control Act (TSCA},
Superfund (CERCLA}, and the state's Hazardous Waste Management Regulations (HWMR}.
CMI accepts wastes in a variety of physical forms, including liquids, sludges, solids, and
compressed gases. For the purposes of this WAP, "containerized" waste is waste managed
in containers that can be moved manually or with a forklift (e.g., U.S. Department of
Transportation ("U.S. DOT"} approved shippable containers, drums, pails, bags, boxes,
pallets, ton sacks, flasks, cylinders}. "Bulk waste" is received and shipped in accordance
with applicable U.S. DOT regulations.
CMI also accepts "lab packs" which are containers that hold a variety of chemicals, products
or small quantities of laboratory samples. Each lab pack container is prepackaged in
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
accordance with applicable U.S. DOT regulations that are based on compatibility, content,
and size of individual samples. An inventory-packing list accompanies each lab pack
container and identifies, among other things, the content, quantity and size of each
container within the lab pack, and applicable RCRA and state-specific hazardous waste
code(s}. See Appendix B of this WAP for an example Lab Pack form.
CMI also accepts "bulk or consolidation packs" that are containers that hold one type of
material (e.g., paints}. Each bulk or consolidation pack container is prepackaged in
accordance with applicable U.S. DOT regulations.
2.0 Waste Prequalification Procedures
All waste accepted by CMI must be approved through the prequalification process. As
described below, the prequalification process requires completion of a Waste Information
Profile (WIP] by the generator or their authorized agent, and review and approval of the
WIP by CMI.
2.1 Waste Information Profile ("WIP")
A WIP must be completed, signed and submitted by the waste generator or the generator's
authorized agent for each waste received by CMI. A sample of the waste may be necessary
for prequalification purposes.
Each WIP is reviewed by CMI to determine if CMI can accept the waste. The CMI WIP form
is included in Appendix A of this WAP. A generator may use a different WIP form, provided
the form is reviewed by CMI and found to be equivalent to the CMI form.
Based on the sample and information provided in the WIP, a CMI Supervisor or Senior
Waste Technician may either approve the WIP or determine that additional information is
necessary prior to approving the waste. A WIP shall not be approved if any pertinent
section of a WIP is omitted; an inconsistency is identified on the WIP (e.g., acidic solution
with pH 14}; the generator does not provide sufficient information about the waste
generating process and/or materials used in the process.
In the event that a WIP is not approved, additional information (e.g. SDS] must be provided
or the waste must be analyzed further before the WIP can be approved by CMI. The WIP
shall document the use of generator knowledge and/or analysis in making a hazardous
waste determination. All supporting documentation must be included with the copy of the
WIP maintained at the CMI facility. Any completed WIP for waste that is unused "product"
material, with the exception of household-generate wastes and waste contained within lab
packs, must include a Safety Data Sheet. In all cases, if the CMI Supervisor or Senior Waste
Technician is not confident that a waste has been characterized accurately, he or she shall
not approve the WIP.
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Upon approval of a WIP, the CMI Supervisor or Senior Waste Technician shall ensure that
the applicable CMI "process code" and CMI "approval code" information is added to the top
of the WIP form.
Each WIP must be reviewed by the generator or the generator's authorized agent on an
annual basis. Following this review, the generator or authorized agent must provide a
signed statement to CMI that either certifies the waste generating process and the chemical
and physical characteristics of the waste remain unchanged or specifies any changes to the
waste or generating process. If a signed certification statement is not returned to CMI, the
WIP will be canceled.
2.2 Determination of Outbound Designated Facility
As part of the prequalification process following WIP approval, the CMI Supervisor or
Senior Waste Technician also selects a designated facility to which CMI will likely ship the
waste after the waste has been received by the CMI facility. Selection of the designated
facility is based on the WIP, assigned RCRA and state-specific hazardous waste codes, any
applicable land-disposal restriction regulations, generator request/requirement, and any
requirements or restrictions of the designated facility's permit or license. Upon selection of
a designated facility, approved waste may be scheduled for transport and delivery to CMI.
2.3 Lab Pack Waste ^^^"^^
In addition to the prequalification requirements described in sections 1.1 and 1.2, above,
for each lab pack waste stream, the CMI Supervisor or Senior Waste Technician must
review and approve a packing list compiled for each lab pack container using the Lab Pack
Contents Form (see Appendix B of this section}. If any incompatible or unacceptable
material is listed on the Lab Pack Contents Form, the generator or generator's agent is
given the option of either properly repacking that material or having the lab pack container
rejected by CMI.
3.0 Acceptable Waste Codes
This facility is permitted to accept the vast majority of RCRA hazardous waste codes in the
state's Hazardous Waste Regulations. See Part A of this permit for a full list of the codes
that CMI is permitted to accept.
4.0 Analysis and Acceptance
When a shipment of waste (containerized waste, bulk waste, and/or lab packs] arrives at
the CMI facility, a CMI Supervisor or Senior Waste Technician is responsible for either
receiving or rejecting the waste upon completing the following procedure:
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Review the manifest or shipping paper for accuracy and completeness
Unload containers to the CMI waste receiving area (i.e., Cell A-l]
Check container labels for completeness and consistency with the WIP
Check the condition of each container and verify that it is U.S. DOT-approved
Verify that each container type is consistent with the information on the WIP, manifest
and waste stored therein
Assign a unique container number to each container using the facility computer system,
and affix a sticker marked with that unique number to the container
Perform the Level I waste analysis procedure described below
If applicable, perform the Level II and Level III waste analysis procedures described
below
CMI will utilize a tiered approach for analyzing incoming shipments at the facility. A Level I
analysis will be performed on each shipment received. Level II analysis will be performed
when the Level I analysis indicates unresolved discrepancies between the waste and its
WIP. Level III analysis will be applied to all containers received on a periodic basis (e.g., to
evaluate the accuracy of the WIPs maintained by CMI}. Table 1 gives an overview of these
analyses and Table 2 summarizes their frequency. Refer to Sections 4.1 through 4.3 of this
WAP for additional information on the Level I, II and III analyses.
TABLE 1: Analyses Performed by CMI Facility
Incoming Shipments"
Parameters Pre-Qualification
% Liquid % Solid % Sludge by content
Color
Viscosity
pH Screen, except solid and non-aqueous
wastes
Water Reactivity
Reactive Sulfides Screen
Ignitability
Reactive Cyanides Screen (Spot Test)
X
X
X
X
X
X
X
X
Level 1
X
X
X
X
NA
NA
Xc
NA
Level II
NA
NA
NA
X
X
X
X
X
Level III
NA
NA"
NA"
X
X
X
X
X
a. As used in this table, NA = not applicable
b. These parameters are analyzed under Level I.
c. If the evaluation of waste properties indicates that the waste is potentially ignitable, CMI will screen the waste for flash point utilizing a
bench-top screening procedure.
NOTE: Table 1 has been shortened in order to reduce the overall length of this example WAP. This was done
solely for purposes of presentation in this guidance document.
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TABLE 2: Frequency of Analysis
uahfication
Each waste will be sampled,
with limited exceptions
Visual inspection of each
bulk load and container
Sampling of each bulk load
Sampling of each
container in a shipment,
except that:
- In the case of multiple
containers of the
same profiled waste, 1
sample will be taken
from 1 out of every 10
containers
- Samples will not be
taken for specified
wastes3
Incoming Shipments
Level II
If Level I analysis
identifies a discrepancy
between the waste and
WIP and it cannot be
resolved with the
generator, a Level II
analysis is performed b
The contents of 1 out of
every 500th container
of waste (including
solid and non-
hazardous waste)
received by CMI will be
sampled and tested
a. Exceptions are for lab packs and non-sampleable wastes (e.g., fluorescent lamps).
b. Alternatively, the waste can be rejected back to the generator or forwarded to an alternative TSDF.
4.1 Level I Analysis
The CMI Supervisor or Senior Waste Technician will open and inspect each container and
bulk load in the waste receiving areas (i.e., Cell A-l for containers, and within the outdoor
secondary containment bays for bulk loads}. With the exception of multiple containers of the
same waste (i.e., waste described by the same WIP and that appear consistent upon visual
inspection], Lab Packs, and other "non-sampleable" wastes (e.g., fluorescent lamps, batteries,
PPE], a sample will be collected from each container and bulk load in accordance with the
facility's Sampling SOP (see Appendix C of this section] for the purpose of performing Level I
analysis. In the case of multiple containers of the same waste, each container will be opened
to visually confirm consistency between waste in the various containers, but only a single
sample will be collected from one of every ten containers received. For lab packs, the content
of each container is compared to the Lab Pack Contents Form.
Upon opening each container, the waste will be visually compared to information on the
container label, manifest, and WIP. For liquids and semi-solids, a thief/tube will be used to
check for layering and, if applicable, to determine the approximate percentage of each
layer. The collected sample will be evaluated for the following properties:
% Liquid, % Solid, % Sludge content (by CMI-1 method]
Color (CMI-1]
Viscosity (CMI-1]
pH (CMI-2], except for solid and non-aqueous wastes
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
If the evaluation of waste properties indicates that the waste is potentially ignitable, CMI
will screen the waste for flash point utilizing a bench-top screening procedure (CMI-5}.
Waste streams that are potentially subject to flash point screening include: non-lab pack
wastes, non-virgin products, and liquid wastes that are not already characterized as
exhibiting the characteristic of ignitability (D001}.
The results of the visual inspection and sample evaluation will be compared to the WIP. If
the Level I analysis identifies a discrepancy with the WIP, CMI will immediately contact the
generator or the generator's agent and attempt to resolve the discrepancy.
Any waste that does not conform to the WIP will be quarantined in Cell A-l. If the
discrepancy is resolved by contacting the generator, the waste will be moved to an
appropriate storage cell by the end of the work shift. If the discrepancy cannot be resolved
by the generator, CMI will follow the Level II procedure below, and the waste will remain
quarantined in Cell A-l.
Level 1 analysis is documented using the Level I QA/QC report (see Appendix F of this WAP}.
4.2 Level II Analysis:
If the Level I analysis identifies a discrepancy with the WIP, and the discrepancy cannot be
resolved, then CMI will perform Level II analysis of the waste, reject the waste back to the
generator, or ship the waste to an alternate TSDF in accordance with the Discrepancy
Policy in Section 7.0 of this WAP. CMI will make every effort to resolve the discrepancy and
accept the waste. The state's Waste Management Division will be notified of any wastes
rejected back to generators in the state, as described in the Rejection Policy in Section 6.0
of this WAP. Level II analysis includes the following tests, as appropriate:
pH Chlorine Spot Test
Water Reactivity Polychlorinated Biphenyl (PCB] Screen
Reactive Sulfide Spot Test Flash Point
Ignitability Free Liquids/Paint Filter Test
Reactive Cyanide Spot Test RCRA 8 metals
Oxidizer Screen Volatile Organics
Specific Gravity Any other parameter deemed necessary
% Suspended Solids
Any waste that is subject to Level II analysis will be quarantined in Cell A-l until the
discrepancy with the WIP is resolved.
Level II analysis will be subcontracted to an independent state certified or NELAC
laboratory that uses ASTM and/or SW-846 analytical and test methods. The results of all
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Level II analyses will be documented in a log (see Appendix G of this WAP] maintained as
part of the facility operating record.
4.3 Level III Analysis:
CMI will select and analyze waste samples received at the facility as follows:
The contents of one out of every 500 containers of waste (including solid and non-hazardous
waste] received by CMI will be sampled and tested according to this Level III analysis
procedure. CMI's container tracking system will be used to identify every 500th container
received by CMI in sequential order. In the event that the contents of the 500th container
cannot be sampled (e.g., batteries, CRTs, lamps, lab packs, etc.], or is verified to be either an
unused "product" material (SDS available] or household hazardous waste, CMI will count
forward (i.e., 501st, 502nd, etc.] until a container of waste is located that can be sampled. CMI
will document the unique container number(s] of each waste container that is by-passed in
the facility operating record along with the rationale for by-passing each container.
On an annual basis, CMI will review the Level III analysis procedure and the previous year's
Level III analysis results (i.e., testing data] to ensure that a variety of waste types and
customers have been, and will continue to be, represented. This annual review will be
documented in the facility operating record. Any potential changes to the Level III analysis
procedure that are identified by CMI based on this review should also be documented in
the facility operating record.
Once a container is identified for the purpose of conducting Level III analysis, the CMI
Supervisor or Senior Waste Technician will collect a sample in accordance with CMI's SOP
(see Appendix C of this section]. In addition to completing Level I analysis and
documenting the physical description of the waste, the following parameters will be tested,
as appropriate:
pH Chlorine Spot Test
Water Reactivity Polychlorinated Biphenyl (PCB] Screen
Reactive Sulfide Spot Test Flash Point
Ignitability Free Liquids/Paint Filter Test
Reactive Cyanide Spot Test RCRA 8 metals
Oxidizer Screen Volatile Organics
Specific Gravity Any other parameter deemed necessary
% Suspended Solids
Level III analyses will be subcontracted to an independent state certified or NELAC
laboratory that will use ASTM and SW-846 analytical and test methods.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
A record of all Level II and Level III analysis will be maintained by CMI for each waste
sampled/analyzed, as part of the facility operating record. The Level II and Level III records
are described in Section 13.0 of this WAP.
If a WIP is determined to be inaccurate through Level II or Level III analyses, the CMI
Supervisor or Senior Waste Technician will review for accuracy all other WIPs
corresponding to wastes generated by the generator who submitted the inaccurate WIP.
4.4 Final Acceptance and Placement of Waste in Storage
Upon verification that a containerized waste or bulk waste is consistent with the
corresponding WIP, the waste will be moved from the receiving area (Cell A-l] to an
appropriate storage cell. Movement to an appropriate storage cell shall occur within the
timeframe specified in the state regulations (e.g., 24 hours] from the transport vehicle.
Any waste that does not conform to the corresponding WIP will be quarantined in Cell A-l
until the discrepancy is resolved with the generator. Upon resolution of the discrepancy,
the waste will be moved to an appropriate storage cell by the end of the work shift.
5.0 Restricted Wastes ^^^^ ^^^
There are few restrictions on the wastes that CMI can accept. We cannot accept:
Radioactive wastes.
Conventional or chemical ordnance.
Gaseous wastes in high-pressure cylinders.
6.0 Rejection Policy
It is the policy of CMI to follow the procedures set forth at 40 CFR 264.72 when managing
rejected loads and non-empty containers (i.e., container holding residues that exceed the
quantity limits for "empty" containers set forth at 40 CFR 261.7(b}}. Specifically, CMI will
perform the following actions after a decision is made to reject a waste or residue:
Obtain or confirm the generator's directions on where to forward the rejected waste or
residue (i.e., either back to the generator or to alternative TSDF};
While the shipment is waiting to be forwarded, ensure that it is stored securely by the
delivering transporter or by CMI. CMI will secure the waste in Storage Unit 22, which is
a fenced area with drainage and protection from weather;
Send the rejected waste or residue off-site within 60 days, if applicable;
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Ensure the rejected load or residue is re-manifested in accordance with 40 CFR
264.72(f)-(g); and
Maintain records of the above actions. Refer to Section 13.0 of this WAP for
recordkeeping.
7.0 Discrepancy Policy
CMI will adhere to the following procedures when attempting to resolve discrepancies.
7.1 Manifest Discrepancies
A manifest discrepancy is defined at 40 CFR 264.72 as significant differences between the
quantity or type of waste designated on the manifest or shipping paper, and the quantity or
type of waste the facility actually receives. It also includes rejected wastes and container
residues. CMI will follow the procedures in section 264.72 to address manifest discrepancies:
Attempt to resolve the discrepancy (e.g., by calling the generator};
If the discrepancy cannot be resolved within 15 days, send a letter immediately to the
state's Waste Management Division describing the discrepancy and attempts to resolve
it, along with a copy of the manifest at issue;
Decide if the waste can be accepted by CMI despite the discrepancy. This involves a
determination whether CMI can manage the waste on-site in a manner that is safe,
effective and in accordance with the provisions of its permit;
If the waste cannot be accepted, reject it in accordance with CMI's Rejection Policy in
Section 6.0 of this WAP;
Perform a WIP re-evaluation to determine if a new or revised WIP is necessary. This
could involve sending the WIP to the generator for re-evaluation and re-certification.
The new or revised WIP will be subjected to the Pre-Qualification process described in
Section 2.0 of this WAP; and
Maintain records of the above actions. Refer to Section 13.0 of this WAP for
recordkeeping.
Note: CMI does not accept "unknown" wastes. All wastes received by CMI must be
approved prior to shipment to the CMI facility. In the event that an unknown waste is left at
the CMI facility during off hours, CMI will immediately contact the state's Waste
Management Division. Following this consultation, CMI will attempt to identify the waste
using Level I and/or Level II analyses for the purpose of accepting the waste or preparing
the waste for shipment to an appropriate off-site facility.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
7.2 Discrepancies Between the Waste and WIP
If a discrepancy between the waste received at the facility and its WIP is identified (e.g.,
discrepancy in pH, flammability, etc.], CMI will perform the following:
Attempt to resolve the discrepancy by calling the generator and requesting additional
information;
Decide whether to accept or reject the waste despite the discrepancy. This involves a
determination whether CMI can manage the waste on-site in a manner that is safe,
effective and in accordance with the provisions of its permit;
If a decision is made to reject the waste, follow the procedures in the Rejection Policy in
Section 6.0 of this WAP;
If the waste is not rejected, perform a Level II analysis to fully characterize the waste.
Refer to Section 4.0 of this WAP for the procedures associated with a Level II analysis;
Ask the generator to provide a corrective action plan that describes the reason for the
discrepancy and actions to be taken to prevent re-occurrence;
Perform a WIP re-evaluation to determine if a new or revised WIP is necessary. This
could involve sending the WIP to the generator for re-evaluation and re-certification.
The new or revised WIP will be subjected to the Pre-Qualification process described in
Section 2.0 of this WAP; and
Maintain records of the above actions. Refer to Section 13.0 of this WAP for
recordkeeping.
8.0 Outbound Waste Screening Procedures
Containerized wastes that are compatible materials, supplemental fuels, used oil, or
wastewater may be consolidated into bulk transportation vehicles at the CMI facility (see
Section D of this permit}. Prior to transferring waste into a bulk transport vehicle, the CMI
Supervisor or Senior Waste Technician will review all applicable WIPs, test for
compatibility (see method CMI-12); for supplemental fuels, CMI will also test for PCBs.
Waste that is bulked on-site for outbound shipments will be tracked using the Bulk
Consolidation Tracking Sheet (see Appendix D of this section}. Upon completion, this
waste tracking form will be maintained with the facility copy of the outbound manifest as
part of the facility operating record.
Bulk transport vehicles may be kept on-site for a maximum of 72 hours from the time/date
when waste is first loaded onto the vehicle. All bulk transport vehicles will be located
within secondary containment throughout loading (and/or unloading] operations.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
9.0 Waste Sampling
Procedures for collecting representative samples are identified below. Collected samples
will either be returned to their original container or consolidated with compatible
materials prior to shipment off-site for proper disposal. Any "waste" material generated by
sampling activities is either returned to the original waste container or CMI will utilize a
new container.
9.1 Sampling Methods
The methods and equipment used for sampling waste vary with the form and consistency
of the waste to be sampled. CMI will select the most appropriate representative sampling
methods, techniques, devices, and containers from those included/described in either the
EPA document "Test Methods for Evaluating Solid Wastes" (SW-846) or the "American
Society for Testing and Materials" (ASTM] standards. A representative sample is defined as
a sample exhibiting average properties of the whole waste.
CMI standard operating procedures designed to protect worker health and ensure worker
safety while sampling the variety of waste types received by the CMI facility are included in
Appendix C of this section.
9.2 Sample Tracking Documentation
All sampling will be performed by CMI personnel.
Samples collected for on-site Level I analysis will be documented utilizing the Level I
QA/QC report (see Appendix F).
All Level II and III sampling will be documented utilizing the "Sample Record" log and the
"Level II/Level III QA/QC Checklist" included in Appendix G of this section. Chain-of-
custody forms (see Appendix E of this section] are used for tracking Level II and Level III
samples sent for off-site laboratory analyses and testing.
9.3 Sampling Personnel
Sampling is performed in the waste receiving area (Cell A-l) by the CMI Supervisor or
Senior Waste Technicians.
9.4 Sample Labels
Labels are affixed to each sample container prior to, or at the time of, sampling. At a
minimum, the labels include the following information, if applicable:
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Generator name
Common name of waste
Name of sample collector
Date of collection
Unique container number
WIP/waste stream number
A unique container number sticker, that matches the unique container number assigned to
the original waste container, is also affixed to sample containers used for Level II and III
analyses. Labels will be affixed after the sample has been removed and the container is
resealed such that the container top and/or bung cannot be opened without disfiguring the
label, thereby flagging those instances that other wastes may have been introduced.
10.0 Parameters and Rationale
The following table summarizes the analytical parameters and rationales used to
determine the general and specific characteristics of a waste stream. ASTM and SW-846 are
used as guidelines in developing the following analytical methods:
TABLE 3: Parameters and Rationale
Parameter Method Rationale for Selection
Physical Description
pH Screen
Water Reactivity
Reactive Sulfides Screen
(Spot Test)
Ignitability
Reactive Cyanides Screen
(Spot Test)
CMI-1
CMI-2
CMI-3
CMI-4
CMI-5
CMI-6
Used to determine the general characteristics of the waste stream.
This facilitates subjective comparison of the sample waste with prior
descriptions. CMI personnel check for color, general form, layering,
and consistency.
Required of all water-bearing liquid, solid, and semi-solid waste
streams to determine the corrosivity of the waste. The apparent pH
of non-aqueous wastes will also be performed. Tight tolerance limits
(e.g., +/- 2 pH unit change) will be established based on the storage
requirements at the facility and other relevant considerations.
Used to determine whether the waste has a potential to react with
water to generate heat, flammable gases, or other products. The test
does not apply to wastes already in contact with excess water.
Used to indicate whether the waste produces hydrogen sulfide upon
acidification below pH 2. It is not required if the pH of the waste is <6
or if the waste is not water-soluble.
Indicates the fire-producing potential of the waste and determines
whether the waste is RCRA-ignitable. This test will be applied to all
wastes liquids, solids, and sludges that are selected for analysis.
Indicates whether the waste produces hydrogen cyanide upon
acidification below a pH of 2. It is not required for wastes with pH <6
or if the waste is not water-soluble.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Parameter Method Rationale for Selection
Oxidizer Screen
Specific Gravity
Percent Suspended Solids
Chlorine (Spot Test)
Polychlorinated Biphenyls
Screen
Compatibility Testing
Total RCRA 8 Metals
Total RCRA characteristic
Volatile Organics
CMI-7
CMI-8
CMI-9
CMI-10
CMI-11
CMI-12
CMI-13
CMI-14
A general qualitative test used to determine if a waste is an oxidizer.
Oxidizers have the potential to react with a wide range of wastes and
therefore often need to be segregated.
Used in conjunction with other test data to determine probable
characteristics of materials and their conformance to the WIP.
Used in assessing the feasibility of wastewater treatment.
Indicates if the material is chlorinated. Information is used to check
conformance to the WIP, as well as disposal options.
Determines PCB content in order to verify WIP information and
assess applicability under TSCA.
Prior to a waste being commingled with other wastes, it is tested to
verify compatibility. Liquid or sludge wastes are combined to assess
their compatibility. Solid waste compatibility is determined based on
generator-provided information and records of bulk materials
previously received and/or currently stored.
Determines if the concentration of arsenic, barium, cadmium,
chromium, lead, mercury, silver and selenium exceeds the limits in 40
CFR 261.24.
Determines if the waste is potentially listed (e.g., contains a volatile
organic compound potentially used as a solvent) and if the
concentration of any volatile organic compound exceeds the limits in
40 CFR 261.24.
11.0 Test Methods
The test methods used to confirm that waste received by CMI conforms to the
corresponding WIP are described below.
CMI-1: Physical Description
The waste is sampled, visually inspected, and its physical appearance is recorded, the
description is to include:
color
physical state (% solid, % sludge, % liquid]
layers (single, bi-layered, multi-layered]
presence of freestanding liquid using SW846-9095 as a guideline (Paint Filter Liquids
Test]
If necessary, a Coliwasa tube or thief/tube is to be used to check for layering and to
determine the approximate percentage of each layer and approximate percentage of solid,
sludge, and liquid.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
CMI-2: pH Screen
The pH of a solid is measured by placing 20 grams of sample into a cup. 20 milliliters (ml]
of deionized water is added and the mixture is stirred for 30 seconds. The pH of the slurry
is then taken and recorded using SW846-9040 and SW846-9041 as guidelines. The pH of
liquids and sludges is taken using SW846-9040 and SW846-9041 as guidelines.
CMI-3: Water Reactivity
The water reactivity of a liquid or solid is determined by adding approximately 3 mL of
water to 0.1 ml of liquid or 0.1 gram of solid. The mixture is observed to detect heating
(more than 15° C temperature rise] or turbulent gas evolution (more than 10% of the
mixture volume}. If the mixture reacts as described above, the test is considered positive. If
the addition of water causes the material to be considered reactive under any definition of
40 CFR 261.23 or state regulations, the material is considered water-reactive.
CMI-4: Reactive Sulfides Screen (Spot Test)
2 to 4 drops of the material are placed on a spot plate. Then, a strip of lead-acetate paper
moistened with 1 drop of water is placed over the spot plate cavity containing the waste.
Next, 2 to 3 drops of 3M HC1 is added. Black PbS forms in the paper after 0.5 to 1 minute if
sulfide is present. The threshold limit of this method is around 4 PPM sulfide.
CMI-5: Ignitability
The ignitability screen is determined by placing the sample in a 125 to 250 mL cup. The cup
is covered and allowed to stand for at least five minutes. After five minutes the cover is
removed and a flame is placed near the opening of the cup. If a flash occurs, the ignitability
screen is considered positive. If no flash is observed, a small amount is placed on the end of
a spatula and heated over a flame. If the material ignites and sustains a flame for 10
seconds, the result is Negative B (per industry standard}. If the sample does not sustain a
flame for 10 seconds or ignite, the result is Negative C. A closed cup flash test will be used
to determine flash point of any Negative B material.
CMI-6: Reactive Cyanides Screen (Spot Test]
Cyanide is determined by placing 2 to 4 drops or a small spatula tip of the sample on a spot
plate. Two drops of water are then added to the waste. Next, one drop of chloramine-T
solution followed by one drop of pyridine-barbituric acid solution is added to the waste. If
the solution turns dark red or carmine after 10 to 30 seconds, this is a positive response.
The presence of cyanide can be detected above 60 ppb in aqueous samples (3 drop size}
and 10 ppm in solid samples (1 gram size}.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Reagents:
Chloramine-T solution: 1 gram of Chloramine-T is dissolved in 100 ml of distilled water.
Pyri dine-barbituric acid: 1.5 g of barbituric acid is mixed with 5 ml of water and 7.5 ml
of pyridine. The mixture is treated with 1.5 ml of concentrated HC1 and diluted to 25 ml.
CMI-7: Oxidizer Screen
The method used is a qualitative examination for the presence of oxidizing materials in
liquid, sludge, and solid samples.
Liquids and Sludges
^H
The procedure for liquid and sludge waste consists of wetting a strip of Kl-Starch paper
in HC1. The wetted strip is then dipped into the sample. The color change is then noted.
If the color turns light brown to dark purple or black, then the result is interpreted as
positive, and the waste is managed as an oxidizer. The color is indicative of the type of
oxidizer present.
Solids
The procedure requires that 2 mL of deionized water be added to 11 grams of sample.
The mixture is then stirred for 30 seconds. A strip of Kl-starch paper is wetted in HC1
and then dipped into the slurry. The color change of the KI paper is then noted. If the
color turns light brown to dark purple or black, then the result is interpreted as positive
and the waste is managed as an oxidizer. The light brown color is indicative of nitric
acid while the purple/black color results from the presence of peroxides.
CMI-8: Specific Gravity
The Specific Gravity of a liquid is determined by weighing 10 ml of the sample (at room
temperature] and dividing this value by 10. The alternate method of using a hydrometer
may be used if sufficient sample is present.
CMI-9: Percent Suspended Solids
Total suspended solids are determined by bringing the sample pH to approximately 3 using
10% sulfuric acid. A determination of the sample's pumpability is made without stirring.
The sample must not gel or turn to sludge. The sample is centrifuged for five minutes and
the percent solids are calculated.
CMI-10: Chlorine (Spot Test]
A small amount of the sample is placed in a test tube. Litmus paper is placed over the
sample as heat is applied. A red coloration of the paper indicates the presence of chlorine.
An additional test is done by placing a small amount of the material in a flame on a wire
loop. A green color indicates the presence of chlorine.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
CMI-11: Polychlorinated Biphenyls Screen
Method SW846-8082 is used to determine PCB content.
CMI-12: Compatibility Testing
Prior to a waste being commingled with other wastes, it is tested to verify compatibility. A
representative sample of the waste is mixed with a representative sample of the wastes to
be commingled. This is done under controlled conditions by personnel trained regarding
chemical reactions.
Representative portions of the wastes to be commingled are mixed together at the same
measured temperature to verify compatibility. For example, if a partially full container is to
be consolidated into another partially full container, a representative sample is drawn from
both containers, the samples are mixed. The mixture is then observed for the following:
Evolution of gas characterized by bubbling or foaming
Heat release evidenced by a temperature increase of more than 15 degrees over the
measured temperature
Polymerization of the mixture to an un-pumpable viscosity within 30 minutes
Miscibility or the formation of layers
m
Precipitate formation
Emulsification
If any of these conditions are observed, the wastes are considered incompatible.
CMI-13: RCRA 8 Metals (totals with digestion)
Liquids
Methods SW846-6010/7470
Solids
Methods SW846-6010/7471
CMI-14: Volatile Organic Compounds (totals]
Liquids
Volatile Organic Compounds - Method SW846-8260C
Solids
Volatile Organic Compounds (with extraction] - Methods SW846-5035/8260
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12.0 Quality Assurance and Quality Control
The following quality assurance/quality control (QA/QC or "quality"} information for this
facility is being provided as required by 40 CFR 270.30(e] and in accordance with the
following EPA guidance documents:
Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Third
Edition, Final Update I, U.S. EPA, Office of Solid Waste, Washington, DC, July 1992,
Chapter One, updated editions.
Handbook for analytical Quality Control in Water and Wastewater laboratories, EPA
600/4-79-019, March 1979, US Environmental Protection Agency (USEPA],
Environmental Monitoring and Support Laboratory (EMSL], Cincinnati, OH.
Quality protocols are applicable to both sampling and analytical techniques. This section
does not provide specific QA/QC performance standards for individual sampling and
analysis techniques. Such specifics are defined in specific operating procedures of the
laboratories performing the tests. Portions of these policies have been summarized in the
following sections.
^
12.1 Sampling Program
With some exceptions, all bulk and containerized waste shipments are sampled (see
Section 4.0 of this WAP}. Individual container samples that are related may be composited
prior to analysis. Sampling procedures are described in Section 9.0 of this WAP. The
selection of the sample collection device depends on the type of sample, the sample
container, the sampling location and the nature and distribution of the waste components.
In general, the methodologies used for specific materials correspond to those referenced in
40 CFR Part 261, Appendix I. The selection and use of the sampling device is supervised or
performed by a person thoroughly familiar with the sampling requirements.
Sampling equipment is typically constructed of non-reactive materials such as glass, PVC
plastic, aluminum, or stainless steel. Care is taken in the selection of the sampling device to
prevent contamination of the sample and to ensure compatibility of materials. For example,
glass bottles are not used to collect hydrofluoric acid wastes.
12.2 Analytical Program
CMI performs minor analyses on-site and subcontracts with independent, state certified or
NELAC laboratories for all pre-qualification and Level II and III analyses. CMI and these
laboratories have developed programs of analytical quality practices and procedures to
ensure that precision and accuracy are maintained. These programs - which include use of
control standards, duplicates, spikes, and blanks - are required. Non-company laboratories
employed by the company demonstrate quality control practices that are comparable to
CMI's practices.
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Good laboratory practices which encompass sampling, sample handling, housekeeping and
safety are required by specific CMI procedures.
12.3 Conclusion
The aforementioned sampling and analytical quality practices help ensure the data
obtained are precise and accurate for the waste stream being sampled. The analytical
results are used by facility management to decide whether or not to accept a particular
waste and, upon acceptance, to determine the appropriate method of treatment, storage,
and disposal. Results are also important to ensure that wastes are managed properly by the
facility and that incompatible wastes are not inadvertently combined. The quality of these
results are as important as the results themselves. Thus, the quality of the analytical data,
along with the thoroughness and care with which the sampling and analyses are performed
and reported, provides an important basis for day-to-day operational decisions.
13.0 Recordkeeping and Reporting
CMI will report manifest discrepancies to EPA as
specified at 40 CFR 264.72. In addition, CMI will
subcontract with independent, state certified or NELAC
laboratories to perform the Level II and III analyses,
will maintain analytical data on-site, and will supply
any analytical data to EPA when requested.
The following records will be maintained in the facility's operating record:
A record of Level I analyses as documented on the Level I QA/QC report (see
Appendix F).
A record and results of all Level II and Level III analysis will be maintained by CMI for
each waste sampled/analyzed:
A copy of the chain of custody document (see Appendix E of this WAP]
Copies of all applicable analytical and test results and lab reports including the
results of the Level I analysis
A copy of the original (incoming] manifest
A copy of the original WIP
Documentation of any discrepancies identified by the Level I, II or III analysis
If applicable, a copy of any written or correspondence with the generator related to
resolving a WIP discrepancy and documentation of relevant conversations with the
generator regarding same.
Issue to Consider
Note that some states have state-
specific requirements for reporting.
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If applicable, copies of any written correspondence with the generator and state
Waste Management Division related to resolving a manifest discrepancy and
documentation of relevant conversations with the generator or state Waste
Management Division regarding same.
If applicable, a copy of the revised WIP.
- The completed Level II/Level III QA/QC checklist (see Appendix G of this WAP]
Records of analyses, corrective action plans and other actions taken under the Rejection
Policy and Discrepancy Policy in this WAP.
In addition, CMI will produce bi-annual reports that summarize the frequency at which
incoming shipments do not conform to their waste profiles. The report must indicate the
steps taken by the facility to evaluate and resolve the discrepancies, including if new or
revised WPSs were produced.
14.0 Corrective Action
CMI will subcontract with independent, state certified or NELAC laboratories for pre-
qualification and Level II and III analyses. CMI and subcontracted laboratories have
processes in place to ensure quality assurance and quality control (see Section 12.0 of this
WAP}. In addition, CMI and subcontracted laboratories have methods for correcting
problems when they are identified. If problems/discrepancies are found, CMI may take a
range of corrective actions, such as performing an audit of the laboratory, reviewing and
revising applicable SOPs, and periodically evaluating subcontracted laboratories and
entering into new subcontracts if CMI has a concern about the quality of work.
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Appendices
The information in the appendices has been reduced to shorten the overall length of this
WAP. This was done solely for purposes of presentation in this guidance document. The
following appendices were removed:
Appendix A: Example Waste Information Profile (WIP] Form
Appendix B: Example Lab Pack Contents Form
Appendix E: Example Chain of Custody Form
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Appendix C: Standard Operating Procedures for Opening and Sampling Containers
Sampling of Containers
Coliwasas, tubes, drum thieves, and corers are examples of the devices used to sample
containers. Samples are taken from locations displaced both vertically and horizontally
throughout the waste. For liquids (or liquids with precipitated solids], the sample collector
uses a Coliwasa or equivalent. The sampling device is inserted into the container from the
top and is pushed down slowly until the bottom of the container is reached. The device is
sealed to retain the contents. The contents of the sampling device are then transferred to a
polyethylene or glass bottle that is labeled with waste identification information.
A corer or equivalent device is used to sample containers that are solid in nature. These
containers are generally filled with dirt and sludges. Several areas from the container are
sampled and composited into a jar in order to ensure a representative sample. The sample
collector removes a sample that uniformly represents the waste composition of the
container (i.e., all layers and phases are represented in the sample}.
Sampling of Bulk Material
Bulk solids are sampled using a simple random sampling strategy. The bulk solids
container, usually a roll-off box or a dump trailer, is divided into sections. A corer is used in
each section to draw a sample from as deep as possible. On occasion, a shovel is used to
access lower levels of a bulk container. The samples are composited together so that there
is one sample that represents that particular bulk solids shipment.
Bulk liquids are sampled using a Coliwasa or similar device that can sample vertical
anomalies. Each compartment of tanker truck is sampled. Compartment samples from the
same generator and waste stream will not be composited prior to analysis.
Tank trucks without manways are sampled through a valve. The valve is flushed prior to
the sample being drawn.
Debris
Debris is sampled as much as possible; however, not all wastes are amenable to sampling
(e.g., universal waste batteries, CRTs, lamps or ballasts, lab packs, etc.}. A container of
debris often contains a wide variety of materials. For example, it may contain spill
absorbent, Tyvek suits, rubber booties, gloves, and paper towels. It may be difficult to
obtain a representative sample.
In virtually all situations, debris has one thing in common: non-hazardous materials are
contaminated with very small to trace amounts of organic and inorganic hazardous
constituents.
Frozen Waste
CMI will not sample waste that is frozen. The container will remain in the receiving area
until the waste can be sampled and be stored on pallets.
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Appendix D: Bulk Consolidation Tracking Sheet
Outbound Facility: Date:
Type of Shipment: Initial:
Pump Start Time: Pump Stop Time:_
Container #
Location
Weight
Size
Waste codes
Notes
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Appendix F: Example Level I QA/QC Report
Date:_
Time: _
Initials:
Manifest Number:
Waste Information Profile (WIP) Number:
Number of Drums in Batch:
Profile Description of Waste:
Description of Waste (Observed):
Physical Characteristics/Screen Results:
% Liquids
% Solids
% Sludge
Color
Viscosity
PH
Flash Point
% Fuel*
Perform a visual inspection on each waste container, including covers and closure devices. Check for visible 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. Examine the physical and structural integrity of the container (e.g., is it bulging, etc.):
Acceptable D Unacceptable D
If "Unacceptable", explain corrective actions taken:
*Waste containing less than 1% fuel cannot be managed under the state's "fuel-to-fuel" exemption (i.e., the waste
does not contain a recoverable amount of fuel)
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Appendix G: Level ll/lll QA/QC Checklist
Sample Date:
Generator:
Waste Stream (WIP)#:
Drum #:
If not the 500th container, justification for bypassing:
Results of Level ll/lll Analysis:
Documents to be included in Level ll/lll WAP file:
Copy of Original Manifest _
Copy of Original WIP
Copy of Level I QA/QC Report
Original Chain of Custody
Analytical Results
Additional documentation to be included in Level ll/lll WAP file (if applicable):
Revised WIP
Manifest Discrepancy Letter
Correspondence with Generator/Customer
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APPENDICES
APPENDICES
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APPENDIX A:
Hazardous Waste Identification
EPA was granted the authority to develop criteria for the identification of hazardous
wastes under Section 3001 of RCRA. Under Section 1004 of RCRA, a hazardous waste is
defined as a solid waste, or a combination of solid wastes which, because of its quantity,
concentration, or physical, chemical, or infectious characteristics, may cause, or
significantly contribute to an increase in mortality or an increase in serious irreversible or
incapacitating reversible illness, or pose a substantial present or potential hazard to human
health or the environment when improperly treated, stored, transported, disposed, or
otherwise managed. The regulatory definition of a hazardous waste is found in 40 CFR
§261.3. Solid wastes are defined by regulation as hazardous wastes in two ways. First,
solid wastes are hazardous wastes if EPA lists them as hazardous wastes; the lists of
hazardous wastes are found in 40 CFR Part 261, Subpart D. EPA lists wastes based on
criteria in 40 CFR §261.11. Wastes listed by EPA as hazardous contain hazardous
constituents, are acutely hazardous, and/or exhibit the characteristics of ignitability,
corrosivity, reactivity, or toxicity. Second, EPA identifies the characteristics of a hazardous
waste based on criteria in 40 CFR §261.10. Accordingly, solid wastes are hazardous if they
exhibit any of the following four characteristics of a hazardous waste: ignitability,
corrosivity, reactivity, or toxicity (based on the results of the TCLP). Descriptions of these
hazardous waste characteristics are found in 40 CFR Part 261, Subpart C. Exclusions to the
regulatory definitions of solid waste and hazardous waste are found in 40 CFR §261.4.1
Generators must conduct a hazardous waste determination according to the hierarchy
specified in 40 CFR §262.11. Figure A-l can be used to assist in making this hazardous
waste determination, and can serve as a roadmap when reviewing the rest of Appendix A.
Persons who generate a solid waste first must determine if the solid waste is excluded from
the definition of hazardous waste under the provisions of 40 CFR §261.4. If the waste is not
excluded, the generator must determine if it is listed as a hazardous waste; if the waste is
not listed, or for the purposes of complying with the LDR requirements in 40 CFR Part 268,
the generator must determine if the waste exhibits a characteristic of a hazardous waste,
either by testing the waste or by utilizing knowledge about the process or materials used to
generate the waste.
Listing Determination
Once the generator determines that a solid waste is not excluded, then he/she must
determine if the waste meets one or more of the hazardous waste listing descriptions. The
hazardous waste lists include wastes from nonspecific sources (termed "F-listed wastes,"
after the F prefix in the hazardous waste codes}; these wastes include spent solvents,
1 Note: EPA is in the process of issuing new rules on the definition of solid waste.
APPENDIX A: Hazardous Waste Identification
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
electroplating wastes, and dioxin-bearing wastes. The hazardous waste listings also include
wastes from specific sources (i.e., K-listed wastes], including wastes from wood preserving
operations, organic and inorganic chemical production, pesticide formulation, explosives
manufacturing, petroleum refining, iron and steel production, pharmaceutical
manufacturing, and the lead, zinc, copper, and aluminum industries. The third group of
hazardous waste listings include discarded unused commercial chemical products, off-
specification products, and spill residues of such products (i.e., P- and U-listed wastes}.
The hazardous waste listings also apply to certain mixtures of solid wastes. Under the
"mixture rule" in 40 CFR §§261.3(a)(2)(iii) and (iv], mixtures of listed hazardous wastes
and solid nonhazardous wastes are defined as hazardous wastes and retain their listing
designations unless the hazardous waste in the mixture is listed solely based on a
particular characteristic (that is, ignitability [I], corrosivity [C], reactivity [R], toxicity [E]}
and the mixture no longer exhibits any of these hazardous waste characteristics. For
example, a mixture of a spent methylene chloride formulation (listed as F002 because of its
hazardous constituents] and used oil would be defined as a hazardous waste and be
designated as F002 whether or not the mixture exhibited a hazardous waste characteristic.
The mixture remains a hazardous waste unless the generator successfully petitions to
delist the waste according to procedures outlined in 40 CFR §260.22.
The hazardous waste listings also apply to solid wastes that are derived from the
treatment, storage, or disposal of a listed hazardous waste. The "derived-from rule" (40
CFR §261.3(c}(2}} defines residual solid wastes derived from the treatment, storage, or
disposal of a listed hazardous waste as a hazardous waste. Examples of wastes defined as
hazardous through the derived-from rule include ash resulting from the incineration of off-
specification toluene (U220], and leachate resulting from the disposal of API separator
sludge from the petroleum refining industry (K051] in a landfill. As with the mixture rule, a
generator may petition EPA to delist a waste that is derived from a listed waste.
EPA also regulates mixtures of hazardous wastes and other materials that are not solid
wastes. The "contained-policy" states that materials containing a listed hazardous waste
must be managed as hazardous wastes until the listed waste can be removed from the
mixture. This provision mainly applies to mixtures of listed hazardous wastes and
environmental media (e.g., contaminated ground water, contaminated soil] that cannot be
regulated by the mixture rule. An example of a waste regulated under the contained-in
policy is soil contaminated with cyanides that has been excavated from under a tank that
contains spent cyanide plating bath solutions from an electroplating operation (F007}; this
soil would be managed as F007.
APPENDIX A: Hazardous Waste Identification
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Figure A-1: Hazardous Waste Identification
Listed
Hazardous
Waste
No
Has the waste been delisted in accordance
with 40 CFR §§260.20 and 260.22? or
Does the mixture or derived-from residue
qualify for any of the exclusions from the
mixture and derived-from rules in 40 CFR
§261.3?
Not a Hazardous Waste
Not a Hazardous Waste
J
Does the waste meet any of the listing
descriptions in 40 CFR Part 261, Subpart D? or
Is the waste mixed with a listed hazardous
waste? or
Is the waste derived from the treatment,
storage, or disposal of a listed hazardous
waste?
Yes
Not a Listed
Hazardous Waste
For purposes of the Land Disposal
Restrictions program of 40 CFR
Part 268, does the listed waste
exhibit a characteristic of
hazardous waste in 40 CFR Part
261, Subpart C?
No
Does the waste exhibit a
characteristic of hazardous
waste in 40 CFR Part 261,
Subpart C?*
No
Not a
Hazardous
Waste
Listed and
Characteristic
Hazardous
Waste
No
Listed
Hazardous
Waste
Yes
Characteristic
Hazardous
Waste
' Note exception for mixtures of characteristic wastes and mining/mineral processing wastes in 40 CFR §261.3(a)(2)(1)
APPENDIX A: Hazardous Waste Identification
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Characteristics Determination
A solid waste that does not meet a listing for a hazardous waste must be evaluated by the
generator to determine if it exhibits a characteristic of a hazardous waste. A generator must
evaluate such wastes to determine if they exhibit any of the four characteristics of a
hazardous waste: ignitability, corrosivity, reactivity, and toxicity. This evaluation involves
testing the waste or using knowledge of the process or materials used to produce the waste.
A waste is defined as ignitable according to a definition in 40 CFR §261.21. A waste is
ignitable if it is a liquid and its flash point is less than 140° F (60° C). EPA Test Method 1010
(Pensky-Martens Closed Cup Method], EPA Test Method 1020 (Setaflash Closed Cup
Method], or equivalent methods may be used to test for ignitability. A waste may also be
defined as ignitable if it is an oxidizer or an ignitable compressed gas as defined in
Department of Transportation (DOT] regulations in 40 CFR Part 173, or if it has the
potential to ignite under standard temperature and pressure and burn persistently and
vigorously once ignited. Wastes that are ignitable are classified as EPA Hazardous Code
D001. Examples of ignitable wastes are certain spent solvents (e.g., mineral spirits] and off-
specification jet fuels.
The characteristic of corrosivity is described in 40 CFR §261.22. A waste is corrosive if it is
aqueous (defined as amenable to pH measurement] and its pH is less than or equal to 2 or
greater than or equal to 12.5. The tests used for this pH determination are EPA Test
Method 9040 (pH Electrometric Measurement], EPA Test Method 9041 (pH Paper Method],
or an equivalent method. A waste is also corrosive if it is a liquid and it corrodes steel at a
rate of more than 0.25 inches per year under conditions specified in EPA Test Method
1110. Corrosive wastes are designated as EPA Hazardous Waste Code D002. Corrosive
wastes include spent sulfuric acid and concentrated waste sodium hydroxide solutions that
have not been neutralized.
A waste exhibits the characteristic of reactivity if it meets any of the criteria in 40 CFR
§261.23. Wastes that exhibit the characteristic of reactivity are classified as EPA Hazardous
Wastes Code D003.
The final characteristic of a hazardous waste is the toxicity characteristic (TC).
Generators who opt to test their waste for this characteristic must develop an extract of the
waste according to the Toxicity Characteristic Leaching Procedure (TCLP - EPA Test
Method 1311] found in Appendix II to 40 CFR Part 261. The extract is then subsequently
analyzed using one or more of several methods listed below. The results of the analysis are
compared to regulatory thresholds for 40 constituents in 40 CFR §261.24. Test methods in
this step may include the following:
EPA Test Methods 3010 and 6010 - for arsenic, barium, cadmium, chromium, lead,
silver, and selenium
EPA Test Method 7470 - mercury
EPA Test Methods 3510 and 8080 - pesticides
APPENDIX A: Hazardous Waste Identification
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
EPA Test Method 8260 - for volatile organics
EPA Methods 3510 and 8270 - semivolatile organics
EPA Test Method 8151 - herbicides.
If the extract from the TCLP procedure contains levels of any of the 40 constituents at or
above regulatory thresholds, the waste is considered a hazardous waste. Wastes that
exhibit the toxicity characteristic are classified as EPA Hazardous Waste Codes D004
through D043. Examples of wastes that may exhibit the characteristic of toxicity include
petroleum wastes, wastes from organic chemical manufacturing, and pesticide and
herbicide wastes.
Certain states may also have requirements for identifying hazardous wastes in addition to
those described above. States authorized to implement the RCRA or HSWA programs under
Section 3006 of RCRA may promulgate regulations that are more stringent or broader in
scope than federal regulations. For example, certain states have broadened the scope of the
hazardous waste listings by specifically listing used oil as a hazardous waste. Some states
also regulate hazardous wastes based on total (versus extract] waste analysis of individual
hazardous constituents.
APPENDIX A: Hazardous Waste Identification
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX B:
Regulatory Summary
This appendix presents a brief summary of some changes to the RCRA hazardous waste
program that have occurred since the 1994 edition of this manual was issued. For more
information concerning specific requirements, consult the Federal Registers cited herein
and the Code of Federal Regulations. These changes include:
Definition of solid waste final rule.
Alternative requirements for laboratories owned by eligible academic entities.
Conditional exemptions for military munitions.
Conditional exemptions for low-level mixed waste storage, treatment, transportation,
and disposal.
Organic air emission standards for tanks, containers and surface impoundments (40
CFR Part 264 and 265, Subpart CC}
Amendments to the Land Disposal Restrictions (LDR} regulations, including the Phase II
- IV rules.
Revisions and updates to the "Test Methods for Evaluating Solid Waste, Physical/
Chemical Methods" (SW-846) and issuance of the Methods Innovation Rule (MIR}.
Definition of Solid Waste Final Rule and Re-proposal in 2011
In October 2003, EPA proposed a regulatory exclusion from the definition of solid waste
which would streamline requirements for the recycling of hazardous secondary materials.
After evaluating public comments and conducting independent analyses, the Agency
published a supplemental proposal in March 2007.
On October 30, 2008, EPA published a final rule (73 FR 64668} establishing conditional
exclusions for the following:
Materials that are generated and legitimately reclaimed under the control of the
generator (i.e., generated and reclaimed on-site, by the same company, or under
"tolling" agreements};
Materials that are generated and transferred to another company for legitimate
reclamation under specific conditions; and
Materials that EPA or an authorized state determines to be non-wastes through a case-
by-case petition process.
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
The rule also contains a provision to determine which recycling activities are legitimate
under the new exclusions and non-waste determinations. This provision ensures that
only authentic recycling, and not treatment or disposal under the guise of recycling,
receives the benefits of these streamlined regulations. In order to be legitimately recycled
under these exclusions, the hazardous secondary material (1} must provide a useful
contribution to the recycling process; and (2} the recycling must make a valuable new
intermediate or final product. Two additional factors must also be taken into account: (1}
whether the recycled material is managed as a valuable product; and (2} whether the
recycled product contains toxic constituents at significantly greater levels than a non-
recycled product made from virgin materials. These exclusions are not available for
materials that are: (1} considered inherently waste-like; (2} used in a manner
constituting disposal; or (3} burned for energy recovery.
On July 22, 2011, EPA issued a proposed rule (76 FR 44094} to modify certain aspects of
the 2008 final rule. The 2011 proposal seeks to ensure that the recycling regulations, as
implemented, encourage reclamation in a way that does not result in increased risk to
human health and the environment from discarded hazardous secondary material. EPA
requested comment on potential revisions to address concerns raised by the Sierra Club, as
well as other environmental organizations.
Alternative Requirements for Laboratories Owned by Eligible
Academic Entities
On December 1, 2008, EPA added Subpart K to the generator standards at 40 CFR Part
262 (73 FR 72912}. The new subpart applies to eligible academic entities, which are
colleges and universities, and teaching hospitals and nonprofit research institutes that
are either owned by or formally affiliated with a college or university. Subpart K is an
alternative set of regulations that allow eligible academic entities the flexibility to make
hazardous waste determinations in the laboratory; at an on-site central accumulation
area; or at an on-site TSDF. The rule also provides incentives for eligible academic
entities to clean-out old and expired chemicals that may pose unnecessary risk. Further,
the rule requires eligible academic entities that opt into the rule to develop a Laboratory
Management Plan (IMP}, which is expected to result in safer laboratory practices and
increased awareness of hazardous waste management. Eligible academic entities may
also choose not to opt into the new rule and remain subject to the pre-existing hazardous
waste generator requirements.
Conditional Exemptions for Military Munitions
On February 2,1997, EPA finalized regulations that clarify when conventional and chemical
military munitions become a hazardous waste under RCRA (62 FR 6621}. The rule
establishes the regulatory definition of solid waste as it applies to three specific categories
of military munitions: (1} unused munitions; (2} munitions being used for their intended
purpose; and (3} used or fired munitions.
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
The rule conditionally exempts (1} from RCRA manifest requirements and container
marking requirements, waste non-chemical military munitions that are shipped from one
military-owned or -operated TSDF to another in accordance with Department of Defense
(DOD) military munitions shipping controls; (2} from RCRA Subtitle C storage regulations,
waste non-chemical military munitions subject to the jurisdiction of the DOD Explosives
Safety Board storage standards.
In addition, the rule identifies four specific circumstances under which an unused munition
is considered to be a solid waste for regulatory purposes: (1} the unused munition is
"abandoned by being disposed of, burned, or incinerated, or treated prior to disposal;" (2}
the unused munition is removed from storage for purposes of disposal or treatment prior
to disposal; (3} the unused munition is deteriorated, leaking, or damaged to the point that
it can no longer be put back into serviceable condition, and cannot be reasonably recycled
or used for other purposes; or (4} the munition has been determined by an authorized
military official to be a solid waste.
Military munitions are not a solid waste for regulatory purposes (1} when a munition is
being used for its intended purpose, which includes when a munition is being used for the
training of military personnel; when a munition is being used for research, development,
testing, and evaluation; and when a munition is destroyed during range clearance
operations at active and inactive ranges; and (2} when a munition that has not been used or
discharged, including components thereof, is repaired, reused, recycled, reclaimed,
disassembled, reconfigured, or otherwise subjected to materials recovery activities.
This rule also specifies that used or fired munitions are solid waste when they are removed
from their landing spot and then either (1} managed off-range (i.e., when transported off-
range and stored, reclaimed, treated, or disposed of or (2} disposed of (i.e., buried or
landfilled] on-range. In both cases, when the used or fired munition is a solid waste, it is
potentially subject to regulation as a hazardous waste. Also, munitions that land off-range,
and that are not promptly retrieved, are statutory solid waste.
Conditional Exemptions for Low-level Mixed Waste Storage,
Treatment, Transportation, and Disposal
A "mixed waste" contains both radioactive and hazardous waste components. Mixed
wastes are regulated by RCRA for the hazardous waste component and the Atomic Energy
Act (AEA} for the radioactive component. In general, the requirements of RCRA and AEA
are consistent and compatible. The U.S. Nuclear Regulatory Commission (NRC) and the
U.S. Department of Energy (DOE] regulate the radioactive portion of mixed waste under
AEA authority, while EPA regulates the hazardous waste portion of mixed waste under
RCRA authority.
Low-level mixed waste (LLMW} is waste that contains low-level radioactive waste (LLRW}
and hazardous waste. LLRW is defined as any radioactive waste that is not high-level
radioactive waste, spent nuclear fuel, or byproduct material. LLMW is generated at
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
industrial and hospital facilities and nuclear power plant facilities in a number of processes
such as medical diagnostic testing and research, pharmaceutical and biotechnology
development, pesticide research, and nuclear power plant operations.
On May 16, 2001, EPA finalized a rule (66 FR 27217} that provides increased flexibility to
facilities for managing LLMW and naturally occurring and/or accelerator-produced
radioactive material (NARM} containing hazardous waste. The rule exempts LLMW from
RCRA storage and treatment requirements as long as the waste is generated under a single
NRC license, meets the conditions specified, and is stored and treated in a tank or
container. In addition, LLMW and NARM, which meet applicable treatment standards, may
be conditionally exempt from RCRA transportation and disposal requirements. This waste
may be disposed of at LLRW disposal facilities which are licensed by NRC. The rule also
provides additional flexibility for manifesting these wastes when they are destined for
disposal at such facilities. Although mixed waste meeting the applicable conditions is
exempt from certain RCRA requirements, it must still be managed as radioactive waste
according to NRC regulations. Note that DOE disposal facilities are not eligible to accept the
exempt waste since they are not subject to NRC regulation.
Organic Air Emission Standards for Tanks, Containers and Surface
Impoundments (Subpart CC)
Section 3004(n} of RCRA requires the development of standards to control air emissions
from TSDFs as necessary to protect human health and the environment. EPA has
promulgated a series of regulations to implement this requirement. These regulations
control air emissions from certain process vents and equipment leaks (Parts 264 and 265,
Subparts AA and BB}, as well as air emissions from certain tanks, containers, and surface
impoundments (Subpart CC}. The Subpart AA and BB standards became effective on
December 21, 1990. The Subpart CC organic emission control standards became effective
on December 6,1996 (59 FR 62896}.
Under Subpart CC, if a hazardous waste has an average volatile organic (VO} concentration
less than 500 parts per million by weight (ppmw} at the point of waste origination or if the
hazardous waste organic content has been reduced by a treatment process to the extent
described in 40 CFR §§264.1082 or 265.1083 prior to placement in the waste management
unit, the unit is exempt from the air emission controls required under the standards.
Subpart CC applies to the containers and tanks of TSDFs and LQGs, as well as to TSDF
surface impoundments:
Containers. Subpart CC standards applicable to containers of hazardous wastes are
specified in 40 CFR §§264.1086 and 265.1087.There are three levels of air emission
controls for containers based on container size, organic contents, and whether the
container is used in a waste stabilization process. Container Level 1 controls require
that the hazardous waste be stored in an approved Department of Transportation
(DOT} container, a container equipped with a cover and closure devices for each
opening, or an open-top container with an organic vapor-suppressing barrier.
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Container Level 2 controls require that the hazardous waste be stored in an approved
DOT container, a container that operates with no detectable organic emissions, or a
demonstrated vapor-tight container. Container Level 3 controls require that the
hazardous waste be stored in a container that is either vented directly to a control
device or is located inside an enclosure that is vented through a closed-vent system to a
control device. Design and operating criteria are specified in the rule for the enclosure,
closed-vent system, and control device.
Tanks. Subpart CC standards applicable to tanks containing hazardous wastes are
specified in 40 CFR §§264.1084 and 265.1085. There are two levels of air emission
controls for tanks based on the size of the tank, maximum organic vapor pressure of the
waste, and whether the tank is used in a waste stabilization process. The owner or
operator is responsible for determining whether Tank Level 1 or Tank Level 2 controls
are applicable.
Surface impoundments. Subpart CC standards applicable to surface impoundments
containing hazardous wastes are found in 40 CFR §§264.1085 and 265.1086.To control
air emissions from a surface impoundment managing a hazardous waste with a VO
concentration >500 ppmw, an owner or operator must install and operate either a
floating membrane cover or a cover that is vented through a closed-vent system to a
control device.
Land Disposal Restrictions (LDR) Regulations (Part 268)
The 1984 Hazardous and Solid Waste Amendments (HSWA] to RCRA prohibit the land
disposal of specific groups of hazardous waste, unless it has been determined that there
will be no migration of the hazardous constituents. The amendments also required EPA to
establish treatment standards for all listed and characteristic wastes, expressed as
concentration levels or methods of treatment that will reduce their toxicity and make them
safe for land disposal. These treatment standards are found in Part 268, Subpart D. LDRs
apply to all generators (except conditionally exempt small quantity generators] and
transporters of hazardous waste as well as to owners and operators of treatment, storage,
and disposal facilities (TSDFs].
Generators must determine whether their waste is subject to LDRs for each hazardous
waste at the point of generation, or alternatively, ask the treatment facility to do so. HSWA
requires that both listed and characteristic determinations be made for each waste as
specified. The generator can make this determination based on knowledge of the waste, by
conducting a total waste analysis, or by testing the waste extract. If a generator determines
the waste is prohibited from land disposal and elects to treat the waste on site (in
accumulation tanks, containers, or containment buildings regulated under 40 CFR §262.34],
a written waste analysis plan (WAP] must be developed to describe the procedures the
generator will carry out to comply with the treatment standards and the plan must be kept
on site in the generator's records. Although no specific criteria are established for
generators developing a WAP in accordance with 40 CFR §268.7(a](5], the plan should be
written in accordance with the procedures prescribed in this manual (i.e., describe the
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
physical and chemical analysis that will be conducted on a representative sample of the
waste(s} being treated, and specifically describe the frequency of testing}. WAPs are not
required from generators who are treating for purposes other than meeting LDR treatment
standards.
Treatment/storage facilities are responsible for including in their WAP (40 CFR
§§264.13/265.13} procedures used to corroborate that correct treatment standards have
been selected for incoming wastes and provisions for testing the waste to verify that it
meets the LDR treatment standardfs}. These facilities will receive the generators'
certification and any available waste analysis data provided by the generator (40 CFR
§§264.73, 265.73}. However, upon subsequent management of the waste, the
treatment/storage facility, like the generator who ships directly to a disposal facility, must
certify to the disposal facility that the waste meets the applicable treatment standards.
The disposal facility receives certifications that the waste meets LDR treatment standards
from generators and treatment/storage facilities. The results of waste analysis or other
information on the waste's properties should also be provided by generators or treaters of
the waste. The disposal facility must conduct sampling and analysis of incoming wastes to
verify that wastes meet the relevant treatment standards for the specific waste. The
procedures for waste sampling and analysis, including the frequency of testing, must be
documented in the facility's WAP.
Since the 1994 edition of this manual was issued, there have been many amendments to
the LDR program. Some key amendments include the following:
EPA finalized the Phase II Rule on September 19, 1994 (59 FR 47982}. This final rule
consolidated the existing treatment standards into 40 CFR §268.40, created the
Universal Treatment Standards (UTS}, and promulgated treatment standards for
toxicity characteristic organic wastes, coke by-products, and chlorotoluenes.
EPA finalized the Phase III Rule and subsequent partial rescission on April 8, 1996 (61
FR 15566 and 15660}. These final rules modified treatment standards for reactive
wastes and decharacterized wastewaters, and promulgated new treatment standards
for carbamate wastes and spent aluminum potliners. Even though Phase III
promulgated treatment standards for these newly identified carbamate wastes, in the
case, Dithiocarmbamate Task Force v. EPA, the D.C. Circuit Court of Appeals vacated
several carbamate hazardous waste listings, thus nullifying their corresponding LDR
treatment standards (62 FR 32974; June 17,1997}.
EPA finalized the first half of the Phase IV Rule on May 12,1997 (62 FR 25998}. This final
rule promulgated treatment standards for the wood preserving wastes and streamlined
the LDR notification requirements. EPA promulgated part two of the Phase IV Rule on
May 26, 1998 (63 FR 28556}. This rule finalized treatment standards for several metal
wastes and certain newly identified mineral processing wastes, and revised the universal
treatment standards for twelve metal constituents. The rule also created a new
treatability group, soil, and established soil specific alternative treatment standards.
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Further discussion of LDRs is available in:
US EPA, Land Disposal Restrictions: Summary of Requirements, EPA530-R-01-007,
Revised 2001. http://www.epa.gov/epawaste/hazard/tsd/ldr/ldr-sum.pdf
US EPA, Introduction to Land Disposal Restrictions (40 CFR Part 268], EPA530-K-05-
013, September 2005.
http://www.epa.gov/epawaste/inforesources/pubs/training/ldr05.pdf
Test Methods for Evaluating Solid Waste (SW-846) and The Methods
Innovation Rule (MIR)
The EPA publication SW-846, entitled Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, is the official compendium of analytical and sampling methods
that have been evaluated and approved for use in complying with the RCRA regulations.
SW-846 functions primarily as a guidance document setting forth acceptable, although not
required, methods for the regulated and regulatory communities to use in responding to
RCRA-related sampling and analysis requirements.
SW-846 was first issued by EPA in 1980 and was originally intended to serve as a guidance
manual of generally appropriate and reliable analytical methods for testing and monitoring
waste. Some of the regulations required the use of SW-846 methods in general, and
therefore all of the publication had to be incorporated by reference at 40 CFR §260.11(a].
In the late 1990s, EPA determined that some of the required uses of SW-846 are not
necessary and that members of the regulated community may use other reliable methods
to comply with hazardous waste regulations.
In 1998, EPA proposed to remove certain required uses of SW-846 methods, and to allow
more flexibility in test method selection and EPA proposed to amend the hazardous and
nonhazardous solid waste regulations for testing and monitoring activities from the RCRA
regulations. This amendment has come to be known as, "The Methods Innovation Rule"
(MIR], which includes the following revisions (see 70 FR 34537, June 14, 2005}:
Certain SW-846 testing regulations will allow the use of other practical test methods, so
long as they fall within EPA's parameter to protect human health and the environment.
Some required uses of SW-846 methods remain in the regulations because they involve
determination of method-defined regulatory parameters (e.g., TCLP], which can only be
the method specified.
Finalizes proposed revisions to Update IIIB to the Third Edition of SW-846;
Removes requirements to use Chapter Nine, "Sampling Plan" in certain circumstances;
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Amends Sections 7.3.3 and 7.3.4 of SW-846 Chapter Seven to withdraw the:
- Cyanide and sulfide reactivity guidance;
- Required uses of reactive cyanide and sulfide methods; and
- Threshold levels from conditional delistings.
Advances in analytical instrumentation and techniques are continually reviewed by EPA
and incorporated into periodic updates to SW-846 to support changes in the regulatory
program and to improve method performance and cost effectiveness. To date, EPA has
finalized Updates I, II, IIA, IIB, III, IIIA, IIIB, IVA and IVB to the SW-846 manual. Today, the
updated and fully integrated manual contains multiple volumes and contains
approximately 3500 pages.
APPENDIX B: Regulatory Summary
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX C:
Regulatory Citations for Conducting Waste
Analysis
Regulatory Citations Specific to Waste Analysis Plans, Waste Analysis,
and Waste Determination
This appendix presents a table identifying many, but not necessarily all, of the federal
hazardous waste analysis requirements found in 40 CFR Parts 262 through 266, 268 and
270. The table indicates if the requirements apply to generators, permitted TSDFs, and/or
interim-status TSDFs. The table includes links to these requirements on the web (CTRL +
Click to follow link}. Go to www.gpo.gov/fdsys for the full regulatory text. Following the
table is a brief regulatory discussion of remediation waste and wastewaters.
The information in this appendix is provided solely as guidance for permit applicants,
permit writers, and others. It is not intended for compliance or enforcement purposes.
It is current as of 2012. Refer to your state's regulations to learn the up-to-date
requirements that apply to you, as they may be more stringent and/or broader in
scope than the federal program.
Table of Waste Analysis and WAP Requirements
Generators (Part 262)
Generator hazardous waste determinations
University Laboratories XL Project
Subpart K alternative requirements for hazardous
waste determination and accumulation
of unwanted material for laboratories owned by
eligible academic entities
r Permitted Interim-Status
Generator TSDFa TSDFa
262.11
Subpart J of Part
262
Subpart Kof
Part 262
TSDFs (Parts 264 and 265)
Hazardous waste analyses and waste analysis plans
Manifest system and operating record requirements
Closure of hazardous waste management unit or
facility
Containers: special requirements for incompatible
wastes
Tanks: waste analysis and trial tests
Surface impoundments: waste analysis and trial tests
Waste piles: waste analysis
Land treatment: waste analysis
264.13
Subpart E of
Part 264
264.113
264.177
265.13
Subpart E of Part 265
265.113
265.200
265.225
265.252
265.273
APPENDIX C: Regulatory Citations for Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Regulation
Landfills: design and operation
Incinerators: waste analysis
Thermal treatment: waste analysis and trial tests
Chemical, physical and biological treatment: waste
analysis and trial tests
Test methods and procedures for organic air
emissions for process vents under Subpart AA
Test methods and procedures for organic air
emissions for equipment leaks under Subpart BB
Waste determination procedures for organic air
emissions from containers, tanks and surface
impoundments under Subpart CC
Generator
265.1034b
265.1063b
265.1084b
Permitted
TSDFa
264.341
264.1034
264.1063
264.1083
Interim-Status
TSDFa
265.301
265.341
265.375
265.402
265.1034
265.1063
265.1084
Boilers and Industrial Furnaces (Part 266)
Boilers and industrial furnaces (BIFs): analysis of Part
261 Appendix VIM constituents for trial burn, etc.
Boilers and industrial furnaces (BIFs): stack emissions
testing
Methods manual for compliance with the BIF
regulations
266.102(b)
266.103(c)(3)(ii)(B)
Appendix IX to Part 266
Land Disposal Restrictions (Part 268)
Analysis of wastes treated in surface impoundments
Analysis of wastes to be placed in landfills under Land
Disposal Restrictions (LDR) petition
LDR requirements for generators, treaters and
disposers to determine if their waste meets LDR
treatment standards and to comply with related
requirements
LDR requirement for generators and TSDFs to test
their wastes that are subject to a variance from a
treatment standard
268.4
268.6
268.7(a), (b), and (c)
268.44
Permitting Requirements (Part 270)
Requirements to include waste analysis data and
WAP in Part B permit application
Incinerators: submittal of waste analysis data in Part
B permit application
Land treatment facilities: submittal of waste data in
Part B permit application
Incinerators: submittal of waste analysis data for trial
burn
Boilers and industrial furnaces: submittal of waste
analysis data for trial burn
Requirement for submittal of WAP by applicant of
standardized permit for tanks and containers
270.14
270.19
270.20
270.62
270.66
270.275
a TSDFs that generate hazardous waste are subject to the Part 262 generator standards (i.e.,
applicable.
Large quantity generators are subject to the organic air emission standards at Subparts AA,
are not subject.
the "Generator" column in this table), as
BB, and CC of Part 265. Small quantity generators
APPENDIX C: Regulatory Citations for Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Other Regulatory Resources
Remediation Waste Identification
Most facilities will generate some type of remediation waste whether it is from
incidental spills or from historical contamination. These wastes also need to be
properly identified. Note that not all remediation wastes are subject to RCRA Subtitle C
hazardous waste requirements. As with any other solid waste, remediation wastes are
subject to RCRA Subtitle C only if they are listed or identified hazardous waste.
Environmental media are subject to RCRA Subtitle C only if they contain listed
hazardous waste, or exhibit a characteristic of hazardous waste. These distinctions are
discussed more completely in the guidance document Management of Remediation
Waste Under RCRA (EPA530-F-98-026).
Wastewater Treatment Sludge Disposal
Almost every business or industry generates wastewater. If you generate an industrial
wastewater, you may have to treat it before you can sewer it, discharge it into a stream or
lake, or do something else with it. If you treat your wastewater, you may generate
industrial wastewater treatment sludge. Wastewater treatment sludge is a solid waste and
may also be a hazardous waste. Both require special management.
What is Wastewater Treatment Sludge?
The treatment of wastewaters frequently produces sludge. 40 CFR §260.10 defines
wastewater treatment sludge as "any solid, semi-solid or liquid waste generated from a
municipal, commercial, or industrial waste water treatment plant, water supply treatment
plant, or air pollution control facility exclusive of the treated effluent from a wastewater
treatment plant."
Any sludge that is not domestic wastewater sludge is industrial sludge. This includes
wastewater sludge from manufacturing or processing of raw materials, intermediate
products, final products or other activities that include pollutants from non-domestic
wastewater sources.
When Is Wastewater Treatment Sludge NOT a Hazardous Waste?
The treatment of wastewaters is generally considered exempt from hazardous waste
regulation if done in a "Waste Water Treatment Unit" (WWTU} that meets the definition
noted below.
Sludges, while they remain in an active WWTU, are not normally regulated as hazardous
wastes. If the sludges in the WWTU go directly from that unit into a municipal sewer, and
travel through that sewer to a "Publicly Owned Treatment Works" (POTW] after mixing
with sanitary wastes as outlined below, the sludges are not subject to a hazardous waste
APPENDIX C: Regulatory Citations for Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
determination or otherwise regulated as hazardous waste unless they leak from the sewer
prior to reaching the POTW.
Prior to entering the sewer system and meeting the criteria outlined below, the waste may
be a solid and a hazardous waste subject to hazardous waste regulation during generation,
storage, and treatment.
Once the waste has been discharged to the POTW, it is subject to Clean Water Act (CWA]
and local restrictions. Note that the CWA may prohibit discharges of certain chemicals and
wastes into a sewer system.
Mixtures of sanitary wastes and other wastes (including hazardous industrial wastes] that
pass through a sewer system to a POTW are excluded from hazardous waste regulation.
Wastes meeting these criteria are not considered solid wastes and the POTW would not be
deemed to be receiving or treating hazardous wastes. However, sludge generated at the
POTW from the treatment of the waste would be a new waste, and must be analyzed to
determine if it is hazardous so that it may be managed legally. If the newly-generated waste
exhibits a characteristic of hazardous waste (i.e., ignitability, corrosivity, reactivity, or
toxicity], it would need to be regulated as hazardous waste.
Sanitary wastes that pass through a publicly or privately owned sewer system are
considered domestic sewage and are excluded from regulation as hazardous waste. Though
these wastes may be excluded from the hazardous waste regulations, water regulations
may apply.
In summary, mixtures of sanitary wastes and other wastes (including hazardous industrial
wastes] that pass through a municipal sewer system to a POTW may be excluded from
hazardous waste regulations. The exclusion applies to a waste at the point where it first
mixes with sanitary wastes in the municipal sewer system if this mixing occurs prior to
reaching the POTW property boundary. This exclusion does not apply to any waste directly
transported to the POTW by truck or rail shipments. This exclusion presumes that the
mixture actually makes it to the POTW. The exemption is lost for any mixture in the
municipal sewer system that leaks from the system prior to arrival at the POTW.
When is Wastewater Treatment Sludge a Hazardous Waste?
If industrial or processing wastes are removed from the wastewater treatment unit prior to
being discharged into the sewer or do not pass through a municipal sewer to a POTW, they
are subject to a hazardous waste determination. Unless they have mixed with sanitary
wastes in a municipal sewer, these sludges may be listed or characteristic hazardous
wastes. If the wastewaters going into the WWTU are listed hazardous waste, the sludges
from the WWTU will also be listed hazardous waste.
How Do You Manage a Hazardous Waste Sludge?
Several hazardous waste codes may apply to your sludge depending on your industrial
processes. Depending on what hazardous waste codes would apply to your sludge, and its
APPENDIX C: Regulatory Citations for Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
physical and chemical nature, you might have a number of management options. You
might have to dispose it as hazardous waste at a permitted hazardous waste landfill or
incinerator. You might be able to manage it under lesser requirements through some form
of reclamation or recycling. You may be able to reuse the material if the use is legitimate
according to U.S. Environmental Protection Agency or authorized State regulatory
authority (i.e., the proposed use is not a subterfuge to avoid regulation of the material as
hazardous waste}.
Definitions
Publicly Owned Treatment Works (POTW) means a treatment works, as defined by
Section 212 of the Clean Water Act (CWA) that is owned by the state or municipality. This
definition includes any devices and systems used in the storage, treatment, recycling, and
reclamation of municipal sewage or industrial wastes of a liquid nature. It also includes
sewers, pipes, and other conveyances only if they convey wastewater to a POTW treatment
plant [40 CFR §403.3]. Privately-owned treatment works, Federally-owned treatment
works, and other treatment plants not owned by municipalities are not considered POTWs.
Tank means a stationary device, designed to contain an accumulation of hazardous waste,
which is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic]
which provide structural support. (From 40 CFR §260.10}.
Tank system means a hazardous waste storage or treatment tank and its associated
ancillary equipment and containment system. (From 40 CFR §260.10}.
Wastewater treatment unit means a device which:
(1} Is part of a wastewater treatment facility that is subject to regulation under either
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 §261.3 of this chapter, or that generates and accumulates a wastewater
treatment sludge that is a hazardous waste as defined in Sec. 261.3 of this chapter, or
treats or stores a wastewater treatment sludge which is a hazardous waste as defined in
Sec. 261.3 of this Chapter; and
(3} Meets the definition of tank or tank system §260.10 of this chapter. (From 40 CFR
§260.10}
Wastewater is not defined under the federal and state hazardous waste regulations, but
EPA assumes that wastewaters "are substantially water with contaminants amounting to a
few percent at most." (See RCRA Online #11020 and #14472}.
APPENDIX C: Regulatory Citations for Conducting Waste Analysis
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX D:
Overview of Major Hazardous Waste
Management Units
Containers
Containers are portable devices used to treat, store, transport, dispose, and handle waste
materials. They include metal drums and pails, polyfiber bags, plastic drums and carboys,
or durable fiberboard paper drums or pails. They do not include tanks, which are regulated
separately, as discussed below. Metal and plastic drums and pails are the most commonly
used containers; however, durable fiber drums (used most often to store and transport
solids designated for incineration] and drums constructed of other materials are also
widely used. Before selecting a container for storage or treatment of the waste, you should
identify its physical and chemical characteristics. The selection of waste analysis
parameters will be dependent upon the specific characteristics of the wastes you manage
and the construction materials of the container used at your facility. You should consider
performing laboratory analysis on a sample of your wastes for parameters such as flash
point, pH, reactivity, and moisture content.
%
Tanks
Tanks are stationary devices constructed primarily of non-earthen materials designed to
contain an accumulation of hazardous waste(s}. They do not have to be totally enclosed and
they are generally distinguished from surface impoundments because they are self-
supporting (i.e., they do not need external support materials, such as earth}. They are
generally constructed of metal, fiberglass, or rugged plastics.
Surface Impoundments
Surface impoundments are natural depressions, man-made excavations, or diked areas,
formed primarily of earthen materials, used to contain an accumulation of liquids or wastes
containing free liquids. Examples of surface impoundments are ponds, lagoons, and
holding, storage, settling and aeration pits. Surface impoundments can be used as
treatment, storage, or disposal units.
Although surface impoundments are constructed primarily of earthen materials, they often
can have components made of synthetic materials, such as liners and leak detection
systems. Synthetic materials that are most often used in the construction of liners include
high-density polyethylene, chlorinated polyethylene, and polyvinyl chloride. Leak detection
and leachate collection systems can be constructed from a number of geosynthetic textile
materials, including polyethylene, polypropylene, and polyester. Surface impoundments
APPENDIX D: Overview of Major Hazardous Waste Management Units
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
may be equipped with a variety of high-strength polymer plastic piping (e.g., polyvinyl
chloride] to aid in the removal of liquids that have accumulated in leachate collection
systems, a component of the leak detection system.
Landfills
Landfills are disposal units where hazardous wastes are placed in or directly on land. In the
RCRA regulations, waste piles, surface impoundments, land treatment units, underground
injection wells, salt dome formations, mines, or caves are not regulated as landfills.
Landfills are usually man-made excavations, but their designs invariably include the use of
synthetic materials for liners, caps, and leachate collection systems. These synthetic
materials may include high-density polyethylene, chlorinated and sulfurated polyethylene,
polyvinyl chloride (PVC], and other geosynthetic textiles.
Containment Buildings
Containment buildings are enclosed structures used to store or treat hazardous waste.
They must be completely enclosed to prevent exposure to precipitation and wind, and be
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.
Wastes managed in containment buildings cannot be in liquid form (i.e., flow under their
own weight to fill the vessel in which they are placed, or be readily pumpable}.
Containment buildings must have a primary barrier designed and constructed of
materials to prevent hazardous wastes from being accidentally or deliberately placed on
the land beneath or outside the unit. They must also have controls to prevent fugitive
dust emissions and the tracking of materials from the unit by personnel or equipment.
Containment buildings used to manage hazardous wastes containing free liquids must
include a primary barrier to prevent migration of hazardous constituents into the barrier
and a liquid collection and removal system that will minimize the accumulation of liquid
on the primary barrier; and be equipped with secondary containment including (1} a
secondary barrier and (2} a leak detection, collection, and removal system. Under certain
conditions, containment buildings may serve as secondary containment for tanks placed
within the containment building.
As with tanks and containers, generators may accumulate and treat their hazardous wastes
within these containment buildings without obtaining a RCRA Subtitle C permit. Generators
treating hazardous wastes in order to comply with the applicable land disposal restrictions
treatment standards must develop and follow a written waste analysis plan.
APPENDIX D: Overview of Major Hazardous Waste Management Units
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Waste Piles
Waste piles are areas used for non-containerized storage or treatment of solid, non-flowing
wastes on the land. Waste piles are normally underlain by liners constructed of concrete or
other materials, which act as barriers to prevent direct contact of the waste with the soil
below the unit. Waste piles that are protected from wind, precipitation, and surface water
run-on, and that are not containment buildings, are subject to reduced regulations. Waste
piles and their associated liners and leak detection systems can be constructed of synthetic
materials, including high-density polyethylene and PVC for liners, and a number of
different geosynthetic textiles (e.g., polyester polypropylene] for leak detection apparatus.
Waste piles also use a variety of high-strength polymer plastic pipes for the removal of
leachate and other liquids that have accumulated in leachate collection systems; these are
often made of polyvinyl chloride. Because of the impact of the Land Disposal Restriction
program, most hazardous wastes cannot be placed on a waste pile until they meet the
applicable LDR treatment standards in 40 CFR Part 268, Subpart D.
Land Treatment Units
Land treatment units are units where hazardous waste is applied or incorporated into the
soil surface. Land treatment units are typically units consisting of natural soils where
natural biological and chemical degradation and attenuation processes immobilize,
transform, or degrade hazardous constituents over time. These soils are normally prepared
in a manner that maximizes these reactions in the upper layers of soil (the treatment zone],
and minimizes processes that might inhibit beneficial reactions or result in the release of
hazardous constituents (such as surface water run-off). Because of the impact of the LDR
program, most hazardous wastes cannot be placed in a land treatment unit until they meet
the applicable LDR treatment standards, unless a no migration exemption has been granted
under 40 CFR §268.6.
Miscellaneous (Part 264, Subpart X) Units
Miscellaneous units (e.g., salt domes, burn pans, open burning or detonation grounds]
include a variety of types of units that are not covered by any other permit standards under
RCRA. A miscellaneous unit is 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 Part 264, containment
building, corrective action management unit, or a unit eligible for research, development,
and demonstration permit under 40 CFR §270.65. Under 40 CFR §270.32, EPA or state
regulators has authority to include terms and conditions that it determines necessary to
protect human health and the environment. This is referred to EPA omnibus authority.
APPENDIX D: Overview of Major Hazardous Waste Management Units
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Hazardous Waste Combustors
Hazardous waste combustors (HWCs} are differentiated based on how the CAA defines
source categories and how the combustion unit is designed and operated. Certain types of
boilers and industrial furnaces (BIFs} and incinerators that burn hazardous waste are
examples of hazardous waste combustors. Hazardous waste combustors are subject to
applicable regulatory requirements pursuant to both the RCRA program and the Clean Air
Act (CAA} National Emission Standards for Hazardous Air Pollutants (NESHAP} program.
Prior to the adoption of the CAA Hazardous Waste Combustor (or HWC} NESHAP standards,
emissions from RCRA hazardous waste combustion units were regulated according to 40
CFR Parts 264 and 265 (for incinerators] and 40 CFR Part 266 (for BIFs}. Thus, for BIFs and
incinerators, the RCRA emission standards/limitations and related operating requirements
resided in the RCRA permit or interim status regulations, and all waste analysis
requirements to comply with the requirements were located in the waste analysis plan
(WAP}. Between 1999 and 2005, EPA established new CAA HWC NESHAP emission
standards, testing and operating requirements for incinerators, cement kilns, lightweight
aggregate kilns, boilers, and hydrochloric acid (HC1} production furnaces burning hazardous
waste. The CAA HWC NESHAP is codified in 40 CFR Part 63, subpart EEE.
In order to avoid (to the extent practicable} having duplicative coverage of emission
standards and operating requirements in the RCRA permit and the CAA notification of
compliance and Title V permit, EPA finalized a regulatory approach allowing a facility to
modify its RCRA permit to remove most or all emission standards and emission related
operating requirements that are covered by the CAA HWC NESHAP once the source
demonstrated compliance with the 40 CFR Part 63, subpart EEE. Under this approach, the
CAA HWC NESHAP emission standards and emission related operating requirements reside
in the CAA notification of compliance and Title V permit, while the other RCRA
requirements associated with the combustion unit and the facility remain in the RCRA
permit. Examples of requirements that continue to be part of the RCRA permit for HWCs
include general facility standards, WAPs, closure plans, contingency plans, financial
assurance, corrective action, and RCRA omnibus provisions.
The table below crosswalks some of the requirements for CAA feedstream analysis plans
(FAPs} at 40 CFR §63.1209(c} to similar requirements for RCRA WAPs and waste analyses
at 40 CFR §264.13 and elsewhere in RCRA. It also identifies sections of this manual that
may provide helpful guidance.
APPENDIX D: Overview of Major Hazardous Waste Management Units
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Crosswalk of FAP-WAP Requirements to Sections of this Manual
CAA FAP Requirements at 40 CFR §63.1209(c)
(c) Analysis offeedstreams(1) General. Prior to feeding the material,
you must obtain an analysis of each feedstream that is sufficient to
document compliance with the applicable feedrate limits provided by this
section.
RCRA WAP Requirements at 40 CFR §264.13 (and Related Requirements)
40 CFR §264.13 (a)(l) Before an owner or operator treats, stores, or disposes of any
hazardous wastes, or nonhazardous wastes if applicable under § 264.113(d), he
must obtain a detailed chemical and physical analysis of a representative sample of
the wastes. At a minimum, the analysis must contain all the information which
must be known to treat, store, or dispose of the waste in accordance with this part
and part 268 of this chapter.
Sections of this Manual Relevant
to FAPs
1.1.2 TSDF Waste Analysis
Requirements
1.2.1 Sampling and Analysis for
TSDFs
(2) Feedstream analysis plan. You must develop and implement a
feedstream analysis plan and record it in the operating record. The plan
must specify at a minimum:
40 CFR §264.13 (b) The owner or operator must develop and follow a written waste
analysis plan which describes the procedures which he will carry out to comply with
paragraph (a) of this section. He must keep this plan at the facility. At a minimum,
the plan must specify:
1.1.2 TSDF Waste Analysis
Requirements
Part Two: Documenting and
Conducting Waste Analysis
(i) The parameters for which you will analyze each feedstream to ensure
compliance with the operating parameter limits of this section;
40 CFR §264.13 (b)(l) The parameters for which each hazardous waste, or non-
hazardous waste if applicable under § 264.113(d), will be analyzed and the
rationale for the selection of these parameters (i.e., how analysis for these
parameters will provide sufficient information on the waste's properties to comply
with paragraph (a) of this section);
2.4 Analysis Parameters
(ii) Whether you will obtain the analysis by performing sampling and
analysis or by other methods, such as using analytical information
obtained from others or using other published or documented data or
information;
40 CFR §264.13 (a)(2) The analysis may include data developed under part 261 of
this chapter, and existing published or documented data on the hazardous waste or
on hazardous waste generated from similar processes.
1.2 How Can You Meet the Waste
Analysis Requirements for Your
Facility?
1.2.2 Acceptable Knowledge and
TSDFs
(iii) How you will use the analysis to document compliance with applicable
feedrate limits (e.g., if you blend hazardous wastes and obtain analyses of
the wastes prior to blending but not of the blended, as-fired, waste, the
plan must describe how you will determine the pertinent parameters of
the blended waste);
See 40 CFR 264.13 (b)(l) above.
2.4 Analysis Parameters
(iv) The test methods which you will use to obtain the analyses;
40 CFR §264.13 (b)(2) The test methods which will be used to test for these
parameters;
40 CFR §264.13 (b) (3) The sampling method which will be used to obtain a
representative sample of the waste to be analyzed.
40 CFR §264.13 (b) (4) The frequency with which the initial analysis of the waste
will be reviewed or repeated to ensure that the analysis is accurate and up to date
2.4 Analysis Parameters
2.5 Selecting Sampling Procedures
2.6 Selecting a Laboratory and
Laboratory Analytical Methods
2.7 Quantifying Data uncertainty
2.8 Determining Re-Evaluation
Frequencies
(3) Review and approval of analysis plan. You must submit the feedstream
analysis plan to the Administrator for review and approval, if requested.
40 CFR 270.14 Contents of Part B [Permit Application]: General Requirements.
(b)(3) A copy of the waste analysis plan required by 264.13(b) and, if applicable,
264.13(c).
The need for TSDFs to submit a
WAP as part of a permit
application is discussed generally
in this manual.
(4) Compliance with feedrate limits. To comply with the applicable
feedrate limits of this section, you must monitor and record feedrates as
follows:
(i) Determine and record the value of the parameter for each feedstream
by sampling and analysis or other method;
(ii) Determine and record the mass or volume flowrate of each
feedstream by a CMS. If you determine flowrate of a feedstream by
volume, you must determine and record the density of the feedstream by
sampling and analysis (unless you report the constituent concentration in
units of weight per unit volume (e.g., mg/l)); and
(iii) Calculate and record the mass feedrate of the parameter per unit time.
40 CFR 264.341 (b) Throughout normal operation the owner or operator must
conduct sufficient waste analysis to verify that waste feed to the incinerator is
within the physical and chemical composition limits specified in his permit (under
264.345(b)).
40 CFR 266.102 Permit standards for burners, (b) Hazardous Waste Analysis (2)
Throughout normal operation, the owner or operator must conduct sampling and
analysis as necessary to ensure that the hazardous waste, other fuels, and
industrial furnace feedstocks fired into the boiler or industrial furnace are within
the physical and chemical composition limits specified in the permit.
2.12 Recordkeeping
APPENDIX D: Overview of Major Hazardous Waste Management Units
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX E:
Glossary of Terms
Captive TSDF: A TSDF that receives hazardous wastes only from generation sites within its
own corporation. Such generation site(s] could be located on the same site as the captive
TSDF or off-site.
Certification: A written statement of professional opinion and intent signed by an
authorized representative that acknowledges an owner's or operator's compliance with
applicable LDR requirements. Certifications are required for treatment in surface
impoundment exemption requests, applications for case-by-case extensions to an effective
date, no-migration petitions, and waste analysis and recordkeeping provisions applicable
to any person who generates, treats, stores, or disposes of hazardous wastes (excluding
generators that do not treat on site and send waste off site to be treated}. The information
referenced by the certification must be true, accurate, and complete. There are significant
penalties for submitting false information, including fines and imprisonment.
Commercial TSDF: A TSDF engaged in the conduct of commercial (i.e., for-profit] waste
management that receives hazardous wastes generated by other companies. Such
companies are normally located off-site.
Disposal Facility: A facility or part of a facility at which hazardous waste is intentionally
placed into or on any land or water, and at which waste will remain after closure.
Facility: All contiguous land, structures, or other appurtenances, and improvements on the
land, used for treating, storing, or disposing of hazardous waste. A facility may consist of
one or several treatment, storage, or disposal operational units (e.g., one or more landfills,
surface impoundments, or combinations of them}.
Fingerprint Analysis: Sampling and analysis of several key chemical and physical
parameters of a waste to substantiate or verify the composition of a waste as determined
previously during a full-scale waste characterization. Fingerprint analysis is typically used
by generators and off-site TSDFs to expedite waste characterization of frequently
generated or received wastes. Parameters for analysis may be a subset of the parameters
used during full-scale characterization, or they may be parameters that are not normally
present in the waste to verify the absence of certain constituents.
Generator: Any person, by site, whose act or process produces hazardous waste identified
or listed in Part 261 of RCRA or whose act first causes a hazardous waste to become subject
to regulation.
Hazardous and Solid Waste Amendments (HSWA): Amendments to RCRA in 1984, that
minimize the nation's reliance on land disposal of hazardous waste by, among other things,
requiring EPA to evaluate all listed and characteristic hazardous wastes according to a
strict schedule to determine which wastes should be restricted from land disposal.
APPENDIX E: Glossary of Terms
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Hazardous Waste: Waste that, because of its quantity, concentration, or physical,
chemical, or infectious characteristics, may cause or significantly contribute to an increase
in mortality or an increase in serious irreversible, or incapacitating reversible, illness, or
pose a substantial present or potential hazard to human health or the environment when
improperly treated, stored, transported, or disposed of, or otherwise managed. Hazardous
wastes are listed in 40 CFR Part 261 and/or exhibit one of the four characteristics in 40
CFR Part 261 (i.e., ignitability, corrosivity, reactivity, and toxicity}.
Hazardous Waste Code: The number assigned by EPA to each hazardous waste listed in
40 CFR Part 261, Subpart D, and characteristic waste identified in 40 CFR Part 261,
Subpart C.
Interim Status: Provision of RCRA that allows a facility to operate without a permit
provided 1} the facility was in existence on November 19, 1980; 2} the facility is in
existence on the effective date of a new regulation that lists a waste as a hazardous waste
or establishes a new characteristic of hazardous waste; or 3} the facility is in existence on
the effective date of a new regulation that regulates a hazardous waste management unit for
the first time. In both circumstances, Part A of the permit application must be submitted
to EPA by a specified date (with Part B submitted voluntarily or "called in " by EPA at a
subsequent date}. The intent of interim status is to allow a facility to continue to operate
for a short time period pending approval of their permit application.
Lab Pack: A lab pack is an over packed container, usually a steel, fiber, or polyethylene
drum, containing small containers of chemicals of the same hazardous class packed in non-
biodegradable absorbent materials.
Land Disposal Restrictions: Provision of HSWA that prohibits the land disposal of
hazardous wastes into or on the land unless EPA finds that it will not endanger human
health and the environment. EPA must develop levels or methods of treatment that
substantially diminish the toxicity of the waste or the likelihood that hazardous
constituents will migrate from the waste that must be met before the waste is land
disposed. Strict statutory deadlines were imposed on EPA to regulate the land disposal of
specific hazardous wastes, concentrating first on the most harmful. EPA has met all of the
Congressionally mandated dates.
Notification: When restricted wastes are being shipped off-site for treatment, storage,
disposal, or are managed on-site, EPA has established a tracking system that requires that
notifications and certifications be sent to the receiving facility or if applicable to EPA or the
appropriate EPA representative. These requirements are outlined in 40 CFR §268.7. For
example, notification requirements include the EPA Hazardous Waste Number,
corresponding treatment standards or prohibition levels, the manifest number, and waste
analysis data.
Off-Site Facility: A facility that receives and manages hazardous waste from another
facility that is not geographically on site.
On-Site Facility: A facility that manages only those hazardous wastes that are generated
on its own geographic site.
APPENDIX E: Glossary of Terms
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Prohibited Wastes: Prohibited wastes are a subset of restricted wastes (under the LDR
regulations] that have established treatment standards but do not meet the respective
treatment standards, nor have a variance or waiver in effect and are, therefore, currently
ineligible for land disposal.
RCRA Subtitle C Permit: An authorization via a permit from EPA that allows a facility to
treat, store, and/or dispose of hazardous wastes. The permit includes administrative
requirements and facility operating and technical standards for each type of waste
management unit that is being permitted. [Facility owners/operators must submit a two-
part (Part A and Part B] permit application to obtain a permit]
Resource Conservation and Recovery Act (RCRA): The Resource Conservation and
Recovery Act of 1976 regulates hazardous waste generation, storage, transportation,
treatment, and disposal. The Act was amended three times: most significantly, on
November 8, 1984. The 1984 amendments called HSWA significantly expanded the scope
and requirements of RCRA.
Restricted Wastes: Restricted wastes are those 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. While some
restricted wastes may be eligible for land disposal without meeting treatment standards, all
restricted wastes are, at a minimum, subject to the waste analysis, notification, and
recordkeeping requirements of 40 CFR §268.7.
State Director: A term used in the RCRA regulations to denote the state hazardous waste
agency.
Storage Facility: A facility that holds hazardous waste for a temporary period, at the end of
which the hazardous waste is treated, disposed of, or stored elsewhere.
Subtitle C Facility: A facility that manages hazardous wastes as defined by RCRA. These
facilities may include generators, disposal facilities (e.g., landfills, surface impoundments],
treatment facilities, (e.g., incinerators] and storage facilities.
Subtitle D Facility: A facility that manages non-hazardous wastes as defined by RCRA.
These facilities may include disposal facilities (e.g., landfills], treatment facilities (e.g.,
incinerators], and storage facilities.
Toxicity Characteristic Leaching Procedure (TCLP): A method to determine the mobility
of both organic and inorganic contaminants in liquids, solids, and multiphasic wastes.
Transporter: A person engaged in the off-site transportation of hazardous waste by air,
rail, highway, or water.
Treatment Facility: A facility that uses 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 to render such waste
either non-hazardous or less hazardous; safer to transport, store, or dispose of; or
amenable for recovery, amenable for storage, or reduced in volume.
APPENDIX E: Glossary of Terms
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Waste Analysis: Obtaining a detailed chemical and physical analysis of a representative
sample of a waste. The analysis may include data developed using sampling and analysis, as
well as existing published or documented data on the waste or waste generated from
similar processes.
Waste Analysis Plan (WAP): Document describing the procedures that will be carried out
at a facility to meet waste analysis requirements.
APPENDIX E: Glossary of Terms
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX F:
Key Considerations and Tips
Key Considerations for Waste Analysis Plans
WAPs are not one-size-fits-all; a WAP that is appropriate for a commercial
treatment/storage/disposal facility may not be appropriate for treatment/disposal
facilities, or even captive storage facilities.
Do not clutter up the WAP by repeating information that exists elsewhere in the permit
(e.g., basic facility description, process descriptions}.
Prepare procedures for subjecting all wastes to the same level of analysis, not just
hazardous wastes.
Focus on up-front waste profiling, this is especially important for "back-end
treatment/disposal facilities.
Include some amount of off-site independent laboratory analysis. It is important to
conduct actual analysis as opposed to relying solely on just generator knowledge.
Procure a laboratory with a state laboratory certification programs like Virginia's
VELAP or other reputable third-party accreditation. It is very difficult for a TSDF to
maintain an adequate on-site lab.
Include electronic records management tools used by the facility, [e.g., Excel
spreadsheets (for TSDFs] and custom software programs (for generators who are
allowed to perform statistical analysis of homogeneous wastestreams and are allowed
to exclude outliers}].
Recommend that all wastes received are subject to some level of waste analysis not just
those received as "hazardous waste".
Specify the test methods (SW-846, ASTM, or other] to be used to test for each
parameter, in accordance with 40 CFR §264.13(b](2].
Include sampling protocols for different containers and transport vehicles (e.g., drums
and tankers] and different materials or phase-separated wastestreams.
Recommend the facility perform a "discrepancy review" when the waste acceptance
testing show a certain percentage variance (to be negotiated with the facility] from the
waste profile data (e.g., for BTU value discrepancy, require a discrepancy review if the
BTU value varies by more than 15%].
Provide documentation for discrepancies and resolution (e.g., rejected load or modified
profile] in the facility operating record. Provide documentation of any unusual
APPENDIX F: Key Considerations and Tips
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
conditions that occur after the waste has passed acceptance criteria and waste is
accepted into the facility (e.g., a tank farm}.
Key Considerations for the Permitting Agency and Inspectors
Become familiar with the facility; schedule a visit.
Use clear, enforceable language when preparing permit conditions and require the
same from the facility in their permit application (e.g., use "must" and "shall" as
opposed to "may" or "should"}.
Consider including a permit condition that requires notification of any changes to the
WAP or deviation from a test method.
Include a permit condition requiring notification of any changes to the WAP or significant
deviation from a test method.
Maintain a generic permit template that includes all federal/state conditions. Keep it
up-to-date.
During inspections, or compliance evaluations consider using someone on-staff (Agency
or Agency contractor} with a chemistry or laboratory background to evaluate WAP
compliance.
Key Considerations for Generators
Learn your legal responsibilities under RCRA and your state's hazardous waste program
by reviewing your state's generator standards and guidance.
Speak with the personnel at your site and compile paperwork to develop a collective
knowledge of your generating processes, potential wastes, regulatory requirements, and
opportunities for waste minimization.
Contact your state agency, or the agency in the TSDF's state, if you have questions (e.g.,
should the analyses be performed by certified laboratory?}.
If necessary, contract with a qualified consultant or TSDF for assistance in identifying,
collecting, and characterizing your waste
Ensure that the implementation of the WAP will avoid mixing of incompatible wastes and
placing wastes in incompatible accumulation tanks/containers.
Obtain representative samples for unlisted wastes; that is, a sample of a universal or
whole (e.g., waste pile, lagoon} which can be expected to exhibit the average properties'
of the universe or whole.
Include procedures for obtaining/maintaining documentation sufficient to support
waste/acceptable knowledge determinations in lieu of testing (i.e., process knowledge,
records of analyses or combination of these with actual chemical analysis of the waste}.
APPENDIX F: Key Considerations and Tips
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Support any claims that secondary materials are NOT solid and/or hazardous waste
with documentation.
Do not rely on a single analysis to characterize subsequent wastestreams. Waste-
derived residues must be sampled as often as necessary for the owner/operator to
determine whether the residue is excluded or fully regulated hazardous waste. All
waste-derived residue generated since the previous successful analysis could be viewed
as fully regulated absent documentation demonstrating otherwise
Make sure you determine what constitutes a new point of generation especially
considering applicability of new underlying hazardous constituents (UHCs].
Use appropriate methods and avoid undocumented methods developed by the
generator for process QA/QC.
Be aware of what happens if the waste contains Appendix VIII constituents but does not
meet the definition of a hazardous waste.
Be aware of the need to characterize your waste more frequently if your process
changes.
Remember that thermal treatment by generators is prohibited except in select units.
Make sure you adequately address your process description in the WAP when using
acceptable knowledge especially if it relates to characterizing F- and K- listed wastes.
Tips for RCRA Inspectors to Evaluate Facility Compliance with Waste
Analysis Plans
Before inspecting the TSDF, familiarize yourself with the facility's permit and
operations generally, including the WAP. Develop a facility-specific inspection plan and
questions to ask the facility when on-site. Perform database searches and review
available facility records, such as Biennial Reporting data on the types and quantities of
wastes received on-site. Reviewing these reporting data may indicate particular
challenges that the facility may encounter when implementing their WAP (e.g., you may
notice that some generators are submitting highly variable wastes that could require
frequent re-characterization}. During your inspections, be sure to ask questions about
these challenges.
During the inspection, speak with the individuals] authorized by the TSDF to be
responsible for ensuring compliance with the WAP (e.g., facility manager or designee]
to get an overview of the facility's experiences using the WAP (e.g., problems, concerns,
questions}. This conversation could occur, for example, during the opening meeting.
Follow up on possible violations, problems, and questions raised. Ask questions about
key processes and procedures in the WAP to ensure the procedures are correctly
followed and that the WAP is up-to-date.
APPENDIX F: Key Considerations and Tips
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Ask questions about the pre-qualification process to ensure the facility is evaluating
new wastestreams adequately. For example, if generic profiles are being used, are they
used only in appropriate situations (e.g., generic profiles are not appropriate for wastes
that must meet numerical limits, such as feed streams into combustion units}.
Request the SOPs for some of the sampling analysis being performed by the facility (e.g.,
pH tests] and determine if they are being followed. This can be accomplished, for
example, by observing facility personnel in the conduct of their job responsibilities (e.g.,
during sampling of drums of an incoming shipment] or by briefly interviewing
laboratory personnel to evaluate their understanding of these procedures. (See below
for additional tips on laboratories].
Ask the facility how often it has found discrepancies between incoming shipments and
waste profiles, and review relevant records. In these cases, did the TSDF identify the
causes and implement appropriate corrective actions to prevent recurrence? Were new
or revised waste profiles developed in all cases? Ask treaters and disposers how often
they test their treated wastes for LDR compliance (e.g., each batch]? For wastes that
have failed to meet applicable LDR standards, what were the causes (e.g., is there a
pattern of failures suggesting a common cause?] and what corrective actions were
taken to prevent their recurrence?
Review the facility's training records of key personnel (e.g., environmental
technicians] to verify that they are given frequent training on relevant knowledge
and skills related to waste sampling and analysis. Interview facility personnel and
observe them performing their job functions to evaluate their knowledge and skills
(e.g., ask for facility workers to demonstrate how to properly sample a drum using a
coliwasa; ask him when a grab vs. composite sample is required for wastes managed
under this authority].
For on-site laboratories at a generator or TSDF:
Ask for a split sample of waste (e.g., a waste that has been treated to meet LDR
standards] to be sent to an independent laboratory that is trusted by EPA to verify
the on-site laboratory's results.
Make certain that it has the required instrumentation (e.g., does it have a Pensky-
Martin flashpoint apparatus if that method is how it reports flashpoint and is it
maintained?] and a trained operator can explain its use. pH is often not correctly
understood or performed for solid and semisolid waste, so reviewing those
procedures can be enlightening regarding the actual level of understanding of the
technicians assigned to these tasks.
Review the laboratory's certificate of accreditation (if the state requires laboratory
accreditation] to make certain that it has achieved and maintained accreditation in
the parameters it is testing. State accreditation programs universally require that
accredited laboratories participate in external performance evaluation programs.
Ask to see records of the evaluations.
APPENDIX F: Key Considerations and Tips
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Consider bringing a chemist or related expert to the inspection to review laboratory
results (or otherwise, copy analytical records and take them for later review}. For
example, the chemist could review a sample of laboratory results to verify that the
analytical methods used were appropriate and the detection limits were sensitive
enough to evaluate compliance with applicable numerical limits.
APPENDIX F: Key Considerations and Tips
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
APPENDIX G:
References
A Method for Determining the Compatibility of Hazardous Wastes, EPA-600/2-80-076. U.S.
Environmental Protection Agency, Cincinnati, Ohio, 1980.149 pp.
Burning of Hazardous Waste in Burners and Industrial Furnaces. Federal Register 56:166
[27 August 1991). p. 42509. Retroactive Hazardous Waste Designation.
Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous
Waste Sites, U.S. Environmental Protection Agency, OSWER 9285.6-10. December 2002.
Characterizing Heterogeneous Wastes: Methods and Recommendations. U.S.
Environmental Protection Agency, ORD, U.S. Department of Energy, EPA 600-R-92-033.
February 1992.
Clean Water Act Analytical Methods.
Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant's
Compliance With the Disposal Regulations. Federal Register 67:154 (9 August 2002} p.
51942. Acceptable Knowledge Definition.
Design and Development of a Hazardous Waste Reactivity Testing Protocol. EPA-600/52- 84-
057, U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory,
Cincinnati, Ohio, 1984.
Guidance Manual for Hazardous Waste Incinerator Permits. SW-966, U.S. Environmental
Protection Agency, Washington, D.C., 1983.
Guidance of Systematic Planning Using the Data Quality Objectives Process, EPA240-B-06-
001. U.S. Environmental Protection Agency, Washington, D.C., February 2006.
Hazardous Waste Management System. Federal Register 55:27 [8 February 1990) pps.
4443-4444. Representative Sample Definition.
Hazardous Waste Treatment, Storage, and Disposal Facilities and Hazardous Waste
Generators. Federal Register 59:233 (6 December 1994} p. 62916. Examples of Acceptable
Knowledge.
Identification and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001. Listing
of Hazardous Waste (40 CFR §§261.31 and 261.32], Background Document. U.S.
Environmental Protection Agency, Washington, D.C., 1980. 855 pp.
APPENDIX G: References
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Joint NRC/EPA Guidance on Testing Requirements for Mixed Radioactive and Hazardous
Waste. Federal Register 62:224 (20 November 1997) pps. 62079-62082. Mixed Radioactive
and Hazardous Waste and Use of Waste Knowledge for Hazardous Waste Determinations.
Land Disposal Restrictions for Newly Identified and Listed Hazardous Wastes and
Hazardous Soil. Federal Register 58:176 (14 September 1993) pps. 48111-48112.
Demonstrating Acceptable Knowledge.
Land Disposal Restrictions for Second Third Scheduled Wastes. Federal Register 54:120 (23
June 1989). pps. 26605-26606. Treatment Standards Based on Single Facility Data and Grab
Samples Versus Composite Samples.
Land Disposal Restrictions for Third Third Scheduled Wastes. Federal Register 55:106 (1
June 1990). p. 22539. Treatment Standards Based on Single Facility Data, Grab Samples
Versus Composite Samples, and Waste Analysis Plans.
Land Disposal Restrictions Phase II--Universal Treatment Standards, and Treatment
Standards for Organic Toxicity Characteristic Wastes and Newly Listed Wastes. Federal
Register 59:180 (19 September 1994) pps. 48003-48004. LDR Lab Packs Phase II.
Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment Standards for
Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials
and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of
Recycled Wood Preserving Wastewaters. Federal Register 63:100 (26 May 1998} p.
28562. Development of New Treatment Standards for Hazardous Wastes Containing
Metals: Measuring Compliance by Grab or Composite Sampling.
Land Disposal Restrictions Phase IV: Treatment Standards for Wood Preserving Wastes,
Treatment Standards for Metal Wastes, Zinc Micronutrient Fertilizers, Carbamate
Treatment Standards, and K088 Treatment Standards. Federal Register 64:90 (11 May
1999) pps. 25411-25412. Treatment Residual, New Point of Generation, and UHCs.
Methods Innovation Rule (MIR}. U.S. Environmental Protection Agency, Washington, D.C.,
2005.
Observational Economy Series, Volume 1: Composite Sampling, U.S. Environmental
Protection Agency, Washington, D.C., EPA230-R-95-005.1995.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, U.S.
Department of Labor, Occupational Safety & Health Administration, October 1985.
Permit Applicants' Guidance Manual for the General Facility Standards of 40 CFR §§264.
SW-968, U.S. Environmental Protection Agency, Washington, D.C., 1983.
APPENDIX G: References
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Permit Applicants' Guidance Manual for Hazardous Waste Land Treatment. Storage, and
Disposal Facilities. SW-84-004, U.S. Environmental Protection Agency, Washington, B.C.,
1983.
RCRA Orientation Manual 2011. U.S. Environmental Protection Agency, Washington, B.C.,
EPA 530-F-11-003. 2011.
RCRA Waste Management: Planning, Implementation, and Assessment of Sampling
Activities, Manual 42. American Society of Testing and Materials, 2000.
RCRA Waste Sampling Braft Technical Guidance, Planning, Implementation and
Assessment, EPA 530-B-02-002. 2002.
Revision of Wastewater Treatment Exemptions for Hazardous Waste Mixtures
("Headworks Exemptions"}. Federal Register 70:191 (4 October 2005) pps. 57769-57771.
Headworks Exemptions.
Standard Methods for the Examination of Water and Wastewater, 22nd Edition. American
Public Health Association (APHA], the American Water Works Association (AWWA], and
the Water Environment Federation (WEF], S82210, 2012.
Superfund Program Representative Sampling Guidance, U.S. Environmental Protection
Agency, Washington, B.C., EPA 540-R-95-141.1995.
Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846. Third
Edition, Through Final Update IVB, U.S. Environmental Protection Agency, Washington,
B.C., 2008.
APPENDIX G: References
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