United States
          Environmental Protection
          Agency
Solid Waste And
Emergency Response
(5303P)
EPA 530-R-1 2-001

April 2015

http://www.epa.gov
Waste Analysis at Facilities that
Generate, Treat, Store, and Dispose
of Hazardous Wastes -Final
A Guidance Manual
                                    Storage
          Generation/
           Treatment
                           Land
                          Disposal

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DISCLAIMER

This manual 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  manual.  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 manual 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.gailOepa.gov.

EPA wishes to acknowledge and thank the  following  EPA and state representatives for
providing input into the manual: 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],  Tracy 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	1-10
           1.1.3  Transmitting Waste Analysis Information	1-13
      1.2  How Can You Meet The Waste Analysis Requirements For Your Facility?	1-15
           1.2.1  Sampling and Analysis for TSDFs	1-17
           1.2.2  Acceptable Knowledge and TSDFs	1-19
           1.2.3  Waste Analysis for Generators	1-24

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	2-20
           2.4.4  Special Parameter Selection Requirements	2-22
      2.5  Selecting Sampling Procedures	2-27
           2.5.1  Sampling Strategies and Sampling Frequencies	2-28
           2.5.2  Selecting Sample Equipment	2-39
           2.5.3  Maintaining and Decontaminating Field  Equipment	2-44
           2.5.4  Sample Preservation and Storage	2-44
           2.5.5  Establishing Quality Assurance/Quality Control Procedures	2-45
           2.5.6  Establishing Health and Safety Protocols	2-50


Table of Contents

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

       2.6   Selecting a Laboratory and Laboratory Analytical Methods	2-50
            2.6.1  Selecting a Laboratory	2-50
            2.6.2  Selecting Laboratory Analytical Methods	2-54
       2.7   Quantifying Data Uncertainty	2-58
       2.8   Determining Re-Evaluation Frequencies	2-61
       2.9   Special Procedural Requirements	2-64
            2.9.1  Procedures for Receiving Wastes Generated Off-Site	2-64
            2.9.2  Procedures for Combustion Facilities	2-67
            2.9.3  Procedures for Ignitable, Reactive, and Incompatible Waste	2-71
            2.9.4  Procedures for Complying with LDR Requirements	2-71
       2.10  Discrepancy Policy	2-74
            2.10.1 Manifest Discrepancies	2-74
            2.10.2 Discrepancies Between Incoming Waste and Profile	2-75
       2.11  Rejection Policy	2-76
       2.12  Record keeping	2-76
       2.13  Corrective and Preventative Action Measures	2-79
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 Key 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	2-31
TABLE 2-5: Major Sample Types	2-33
TABLE 2-6: Applicability of Sampling Equipment to Wastestreams	2-43
TABLE 2-7: Important QA Elements	2-52
TABLE 2-8: Laboratory QC Techniques	2-53
TABLE 2-9: Re-Evaluation Frequencies	2-63
                               List of Figures
FIGURE 1-1: Summary of Generator Testing, Analytical & Documentation Requirements	1-5
FIGURE 1-2: Analytical Requirements for LQGs Determining Applicability of Standards
under SubpartsAA, BB, and CC of 40 CFR Part 265	1-6
FIGURE 1-3: Summary of TSDF Analytical Requirements	1-12
FIGURE 1-4: Waste Analysis Data Flow	1-14
FIGURE 1-5: Waste Analysis Quality-Conceptual Model	1-16
FIGURE 2-1: The Seven Steps  of the DQO Process	2-11
FIGURE 2-2: Waste Analysis Parameter Selection Process	2-21
FIGURE 2-3: Illustration of Simple Random, Stratified Random and
Systematic Random Sampling	2-32
FIGURE 2-4: Samplers for Liquid Wastestreams	2-41
FIGURE 2-5: Samplers for Solid Wastestreams	2-42
FIGURE 2-6: Precision Versus Bias	2-47
FIGURE 2-7: Example Chain-of-Custody Record	2-49
FIGURE 2-8: Analytical Methods Selection Flowchart	2-57
FIGURE 2-9: Shipment Screening	2-66
FIGURE 2-10: Example Waste Profile Sheet	2-80
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
H&S     Health and Safety
HW     Hazardous Waste
HWC    Hazardous Waste Combustor
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 Part 279. In addition,  the manual  can be helpful to federal and state permit
writers  in evaluating  WAPs and inspectors/enforcement  personnel in determining
whether a facility is in compliance with its WAP requirements. 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, consult your state's regulations to  learn the requirements that
apply to you.

This manual has 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 EPA has updated the manual to
reflect experience that the Agency and states have gained  since then.  Some of the new
recommendations  in  this current  edition (e.g., for greater use  of testing]  reflect this
experience. In addition, 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 to give
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


permit applicants and permit writers ideas to consider when preparing or approving a WAP.
This edition  also includes  information on  some changes  to the federal RCRA program
concerning waste analysis requirements that were promulgated since the last edition (e.g.,
new regulations}. The following is a list of these program changes:

   Definition of solid waste final rules.

   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 [Parts
   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 acceptable 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. A facility may also apply
acceptable knowledge of  the  waste in  lieu of
testing the waste, as  specified.  Proper  waste
analysis  is needed to:
                                                     http://www.gpo.gov/fdsys/
   _      .      ,   ,                 .     T^r. A       RCRA Orientation Manual
   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 and       urces/pubs/rmods.htm
   avoid commingling incompatibles.

   Ensure you  are  complying with  permitted
   feedrate  (e.g., metal  feedrates]  and  other
   numerical limitations as applicable.
                                                     TSDFTool
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,       http://www.epa.gov/waste/laws-
  °.     ,                                            regs/regs-haz.htm
or disposal.
The   majority   of  RCRA's   waste   analysis
requirements apply to hazardous waste generators
 General References on the RCRA Program

• EPA Regulations (Title 40)
  http://www.epa.gov/epawaste/inforeso
  urces/pubs/orientat/
  RCRA Online (database)
  http://www.epa.gov/epawaste/inforeso
  urces/pubs/orientat/
  RCRA Training Modules
  http://www.epa.gov/epawaste/inforeso
  Envirofacts (database)
  http://www.epa.gov/enviro/index.html
  RCRAInfo (database)
  http://www.epa.gov/enviro/facts/rcrainf
  o/index.html
  http://www.epa.gOV/epawaste/hazard/t
  sd/permit/tsd-regs/tsdf-ref-doc.pdf
  EPA Hazardous Waste Regulations
  EPA Test Methods for Hazardous Waste
  http://www.epa.gOV/epawaste/hazard/t
  estmethods/index.htm
2 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 should consult your state's regulations to
learn the requirements that apply to you.
3 Use of the phrase "waste analysis" refers to both waste testing and applying acceptable knowledge.
PART ONE: RCRA Waste Analysis - An Overview

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


and  TSDFs. The  RCRA generator standards primarily apply to large quantity  generators
(LQGs} and small quantity generators (SQGs}.4 Briefly, LQGs and SQGs are required to:

   Determine if they have generated a hazardous waste (see 40 CFR 262.11}.

   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 until it meets those standards.5 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 which describes  the  procedures they will carry out to
   comply with the LDR treatment standards (§268.7}.6

   Manage the  hazardous  wastes in accordance with the applicable Part 262 and 268
   requirements (e.g., accumulate the hazardous  wastes only in tanks,  containers,  or
   containment buildings that meet specified standards, perform periodic inspections}.

   Comply with Parts 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 Parts
264  through 268 and 270. Concerning the waste analysis requirements,  §§264/265.13
require a TSDF to:

   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.

   Test their treated waste according to the frequency specified in their  waste analysis
   plan to assure that they meet the applicable treatment standards.

   Prepare and  follow  a WAP that adequately describes the  methods, procedures and
   equipment that will be used to perform these analytical requirements.
4 Conditionally exempt small quantity generators (CESQGs) are subject to the regulations at 40 CFR 261.5, including
the need to make hazardous waste determinations.
5 Land disposal as defined in §268.2 means placement in or on the land, except in a corrective action management
unit or staging pile, and includes, but is not limited to, placement in a landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome formation, salt bed formation, underground mine or cave, or
placement in a concrete vault or bunker intended for disposal purposes. The RCRA statute draws no distinction in
the duration of disposal. "Temporary" placement in a land disposal unit is "land disposal" just as much as is
permanent disposal.
6 Enforcement of the LDR requirements is based on the treatment standard, not the facility's waste analysis plan,
so that enforcement officials would normally take a single grab sample and analyze for all constituents regulated
by the applicable treatment standards. (See Federal Register 54:120 (23 June 1989). p. 26606.)
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, 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, see 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.

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 40 CFR 262.11 to determine if
their wastes are hazardous. If a hazardous waste generator intends to send the hazardous
waste to a  TSDF, he may be required to  provide waste-related information to the TSDF,
such as  a waste profile  (see  Section  1.1.2 on  pre-acceptance] or information that
accompanies an LDR notice with a shipment (see the "Generator Paperwork Requirements
Table" at §268.7(a}(4}}. A generator is not required to prepare a WAP unless he is
managing  and  treating waste or  contaminated  soil  in  tanks,  containers,  or
containment buildings regulated under §262.34 to meet applicable  LDR treatment
standards. Figures  1-1 and 1-2 provide an overview of the 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
„,    I_T^ en  ,-1^    j                              prepare a WAP except when
Subpart D of Part 261; and
   r                                                 managing and treating waste or
                                                     contaminated soil in qualified
                                                     units to meet applicable LDR
261, determining whether the waste exhibits any of the    treatment standards found at
,   '       ,    <-•<-•   •  c  u    <-r  fn  <-o£-i  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 acceptable knowledge to
   For purposes of compliance with the LDR Program in
   Part 268, or if the waste is not listed in Subpart D of Part
PART ONE: RCRA Waste Analysis - An Overview

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   make the determination. (See Section 1.2.2 of this manual 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 or acute hazardous waste, you must determine
the amount of hazardous  waste  that you generated during  that calendar month,  as
required by §261.5. You then must determine whether you are a small quantity generator
(SQG}, large quantity generator (LQG), or conditionally exempt small quantity generator
(CESQG):7

   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}.

   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 the waste analysis requirements 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 identify all applicable treatment standards under the
LDR program. You must refer to  the treatment standards  in  §§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 acceptable 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  §§264/265.13 and 268.7(b}.

If the hazardous waste does not meet the treatment standards, as generated, 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 a requirement to test the waste  or use
acceptable knowledge of the waste to determine if the air emission requirements apply to
your units.
7 The quantities shown only apply to hazardous waste. For acute hazardous waste quantities, see 40 CFR 261.5(e).
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 Testing, Analytical & Documentation 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 LOG? (261.5 and 262.34)°
                        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-
       site in 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)) to test waste and comply
with other applicable  LDR requirements

    Ship wastes meeting treatment
standards to disposer with 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 Determining Applicability of Standards 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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
LDRs: Underlying Hazardous Constituents
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],  as required by
§268.9(a}.  A  UHC is  any  constituent  listed  in
§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  (§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
the  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 Table  UTS in §268.48,
which lists the regulated constituents  (i.e.,  UHCs}
and their respective treatment standards expressed as concentrations. The waste must be
treated to both eliminate the characteristic^} and meet the UTS treatment standards for the
UHCs,  as indicated in the table. Compliance with the treatment standards is based on grab
sampling, unless  otherwise noted  in the table.  Compliance with the wastewater treatment
standards is based on the maximum for any one day, except for D004 through D011 wastes
for which the previously promulgated treatment standards based on grab samples remain in
effect.  (See §268.40(b}.}8
        Applicability of UHCs to
         Treatment Residuals

Generators of characteristic hazardous
wastes are required to identify any
underlying hazardous constituents
reasonably expected to be present above
their concentration-based levels (see Table
UTS in §268.48) at the point of generation.
This means that, for metal constituents that
did not qualify as UHCs in the original waste
but 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 Federal
Register 64:90 (11 May 1999) p. 25411 for
additional clarification.
 Compliance with LDR treatment standards for nonwastewaters is based on grab sampling (i.e., a one-time sample
taken from any part of the treated waste), rather than composite samples (i.e., a combination of samples collected
at various locations for a given waste, or samples collected over time from that waste). The Agency believes that
grab samples generally reflect maximum process variability and thus would reasonably characterize the range of
treatment system performance. (See Federal Register 54:120 (23 June 1989). p. 26605 and Federal Register
55:106 (IJune 1990). p. 22539.) The grab sample also meets the ultimate objective of the LDR program that all of
the hazardous waste to be land disposed be treated in a way that minimizes threats that land disposal could pose,
not just the average portion of the waste to be so treated (a possible result of using composite sampling).  In
addition, since grab sampling is based on an individual sampling event, it facilitates the collection of data to
evaluate compliance. This is discussed further in Section 2.5.1 of this manual.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                       Examples of the Applicability of UHCsto Treatment Residuals


  Following is a discussion of the applicability of UHCsto treatment residuals.  Two scenarios are described and
  analyzed.
  Background
  Scenario 1: A D007 chromium waste is incinerated. Trace quantities of lead are present in the original waste,
  but at levels below the UTS (thus, lead is not a UHC under §268.2(i)). The resulting ash is no longer
  characteristic for chromium,  but lead is now present at levels above the UTS.
  Scenario 2: A D008 lead wastewater contains no underlying hazardous constituents as generated, but is treated
  with dithiocarbamate, a metal precipitating agent. Dithiocarbamate is also a hazardous constituent that
  appears on the list of potential UHCs in §268.48. The dithiocarbamate assists the stabilization of the lead but,
  after treatment, is present at levels above the UTS in the treatment residuals.
  Analysis
  In both scenarios, the treatment residuals (ash and sludge) demonstrate that the original waste is
  decharacterized. Under §268.2(i), the only UHCs that must be treated and that must meet the Universal
  Treatment Standards (UTS) are those determined to  be present above UTS levels in the original waste, i.e., at
  the point of generation-either via testing or generator knowledge. Because the treatment process results in
  non-hazardous residuals, the treatment facility is not responsible for additional testing to determine if any
  different underlying  hazardous constituents are added or created during the treatment process itself.
  Furthermore, only the original UHCs must meet the UTS.
  However, if in either case the treatment residual is also characteristic by having constituents that are not only
  above the UTS level but also above the TC level, then the residual is a newly-generated hazardous waste for
  LDR purposes. This result is consistent with the definition of generator at §260.10. The result is also consistent
  with the key LDR principle that hazardous wastes must meet  LDR treatment standards to minimize threats
  before the wastes are land disposed. For these reasons, the Agency regards generation of a new characteristic
  treatment residual as being a new point of generation for LDR purposes.
  This newly-formed hazardous waste would have to be treated to below the characteristic and any underlying
  hazardous constituents would have to be treated to below their UTS levels.
  Thus, in the first scenario above regarding a decharacterized waste with lead in the ash, if the lead is present in
  the ash at or above TC levels (i.e., a new D008 waste has been generated), the lead must be treated to UTS
  levels. Furthermore, the treater has generated the new hazardous waste for LDR purposes and is responsible
  for a new determination of UHCs that are present and that require treatment to UTS levels. The same is true in
  the second example  if the dithiocarbamate treatment sludge is characteristic.
  See Federal Register 64:90 (11 May 1999) p. 25411 for additional clarification.
Rules for characteristic wastes under §268.9 require generators to identify all the listed
and characteristic waste codes that could  apply to their waste.  If a listed  waste  also
exhibits a characteristic, the treatment standard for the listed waste may operate instead of
the characteristic treatment standard, provided that the treatment standard for the listed
waste includes a treatment standard for the constituent that caused the waste to exhibit
the characteristic.  In these  cases, there  would be no  need  to meet  the  treatment
standards for UHCs.  However, where the treatment standard for the listed waste does not
include a  treatment  standard for  the  constituent that  caused the waste  to exhibit  a
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
characteristic, the waste must meet the treatment standards for all  applicable listed  and
characteristic waste codes.
                  Determining Applicability of UHCs During and After Waste Treatment

  In determining whether a treatment process has generated a new hazardous waste for LDR purposes and
  therefore is subject to the requirement for UHCs, the Agency looks to the entire treatment process, not to each
  component part. In general, the determination of whether a new hazardous waste is generated--!.e., whether a
  new point of generation for LDR purposes is created—is made at the completion of the treatment process.
  •  For residuals that are the end product of a one-step treatment process or the end product of a treatment
     train, the treater has the obligation to ensure only that the original UHCs meet UTS standards and that the
     treatment residuals are not themselves characteristic. If a treatment residual in this scenario does not
     meet the treatment standards for the original characteristic (i.e., when treatment is ineffective or
     incomplete) and requires further treatment, EPA does not consider the treatment residue to be newly
     generated for LDR purposes. Such a treatment residue, however, cannot be land disposed until it meets
     the treatment standard applicable to the original waste. This situation would normally involve re-treating
     the waste residuals on-site. Any UHCs added or created by the treatment  process are not required to be
     treated  because there is no new point of generation for LDR purposes. However, if the treatment residuals
     are themselves characteristic due to a new property (e.g., a formerly characteristic chromium D007 waste
     is now characteristic only for D008 lead), then the treater must make a new determination of the UHCs
     present-either through knowledge or additional testing. This is the same obligation that attaches to any
     generator of a hazardous waste.
  •  For treatment residuals that appear only at intermediate steps of a treatment train, there is no obligation
     to determine UHCs or to determine whether the residual is itself characteristic.  Intermediate-step
     treatment residuals are not newly generated hazardous wastes for LDR purposes. Thus, even when an
     intermediate treatment residual is sent off-site for further treatment (such as incinerator ash going off-site
     for stabilization and landfilling), §268.7(b)(5) requires only that the UHCs identified at the LDR point of
     generation be identified. There is no such requirement for any new UHCs that may be added or created
     during the preceding  steps of the treatment process.
  See Federal Register 64:90 (11 May 1999) p. 25411 for additional clarification.
LDRs: Generator WAP Requirement

If you are  a generator managing and treating prohibited waste or contaminated  soil in
tanks, containers, or containment buildings regulated under §262.34 to meet applicable
LDR treatment standards, you must prepare and follow a WAP [§268.7(a}(5]]. The WAP
must  describe  all  the  procedures  you  will  carry  out  to comply with the  treatment
standards.   (Generators  treating  hazardous  debris  under  the  alternative  treatment
standards  of  Table  1,  §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
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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.9

   Wastes shipped off-site must comply with the notification requirements of §268.7(a)(3).

1.1.2    TSDF Waste Analysis Requirements

As a TSDF, you must comply with the applicable §§264/265.13 requirements for waste
analysis  and WAPs. Part 264 covers the requirements  for  permitted  facilities/units,
whereas Part 265 covers interim status facilities/units. Figure 1-3 provides an overview of
these  analytical requirements. The figure  identifies  the  requirement for  a WAP  at
§§264/265.13,  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}.10

A TSDF receiving waste from off-site 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 the wastes to ensure compliance with its permit/regulations
and manage the wastes in a protective manner. If the TSDF relies on generator-supplied
information, it is important  for the TSDF 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

Sections 264/265.13(a] establish two broad analytical responsibilities that you as a TSDF
must perform at a minimum:

   Pre-acceptance.11 Before  you can treat, store, or dispose of candidate hazardous
   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  Part 264 or 265 and  the LDR program. The analysis may include  information
   developed under  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 §268.7(b) and (c}. If the generator does not supply the information or
9 The WAP must also contain procedures for re-treating the waste if it is determined that the waste, after testing,
does not meet the applicable UTS.  It is also important to note that these procedures must be in compliance with
all Part 268 requirements including, for example, the LDR storage prohibition.
10 The figure does not address all analytical requirements that may potentially apply to a TSDF.
11 Other terms may be used such as "pre-qualification."
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   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.
   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 §§264/265.113(d), has changed; and
   —  For off-site facilities, when the inspection 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

Sections 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 §§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 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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                      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 facilities'1
                        For hazardous waste landfills:
                        • tests to demonstrate absence or presence of free liquids in bulk or containerized liquids;c
                        • tests to determine if sorbent used to treat 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 CCf (264.1083 and 265.1084)b
                       For treaters and disposers under LDR program, tests to assure that treated waste meets
                       applicable treatment standards (268.7) and that other applicable LDR requirements are met
      Permitted TSDFs only

          	>
                      Document compliance with applicable requirements to take precautions for ignitable, reactive
                      or incompatible waste activities(264.17)
        Interim-Status TSDFs/Units Only

                        For tank, surface impoundment, waste pile, thermal treatment, or chemical, physical or
                        biological treatment that is used for a 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 > 10ppmw are 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   For permitted  TSDFs, where applicable: the methods that will be used to meet the
   additional  waste analysis requirements for specific waste management methods  as
   specified in §§264.17,  264.314,  264.341,  264.1034(d],  264.1063(d], 264.1083, and
   268.7. (See Figure 1-3.}

   For interim status TSDFs, where applicable: the methods that will be used to meet the
   additional  waste analysis requirements for specific waste management methods  as
   specified in §§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 the  land  disposal  restrictions  under
   §268.4(a], the procedures and schedules described in §§264/265.13(b}(7}.

   For owners and operators  seeking an exemption to the air  emission standards  of
   Subpart CC in accordance with §§264.1082 or 265.1083, the information specified in
   §§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; and
   —  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 sorbent to the waste container. Sorbents used must be non-
   biodegradable (§§ 264/265.314}.
1.1.3    Transmitting Waste Analysis Information

In addition to conducting waste analyses, generators and
owner/operators  of TSDFs that  ship waste  off-site are
required to transmit  waste-related information to the
destination facility 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"   [§268.7(a]]  and
"Treatment Facility  Paperwork  Requirements  Table"
[§268.7(b]]. For example, if you are:

   A generator or TSDF that ships waste to an off-site
   (i.e., "designated"} TSDF, you normally will be asked to
   provide  waste profile  data  (e.g.,  analytical  data,
  Adding Waste Codes to an LDR
     Notification (§268.7(a))

         An Example
A wastestream, K062, is listed due to
corrosivity, hexavalent chromium and
lead. The LDR treatment standard for
K062 only includes treatment for
metals. If the K062 wastestream is
actually corrosive (D002), 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 also.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   description of the waste generating process] to the designated facility prior to the initial
   shipment. As discussed earlier, the designated TSDF will review the data as part of its pre-
   acceptance process  to ensure,  among other  things, that the waste can  be accepted
   according to its permit [§§264/265.13(a]].  If the designated TSDF gives you approval to
   ship, you must transmit the hazardous waste  manifest (EPA forms 8700-22 and 22A]
   describing the shipment (e.g., RCRA waste codes,  DOT shipping description] [Part 262,
   Subpart B] as well as LDR paperwork (e.g., notice laying out RCRA waste codes, etc.] and
   available waste analysis data, as specified [§268.7(a] or (b]].
   An owner/operator of a treatment facility,  you
   must comply  with  LDR  paperwork  transmittal
   requirements  specific to treaters as  applicable
   [§268.7(b](3]-(6]].  This  includes transmitting a
   notice and certification to the designated facility, as
   specified. It also  is important to provide  waste
   analysis information when  available  (including
   any information  supplied by the generator, as
   well  as  waste analysis data  developed by your
   facility before and after treatment] to ensure that
   the waste is  managed in compliance with  LDR
   requirements and the permit.
                 Information-Sharing under Manifest
                        and LDR Programs

                 Manifest Program

                 •  For generators, refer to Subpart B
                   of 40 CFR Part 262.
                 •  For designated TSDFs, refer to
                   Subpart E of 40 CFR Part 264 or 265.

                 LDR Program

                 •  For generators, treaters, and
                   disposers, refer to 40 CFR 268.7.
In addition to generators and TSDFs, hazardous waste transporters and 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 protective
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 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 important to them and to the
many  individuals (e.g.,  subsequent
transporters,  emergency  response
       FIGURE 1-4: Waste Analysis Data Flow
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  hazardous
waste.  It  is  advantageous  for  all
facilities involved to provide detailed
waste analysis information with each
shipment of a  wastestream, and for
the receiving facility to verify, through
                     Transfer Facility

Generator
Treatment Facility
  Cf
                     Storage Facility
                                            v
                                                                        Disposal Facility
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


waste analysis, the information that the generator or sender of the waste provided. Doing this
should increase the likelihood that the waste will be treated, stored, or disposed of properly,
and  reduce the  chance  of  accidents, releases,  and mismanagement (e.g.,  mixing of
incompatibles}.


1.2       How Can You Meet The Waste Analysis Requirements For
          Your Facility?

You  can  meet the general  and  specific waste  analysis  requirements  using several
approaches  or  combinations of  methods.  Meeting waste analysis  requirements  by
performing  waste sampling  and  laboratory  testing typically is more  accurate  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.

Waste analysis information can be acquired by either collecting samples and conducting
laboratory testing or using published data and generator knowledge of the waste and the
process that generated it  (known  as acceptable  knowledge, generator  knowledge or
process knowledge}. Acceptable knowledge can include, but is not limited to:12

   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}.

   Incidents of human injury or environmental damage attributed to the waste.

   Data on waste composition or  properties from analysis  or relevant testing performed
   by the generator.

   Information on the properties of waste constituents or, in cases of newly listed wastes,
   data from recent waste analyses performed prior to the effective date of the listings.

Section 1.2.2 addresses acceptable knowledge.

Generators may use any of the above or other information demonstrated to be relevant in
making hazardous waste  determinations.  TSDFs may   have  process-related permit
requirements that exceed generator determination requirements. The regulations establish
more robust waste analysis requirements for TSDFs. At all times, the owner/operator 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
12 For additional discussion of acceptable knowledge, see Federal Register 58:176 (14 September 1993) p. 48111,
Federal Register 59:233 (6 December 1994) p. 62916, Federal Register 62:224 (20 November 1997) p. 62081, and
Federal Register 68:202 (20 October 2003) p. 59939.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


knowledge, as discussed above, may be sufficient for documenting compliance in
certain circumstances and is required to be used where the Agency has determined
that no acceptable test method exists (e.g., D003). 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 permit 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 should be
evaluated for each waste in developing an appropriate waste analysis plan. In addition, it is
important for the WAP to address the range of operating conditions, not just when the
facility is operating at normal conditions, but during planned and unplanned events (e.g.,
consider wastes generated during start-up, shut down, etc.}.   Figure 1-5 illustrates the
relationship between waste variability (e.g., the extent to which a waste varies within a
shipment (heterogeneity] or across repeated shipments] and the need for high quality and
frequent waste analysis.

                 FIGURE 1-5: Waste Analysis Quality - Conceptual Model
           ra
           *)-
           o
           I"
           2
           ra
           •c
           ra
                           Frequent
                       Sampling & Analysis
                             Frequent
                            High Quality
                         Sampling & Analysis
Sampling & Analysis
                       Acceptable Knowledge
                            High Quality
                         Sampling & Analysis
                        Level of Accuracy and Precision Needed to Document Compliance

For example, facilities with constituent feedrate limits may need relatively accurate and
precise analytic results  to verify that 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]. In addition, variable wastestreams or
wastestreams  close  to  a  numerical limit  may  require frequent analysis to  document
compliance, whereas wastestreams shown to be consistent over time may only require
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


periodic evaluation and/or testing.  Generators are responsible for the accuracy of their
waste determinations.

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 hazardous 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.

    The TSDF has reason to believe that the wastes shipped were not accurately identified
    by the generator.

    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 receiving waste from off-site may need to confirm various characteristics of a waste
at the time of pre-acceptance (profiling] to avoid accepting a generator's waste that it is 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 generator normally submits analytical data 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 2-10 of this
                        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 wastestreams that are similar in physical and chemical properties.
    Generic profiles may not be acceptable in a number of situations, e.g., if the TSDF's treatment/disposal
    processes must meet numerical limits.
    Sampling of 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  recertification to ensure that
    profiles are up to date.
    Carefully examining documentation from the generator supporting its waste profile sheet (e.g., see the
    suggested factors in Section 1.2.2 for evaluating acceptable knowledge).
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


manual. Waste profiles and submitted data are normally used by the TSDF, pursuant to
§§264/265.13(a], to (1} determine and document with adequate specificity what waste it
will be managing and (2} assure that it can manage such waste effectively, protectively, and
in accordance with the conditions of its permit and/or governing regulations.

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
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.

Two key objectives of all waste acceptance  sampling and analysis are to 1} ensure that the
parameters being tested (e.g., pH) meet permit requirements  and fall within acceptable
limits for effective treatment  and management and 2} verify that the incoming shipment
matches the manifest and is the same waste that was approved during pre-acceptance.  In
regard to this second objective, if a facility's waste acceptance criteria are too broad (e.g.,
wide pH range], they are an  ineffective screen for verifying that the incoming shipment
matches the originally approved waste.  As  a result, a TSDF might accept a new or changed
wastestream  that falls within the broad criteria for acceptance but that has vastly different
properties than the originally approved waste.

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}
meets  the  acceptance criteria and 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 WAP 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 the 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.

As another example, fingerprint analyses may be done to track metal concentrations in a
highly variable wastestream 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
a representative sample of the waste(s] in question. As a result, it  is important for the
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selection of key parameters to be based on sufficient waste profile knowledge  and data
testing frequency to ensure accurate waste representation on an on-going basis.
                          Considerations for TSDF Acceptance Procedures

    Fingerprinting > 10% of the containers of each wastestream shipped from each generator.
    Using a tiered approach for analyzing incoming shipments, whereby all shipments are
    inspected/fingerprinted and non-conformances between shipment and waste profile sheet (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 protective to
    do so (e.g., open the containers and verify their contents and packing materials) and reviewing their
    inventories (e.g., identify compatibility/potential incompatibility of materials).
    Ensuring that a detailed analysis for the regulated hazardous constituents 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).
    Using 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.
Other Information Needed for TSDF On-site Management

In addition to the analytical results from pre-acceptance and acceptance, other analytical
information may be needed to document a TSDF's compliance with permit conditions.  An
example is verifying whether LDR treatment standards have been met as a result of on-site
waste treatment. Note that sampling and analysis may be particularly important to verify
the achievement of numerical limits (e.g., feed rates  for combustors, organic constituent
levels for wastes subject to the organic air emission standards in Subparts AA through CC
of Parts 264 and 265}.

1.2.2    Acceptable Knowledge and TSDFs

While   waste  generators  are  responsible  for   making  accurate  hazardous   waste
determinations under §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. However, 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 using
the same processes.
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On the other hand, there may be situations where it may be sufficient to apply acceptable
knowledge, such as the following:

   Hazardous constituents in wastes from specific processes are well documented, such as
   with K-listed wastes, presuming that the wastes are not highly variable and accurate and
   precise concentrations are not necessary for documenting compliance.

   Wastes are discarded unused commercial chemical products, reagents or chemicals of
   known physical and chemical constituents,  presuming 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 §261.33.

   The Agency has  determined that  no acceptable  test  method exists  to  satisfy an
   analytical requirement (e.g., hazardous waste determinations under §261.23 for D003
   reactivity}.

   Health and safety risks to personnel  would not justify sampling and analysis (e.g., if
   opening a container exposes technician to radionuclides from radioactive mixed waste}.

   Physical nature of the waste  makes it technically impracticable  to obtain 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 "wipe" samples or, if coated, remove a chip of paint or other
   coating 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  acceptable  knowledge is used, 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}.13
13 The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical
manufacturer, distributor, or importer provide to downstream users Safety Data Sheets (SDSs) (formerly MSDSs) for
potential 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
(http://www.osha.gov).
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Concerns When Using Acceptable
Knowledge

It  is   important  to   consider
relevant   concerns   when  using
acceptable knowledge for  waste
analysis purposes.  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 whether
there are any differences between
the waste  generation process and
the   process  described  in   the
published  information/data being
utilized and  whether it is current.

Generators and off-site TSDFs  may
use  the factors discussed  in  this
section, among others, as a starting
point  to  make  hazardous  waste
determinations based on acceptable
knowledge.  Periodic re-evaluation
of  these 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   due   to   shifting  industry
practices  and/or  process  inputs.
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 hazardous  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 production or use  of  the  product  and  would not be
identified on the SDS.  SDSs typically list constituents present at a minimum  of 1% by mass
 Suggested Factors for Evaluating Waste Determinations Using
              Acceptable Knowledge (AK)

'  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.)?
'  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?
'  Is the testing capable of illustrating the properties of the
   waste that are related to the hazardous characteristics?
'  Does the generator review its original AK determination
   annually, randomly, and whenever the generating
   process/waste changes or the TSDF finds a
   nonconformance?
'  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.)?
'  Are records kept demonstrating that periodic reviews are
   being conducted (e.g., a log or certification by facility
   personnel that is signed annually)?
'  Are analytical results of published studies based on
   currently acceptable sample/test methods?
'  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?
'  Has the TSDF visited the generator's site to confirm
   determination?
'  Has the TSDF obtained samples of generator's waste to verify
   the accuracy of the generator's determination?
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(10,000 mg/kg).Hazardous constituent concentrations much lower than this routinely
impact hazardous waste management and waste analysis requirements.

The following examples highlight some potential concerns with using acceptable knowledge:

   A paint manufacturer used knowledge to identify the hazardous 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 and
   periodically re-evaluated. 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 equal to or exceeding the regulatory
   level for barium at §261.24. However, the company had failed to obtain and review
   information specific to its manufacturing process for the new paint colors and instead
   relied on manufacturing documentation about its earlier colors, which did not involve
   barium. The company was found to be out of compliance because the level of barium in
   the extracts of the new paint color was analyzed and found to exceed the toxicity
   characteristic threshold  for barium.  This  illustrates  a  potential  concern  that  the
   analytical information underlying a knowledge determination may not be sufficiently
   comparable or applicable to the actual generation processes being analyzed.

   Some of RCRA's requirements mandate the use of specific test methods. For example, if
   a generator tests  his waste for the toxicity characteristic  (TC]  instead  of using
   acceptable  knowledge, he must use the  Toxicity  Characteristic Leaching Procedure
   (TCLP}, as required by §261.24.  This requirement to use the  TCLP has implications for
   persons using acceptable knowledge to make a TC determination. If a generator uses
   knowledge under §261.24, it would be unacceptable for him to conclude that his waste
   does not exhibit the TC based solely on the  results of a leaching procedure that is  not
   the TCLP (e.g., a  proprietary leaching  procedure that  EPA  is unaware of).  This
   illustrates a potential concern that the analytical information underlying a knowledge
   determination may not satisfactorily address the applicable  test requirement. Where
   published studies are used as part of acceptable knowledge, it is important to ensure that
   the information is  based on valid and relevant/applicable analytical techniques. This
   includes testing   for  waste  characteristics  as   well   as hazardous constituent
   concentrations.  The ability  of analytical  equipment to detect low  concentrations of
   contaminants has improved over the years and hazardous constituents that once were
   determined to  be  "non-detectable"  may, in fact,  be detectable  using 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,
mis-identification 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  testing may be
critical for meeting some of the requirements of other regulatory programs  such as effluent
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


discharges  under the Clean Water Act and transportation requirements regulated  by the
Department of Transportation.

It is recommended that you keep abreast of regulatory developments in the RCRA program
(e.g., by reviewing the  Web  sites listed  in Section 1.0  of this manual] to  identify new
requirements or test methods that may affect the classification of your waste  and to  re-
evaluate them as needed using current analytical methods and/or acceptable knowledge,
particularly for rules affecting waste identification/classification.
                  Tips on Using a Safety Data Sheet (formerly Material Safety Data Sheet)
                              to Support Hazardous Waste Determinations

     Some wastes have their own corresponding safety data sheets (SDSs). More often, SDSs are used to support
     hazardous waste classifications by identifying ingredients used in the process generating the waste. In this
     instance, SDSs might not represent waste characteristics but are useful in identifying possible hazardous
     constituents and their properties.
     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; check chemical synonyms and chemical abstract service (CAS) numbers carefully); 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. Note, however, that an SDS statement would not by itself support a RCRA determination;
     information corroborating this conclusion would be needed to make a well-supported determination.
     Review the SDS for any hazard classifications using non-RCRA criteria that may be relevant (e.g., DOT
     Hazmat regulations, NFPA ratings, etc).
     If it does not mention RCRA, find the 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 exhibit a 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 NFPA fire rating (a rating of 0
        indicates not ignitable, whereas a rating of 1 to 4 may 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 appear 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 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, or derived from  other chemicals (e.g., acids with bases) or
        otherwise chemically altered (except as indicators of possible  constituents).
        If the SDS is more than five years old, unless you confirm that  relevant data are still accurate.
        As a substitute for laboratory analysis of constituent concentrations when required.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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, protectiveness, and  data  quality discussed  above for TSDFs when
choosing an approach to waste analysis.
         Tips for Generators Unfamiliar with RCRA's Hazardous 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 §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.
     Speak with a qualified consultant, your transporter or the designated 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.
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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  learned  about your waste  analysis and  waste analysis  plan  (WAP]
responsibilities and reviewed the methods by which you can meet these responsibilities (i.e.,
sampling and laboratory testing, and acceptable knowledge}. In Part Two, you will learn:14

   What may be included in a WAP and how the WAP may be organized (Sections 2.1 and
   2.2}.
   How to use a systematic planning process to define
   the  objectives  of your  sampling  and  analysis
   program (Section 2.3}.

   How to  conduct waste testing, 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 2.4-2.9}.

   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 testing and developing a
WAP, Table 2-1  provides  a  list  of key questions
arranged   by  facility  type,   that  when  analyzed
sequentially, provide  an overview for  your facility to
consider when planning, documenting,  and conducting
waste testing. Answers to the questions posed in Table
2-1 will  be based  on facility-specific  considerations.
  Key Initial Considerations
      for the Facility

It is important for WAPs to be
tailored to the circumstances and
business practices of the facility; 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 repeat information that
exists elsewhere in the permit
(e.g., basic facility description,
process descriptions); however,
brief summaries may sometimes
be appropriate, with a reference to
where a fuller discussion can be
found in the permit.
Prepare procedures for subjecting
wastes to an appropriate level of
testing. 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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Relevant facility-specific factors include:

    The  type  of facility  (e.g.,  generator,
    storer  or disposer]  and  its  operating
    activities (e.g., whether it accepts waste
    from off-site sources  for management
    on-site}.

    The  characteristics  and  quantities of
    wastes generated.

    The  types of  units  that are used to
    manage wastes on-site.

The text box  on the next page, "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 a number 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 and those that are mandatory. Only those that
are mandatory are required to be  included in the WAP.

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.
         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 §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 refer to
Table 2-1 for guidance on developing their WAPs in
accordance with applicable requirements.
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 facility 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 its 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 inviting someone on-staff (Agency or
   contractor personnel) with a chemistry or
   laboratory background to evaluate WAP
   compliance.
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                                       Content & Organization of the WAP

   1    Purpose <-ClRecommer|decl  |

       A.   Identify requirements/permit conditions for preparing and implementing a WAP at your facility.
       B.   Provide a brief outline or overview of the WAP.
  2.   Facility Description (see Section 2.2) 
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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 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, 2.7)
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? (1.1.1,
2.9.4)
Generators That Treat Waste in
Certain Types of Units***
Address all Generator Only
information from items 1- 10 in
column one. In addition,
address the Treatment Facilities
(On-Site Only column)
information from items 11-19 as
applicable.
Treatment Facilities
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 protect
live 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? (1.1.1, 2.9.4)
After Treatment
14. Did the treatment achieve LDR
standards or is additional sampling and
analysis necessary to make this
determination? (1.1.1, 2.2, 2.4, 2.5, 2.6,
2.8, 2.9)
15. What new wastes, waste codes, and
treatability groups were generated?
(1.1.1, 2.2)
16. Arethere any additional applicable
treatment standards with respect to
LDR regulations? (1.1.1, 2.2, 2.9)
17. What additional parameters of the
treated materials (residues) will need to
be monitored and why? (1.1.1, 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?
(2.4, 2.6)
Before Treatment
14. What are the treatment process design limitations
for optimum protective 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? (1.1.1, 2.9)
After Treatment
17. Did the treatment achieve the LDR standards or is
additional sampling and analysis necessary to
make this determination? (1.1.1, 2.2, 2.4, 2.5, 2.8,
2.9)
18. What new waste/waste codes & treatability
groups were generated? (1.1.1, 2.2)
19. Arethere additional applicable treatment
standards with respect to LDR regulations (1.1.1,
2.2, 2.9)
20. What additional parameters of the treated
materials (residues) will need to be monitored?
(1.1.1, 2.4)
21. How will the treated waste be sampled? (2.5)
22. What testing/analytical methods will be used to
analyze the waste? (2.6.2)
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
                                                       Off-Site Only
                                                                          Disposal Facilities
                                                        On-Site Only
                                                      Off-Site Only
  Address all Generator Only information
  from items 1- 10. And also, answerthe
  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, 2.7)
 13.  What additional sampling and analysis
      are required at the storage facility?
      (1.1.2, 2.4, 2.5)
 14.  Will a new waste identification be
      required and how will it be verified?
      (2.7, 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?
      (1.1.1, 2.2, 2.8, 2.9)
  Address all Generator Only information
  from items 1- 10. And also, answerthe
  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 storage process? (2.4, 2.6)

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, 2.7)
 16.  What additional sampling and analysis
      is required at the storage facility?
      (1.1.2, 2.4, 2.5)
 17.  Will new waste identification be
      required and how will it be verified?
      (2.7, 2.8)
 Address all Generator Only information
 from items 1-10. And also, answerthe
 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)
  Address all Generator Only information
  from items 1- 10. And also, answerthe
  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, 2.6)
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? (2.4, 2.6, 2.8, 2.9)
 14.  Have all wastes received on site for
      disposal  met applicable LDR treatment
      standards? (1.1.1, 2.2, 2.9)
 15.  Are additional procedural
      requirements applicable for wastes
      from off-site? (2.9)
 16.  Have applicabletests been conducted
      to ensure nofree liquids will be placed
      into landfills? (2.4)
*This table is intended for illustrative purposes only and should not be used as the sole basis for compliance.  Numbers in parentheses indicate the pertinent section numbers of this manual for
further reference.
** A generator is not required to prepare a WAP unless 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. The information in this column is for generators who do not treat but who opt to prepare a WAP to more effectively evaluate their wastestreams under RCRA's
analytical requirements.
***Treatment in tanks, containers, or containment buildings.
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                                                       40 CFR 264/265.13 do not require WAPs
                                                       to provide a facility description.
                                                       However, this manual recommends that
                                                       a brief facility description (e.g., wastes
                                                       and waste generating processes) be
                                                       addressed in the WAP in order to aid in
                                                       the efficient review of the WAP.
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 may be obtained.

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 waste testing. This
information could include facility diagrams, narrative process descriptions, and other data
relevant to the wastestreams subject to waste testing. 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 if you receive waste from off-site,
you should also  consider including  in  the WAP 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.
PART TWO: Documenting and Conducting Waste Analysis

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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, you should also
consider including in the WAP:

   Rationale for identifying each waste as hazardous.

   Procedures  and  protocols  for  evaluating
   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  handling these wastes and
   generating treatment residues.
                                          Pre-Acceptance of Off-site Wastes

                                     If the facility will receive off-site waste
                                     shipments, it is important for the WAP to
                                     include processes and procedures for pre-
                                     qualifying these wastes before the first
                                     shipment. This includes describing, for
                                     example, the types of information these off-
                                     site sources should provide and the facility's
                                     decision-making criteria.
                                     Refer to Sections 1.2.1 and 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, you could include tables to present
relevant information. For example, Table 2-2 provides one possible format that you
may use to present relevant information about off-site (received) waste.

                          TABLE 2-2: Description of Listed Wastes
    Facility
 Wastestr
     Name
    Process
 Generating this
    Waste
   Rationale for
  Hazardous Waste
    Designation
 FACILITY A
 Semi-
 conductor
 Manufacture
Spent Degreasing
   Solvents
(Trichloroethene)
   Machinery
   Degreasing
  Operations in
    Bldg. 12
   Contains 25%
  trichloroethene,
cutting oils, and other
   non-hazardous
 degreasing solvents
 EPA
Waste
 Code
 F001
NWW
 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
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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
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.

                     TABLE 2-3: Description of Characteristic Waste


Facility . .
Characteristic
Process Rationale for EPA LDR
Generating Hazardous waste waste

FACILITY A
Pharmaceutical
Manufacturer

FACILITY B
Hazardous
Waste
Treatment
Facility
this Waste Designation Code(s) UHL(S)

Toxicity


Toxicity


Analgesic
cream
(see Process
A- 106)

Fuel
Combustion



Benzene >0.5 ppm


Cadmium > 1.0 ppm
in Waste Residues



D018


D006



None


None



^^jjjf^Wjjfl

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 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
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


significant  likelihood of mixing  hazardous constituents  in  the same area [§260.10].
Examples include:

   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 [§260.10].
   Tanks and associated piping and underlying containment systems.
   Surface impoundments.
   Landfills.
   Waste piles.
   Containment buildings.
   Land treatment units.
   Incinerators.
   Boilers and industrial furnaces.
   Miscellaneous units.

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 could
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, any treatment residues, or
   any re-treated wastes 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 [§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
   meeting applicable permit-established performance standards and complying with the
   regulatory provisions of RCRA (e.g., Part 268}. This  information may need to define
   specific physical and chemical operating constraints  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}.
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


2.3   Systematic Planning

The process of waste analysis is one that involves the
collection  and  evaluation   of  data  to  accurately
characterize the waste. To this end, it may be helpful to
define clearly the objectives of the program. One way to
 ,   , .  .        .11        .            i              process described in this section or an
do this is to consider what questions you need to answer     a|temate pmcess of simj|ar rjgor js
                                                       40 CFR 264/265.13 do not specify the
                                                       WAP development process described
                                                       in Section 2.3. However, using the
                                                       recommended to ensure that quality
                                                       data is generated.
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 analytical 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; and

   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 rules, including 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 (1} that your
data will  support  your decisions;  and  (2}  compliance with  permit  and   regulatory
requirements.

Many systematic planning process 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
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
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


State the Problem
JJ,

Identify the Decision
rj.


Identify Inputs to the Decision

4


Define the Study Boundaries

1


Develop a Decision Rule

*


Specify Limits on Decision Error






4 T
Optimize the Design





more information. The following is a brief discussion of     FIGURE 2-1: The Seven Steps
each  of the  seven  steps  in  the  process.  Further         of the DQO Process
discussion  of  implementing  the DQO process in  your
waste  analytical  program  is included  in  Sections 2.4
through 2.8 of this manual.

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 can
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, should
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 non-hazardous. 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}  conduct necessary  testing to determine if reactive,
flammable, corrosive or toxic}. 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 be
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?
PART TWO: Documenting and Conducting Waste Analysis

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 generator acceptable
knowledge. This should include identifying possible sample and analytical 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 of this manual. 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 using the SW-846 TCLP Method 1311.
  •  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 Part 261 Appendix I.
  •  Use of the SW-846 TCLP Method 1311 to produce the extraction.
  •  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 defined by 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, however, 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 of this manual.
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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
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 regulated  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/L TCLP for lead in 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, you could 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 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/L TCLP for
  lead in the non-wastewater, then the waste does not meet the LDR treatment standard and is not eligible for
  land disposal under Part 268. Otherwise, the waste will be considered suitable for landfill disposal for lead
  under 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,
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the consequences would be the increased cost of unnecessarily treating the waste before
disposal. If, however, you consider a waste non-hazardous when it is in fact hazardous, the
consequences may  include potential  future legal or  financial liability problems for  the
owner that are much more consequential and 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
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 appropriate.  Applying a 90%
confidence level  will reduce the chances of the facility being  noncompliant with  the
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 non-wastewater is greater than 0.75 mg/L TCLP for lead 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 Part 268. Otherwise, the waste will be considered suitable for landfill disposal for lead
 under 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 testing understand and properly
implement the sample design.

Further information on systematic planning and the DQO process can be found in the
following sources:

   Guidance of Systematic Planning Using the Data Quality Objectives Process, EPA240-B-
   06-001. U.S. Environmental Protection Agency, Washington, B.C., February 2006.

   RCRA  Waste  Sampling  Draft  Technical  Guidance,  Planning,  Implementation  and
   Assessment, EPA 530-D-02-002. U.S. Environmental Protection Agency, Washington,
   D.C., August 2002.
   —  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
                                            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.
An  accurate  representation  of a  waste's
physical and  chemical properties is critical
in  determining  effective  and  compliant
waste management options. Accordingly, the
facility's    WAP   must   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 for those states that are
   authorized to implement the RCRA hazardous waste program.
   Conformance with permit conditions (i.e., ensure that wastes accepted for management
   fall within the scope  of the facility permit and that process performance standards can
   be met}.
   Effective and appropriate 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 parameter selection 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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2.4.1    Criteria for Parameter Selection

Waste analysis parameters are designed to develop the information necessary for protective
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:

   Waste identification.

   Identification of incompatible/unauthorized wastes.

   Process and design considerations.

Each major category where selection criteria are to be applied is described 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 Part 261, Subparts C and D. In addition, pursuant to the LDR regulations,  they
must determine whether hazardous wastes are  restricted from land disposal according to
Part 268. If the generator determines that his waste is subject to the LDR requirements, he
must comply with the LDR notification and certification requirements at §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  need to include
provisions  to ensure that  applicable  LDR
requirements  are  fulfilled.  Waste analysis
requirements  for   generators  and TSDFs,
including the LDR provisions for underlying
hazardous constituents (UHCs], are presented
in Section 1.1.1 of this manual.

TSDFs are responsible for meeting the LDR
treatment standards prior to  land disposal
for all  regulated  hazardous  constituents
and/or   UHCs    subject   to   the   LDR
requirements, regardless of the constituents
         Characteristic Waste and
  Underlying Hazardous Constituents (UHCs)

Characteristic hazardous waste (per §§261.21-.24)
must comply with the special requirements set
forth in §268.9. This includes addressing UHCs.
When determining the LDR treatment standard for
the characteristic waste, you must consult the
table of standards in §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; and
•  Meets the concentration-based universal
   treatment standard (s) in §268.48 for each
   regulated constituent (i.e., UHC) in the waste.
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identified by the generator.15 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:

   Part 261, Appendices VII and VIII (i.e., the basis for listing hazardous wastes and
   hazardous constituents, respectively}.

   Applicable state hazardous waste regulations.

   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 fingerprint analyses. 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 that 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.

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  be selected to verify that each waste arriving at the gate of the TSDF
matches its profile.
15 As previously noted, Part 268 defines land disposal as the placement in or on the land, except in a corrective
action management unit or staging pile, and includes, but is not limited to, placement in a landfill, surface
impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation,
underground mine or cave, or placement in a concrete vault, or bunker intended for disposal purposes.
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Sampling  frequencies and waste re-evaluation  frequencies  are  discussed  in  detail in
Sections 2.5.1 and 2.8, respectively.

Identification of Incompatible/Unauthorized Wastes

Regulatory requirements and good management practices dictate  that incompatible (e.g.,
acids  and  bases]  or unauthorized  wastes  be identified prior to waste  management
[§§264/265.17]. If combined, incompatible wastes are capable of spontaneous combustion,
toxic gas generation, or explosions. Compatibility testing may include  determining water
reactivity  (e.g., foaming,  heat generating, explosiveness], oxidation-reduction potential,
spot tests for cyanide and sulfide, among others, with the objective to:

   Ensure compatibility of waste with the hazardous waste management unit into which it
   will be placed (e.g., the material that a container is made of).

   Determine compatibility of separate  wastestreams prior to commingling.

   Avoid accumulating incompatible wastes in the same storage location.

   Ensure that tanks/containers that were  used to  store a different wastestream have
   been adequately cleaned.

In addition, 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 [Part 264/265, 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}.
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.,  hazardous constituent
concentrations, pH,  etc.]  that may be protectively  managed  in  a  given  process while
maintaining regulatory and permit compliance. Thus, the facility WAP  should consider
including  such 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,
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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.

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, piped}.

   Source of waste to be managed (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 (e.g.,  container storage  areas,
   tanks}.16

   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.
16 For purposes of the LDR program, treatment of hazardous waste occurs in non-land based units before a
prohibited waste is land disposed. Thus, hazardous wastes are typically treated in units such as incinerators, tanks,
containers, or containment buildings before they are land disposed. Storage units in or on a landfill are defined in
Part 268 as land disposal.  Placement of waste in containers located in or on a landfill is also considered land
disposal. Waste piles are considered land disposal units. Treatment in surface impoundments is not allowed,
except under a treatment surface impoundment exemption (§268.4).
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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 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.

2.4.3    Rationale for Parameter Selection

Along with identifying waste analysis parameters, the RCRA regulations require that the
WAP provide the  rationale for the selection of each parameter [40 CFR 264/265.13(b)(l)].
The rationale must describe  the basis for waste analysis parameters and how each will
measure the physical and chemical waste properties such that wastes are managed within
regulatory  and  permit conditions, as  well  as  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.
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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.ev
     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
1
                               Identification of
                               Incompatible/
                               Unauthorized Wastes

                               Identify appropriate waste
                               analysis parameters to measure
                               ignrtabilty 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 appropnate
                                 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
Waste Identification
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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
 2.4.4   Special Parameter Selection Requirements

Where applicable, WAPs  may also  need to  include procedures  and  parameters for
managing specialized wastes in particular types of hazardous waste  management units as
follows:

   Facilities managing ignitable, reactive, or incompatible wastes.

   Bulk and containerized liquid wastes for landfills.

   TSDF process vents.

   Equipment leaks.

   Air emissions from tanks, surface impoundments and containers.

   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 hazardous  waste management units must be
included, where  applicable, in your WAP [§§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 [§§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 one or more of the eight
properties identified in §261.23. As EPA does not currently have a set of approved methods
for determining reactivity, generators should use acceptable knowledge. 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 for a list of some common potentially
incompatible wastes [Part 264/265, Appendix V]. For compatibility of wastes not listed in
the regulations, the facility may need to test the waste and the unit for compatibility.

For further information on waste compatibility, refer to:

   A Method for Determining the Compatibility of Hazardous Wastes, EPA-600/2-80-076. U.S.
   Environmental Protection Agency, 1980.

   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.
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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
                                                    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
                                              liquids test, elimination of free liquids, etc.).
on   containerized   liquids  are  met  [§§
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 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 non-biodegradable
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 the  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
[§§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.  The facility's WAP
must address sampling and analysis procedures under §§264/265.1034(d], as applicable.

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 acceptable 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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


These requirements  are  established at  §§264/265.1063(d].  The  facility's WAP must
address sampling and analysis procedures under §§264/265.1063(d], as applicable.

Air Emissions from Tanks, Surface Impoundments and Containers

TSDF owners/operators  may determine that their  tanks, surface  impoundments,  and
containers  are exempt from the air  emission standards, as provided at §§264.1082  and
265.1083.  A tank, surface impoundment, or container is exempt, provided that the waste
management unit meets  specified criteria.  This includes, for example, a tank, surface
impoundment, or container for which all hazardous waste entering the unit has an average
volatile organic (VO] concentration at the point of waste origination of less than 500 parts
per million by weight (ppmw]. The average VO concentration shall be determined using
specified procedures. The owner or  operator shall review and update, as  necessary,  this
determination  at least once every 12 months following the date of the initial determination
for the hazardous wastestreams entering the unit.

Sections  264.1083 and 265.1084 establish procedures to  determine the average VO
concentration of a hazardous waste at the point of waste origination, waste determination
procedures for treated hazardous waste,  and  procedures to determine the maximum
organic vapor pressure of a hazardous waste in a tank. They also establish procedures for
determining no detectable organic emissions for the purpose of complying with the air
emission standards.  The  facility's WAP must address sampling and analysis procedures
under §§264.1083 or 265.1084, as applicable.

Hazardous Waste Combustors

Certain types  of hazardous waste  combustors  (incinerators,  cement kilns, lightweight
aggregate kilns, boilers, and hydrochloric acid (HC1] production furnaces] are RCRA TSDFs
that are also subject to 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  all RCRA hazardous  waste
combustion units were regulated according to Parts 264 and 265 (for incinerators] and  Part
266 (for Boilers and Industrial Furnaces]. Thus, the RCRA emission standards/limitations
and related operating requirements resided in the RCRA permit or interim status regulations,
and all waste analysis 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 HC1 production furnaces burning hazardous waste. The CAA HWC NESHAP is codified in
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 Part 63, Subpart EEE. Under this approach, the CAA HWC
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 these types of 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
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 in section
2.9.2 (Procedures for Combustion Facilities], the RCRA WAP would include, for example,
general RCRA waste analysis requirements that ensure protective receipt and management
of wastes17 (inclusive of all non-combustion hazardous waste management activities], as
well as (if needed] waste analysis requirements necessary to ensure compliance with the
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.18  Thus,
the FAP can be thought of as a subset of the facility's RCRA WAP, since the incoming waste
affects what is ultimately combusted.

As alluded to in the previous paragraph, 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, based on
   the results of a site-specific risk assessment, and the WAP may include procedures to
   ensure compliance with them.

   The owner/operator elects to comply with one of the "RCRA Options" in §270.235 for
   minimizing emissions during periods of startup, shutdown, and malfunction.
17 See 40 CFR 264.177, 264.198, and 264.199.
18 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).
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   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 §63.1218(e}}.

It is important to note that there are other types of RCRA thermal treatment units that are
not subject to  the CAA HWC NESHAP under 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, but are rather
regulated pursuant to the applicable RCRA standards for Miscellaneous Units (see Part 264,
Subpart X]19 or BIFs (see §§266.102 and 266.103}. Thus, these facilities are only subject to
the 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.20

Also, some boilers and HC1 production furnaces 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"21 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 standards.
Specifically, area sources that choose not to be subject to the full suite of CAA HWC NESHAP
standards  are  subject to  the CAA HWC  NESHAP standards for mercury, dioxin/furans,
carbon  monoxide/hydrocarbons, and destruction and removal  efficiency, while the RCRA
standards under Part 266, Subpart H for particulate matter, metals other than mercury, and
hydrogen chloride and chlorine apply.  For additional information, see §§266.100(b}(3],
270.22, 270.66, and the final rule preamble  fFederal Register 70:196 f!2 October 20051
pps. 59433-59434}.  As a result, the RCRA WAP would need to cover these pollutants 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.
19 The Subpart X regulations do not include specific performance standards, but instead direct permitting
authorities to look at requirements from other sections in the regulations to develop appropriate permit
conditions for miscellaneous units. Thus, permitting authorities may include operating parameters and emission
limitations from the CAA HWC NESHAP in RCRA permits for thermal treatment units. Regardless of the source of
the standards, the RCRA WAP is applicable for all units regulated under Subpart X.
20 The Draft 1994 Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, although never finalized,
contains information related to combustor constituent feedstreams and the associated sampling and analysis
strategies (e.g., batch, qualification, and statistical) for determining compliance that readers may still find useful.
(EPA530-R-94-019, October 1994).
21 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


In summary, the RCRA WAP is still a required component of a 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 §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, 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, and  characterizing combustion residues to determine whether
   they exhibit any hazardous waste characteristics that could affect LDR requirements}.
2.5      Selecting Sampling Procedures

Sampling  is   the   physical   collection  of   a
representative  portion  of  a  waste  or  waste
treatment  residual.  40  CFR  260.10   defines
"representative sample" as a sample of a  universe
or whole (e.g., waste pile, lagoon,  ground water]
which can be expected  to  exhibit  the average
properties  of the universe  or  whole.   EPA has
clarified  that the term "representative  sample"
refers primarily to the issue  of sampling accuracy,
i.e., the samples exhibit the  average properties of
the whole waste or treatment residual.
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.
To be representative, a sample 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.
Only the methods referenced in Appendix I to Part
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.
     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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.5.1    Sampling Strategies and Sampling Frequencies

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 the applicable regulatory requirements
   (e.g.,  LDR  regulations,  newly  identified  or  listed
   hazardous wastes}.
   Sampling Methods and
        Quantities
Although a single grab sample
is easy and inexpensive to
collect, it may not be adequate
to characterize a wastestream
(e.g., under §262.11). The
sampling methods and
quantities used need to be
representative of the
wastestream being sampled as
required by regulation.
   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}.

   Effective and appropriate 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
selected sampling procedures. A sampling strategy may need to address the following:

   Types of samples needed (e.g., grab or composite samples; authoritative or random}.

   Selection of sampling locations.

   Number of samples.

   Sampling frequency.

   Sample collection and handling techniques.

In addition, the following factors may 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 to be homogenized
   prior to sampling or other  techniques to be used to obtain a representative sample.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   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 should 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 the  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.

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,   regulatory
requirements, 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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
           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 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.

   When 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 sample based on professional judgment.
   The waste handler, however, may want to ensure that waste concentrations are low enough so that it would be
   highly unlikely that any individual sample of the waste would exceed a "do not exceed" 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 portion of the
   wastestream exceeds the regulatory level. This only requires a single measurement above the regulatory level
   to draw such a conclusion, that the waste at least  in part exceeds the "do not exceed" regulatory standard.
   "Proving the positive" usually does not depend on low detection limits or high analyte recoveries. Per Federal
   Register preamble (see Federal Register 55:27 (8 February 1990) p. 4442). 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 focus on "proving the
   negative." While it is never possible to have complete confidence in a determination, the waste handler may
   seek 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, perhaps collected by an enforcement official,
   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 Federal Register 55:27 (8 February 1990) p. 4441). 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 non-hazardous when, in fact, it is hazardous."

   Similar considerations apply  when developing a sampling strategy to assure compliance with applicable Part 268
   requirements prior to placing waste in  a land disposal unit. Therefore, the waste handler may want to establish
   objectives that focus on "proving the negative." This is accomplished by using a systematic planning process,
   designing a WAP based on the objectives, collecting and analyzing the appropriate  number of samples, and using
   the results from the sample analyses for decision-making.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                                                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
hazardous constituents of wastestreams. Rationale for
sample selection should be 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
hazardous 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


             FIGURE 2-3: Illustration of Simple Random, Stratified Random and
                              Systematic Random Sampling
                        8 —
                                           Simple Random Sampling
                       6 —
                                  E
                                    Q
                                                        m
                                                               [3
                                                    Q
                                i      i      i      i      i      i      i
                          024      6     8     10    12    14
                       8  —
                                       Stratified Random Sampling
                       6 -
                       o -
                          0
                                                                     El
                       8 -
ii       i     i      i      i      i
24      6     8     10    12    14

         Systematic Random Sampling
                       6 —
                       4 —
                       2 —
                                24     6     8     10    12    14
                            LEGEND:
                                       Sample Area Boundary
                                       Strata Boundary
                                       Randomly Selected Sample Location
                                       Sample Location Determined
                                       Systematically
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                                 TABLE 2-5: Major Sample Types
  Sample Type      Definition
  GRAB
A sample taken
from a particular
location at a
distinct point in
time.
                        Applicability
                                 Advantages/Disadvantages
Most common type used
for random sampling.
Useful in determining
wastestream variability
(e.g. range of
concentration) when
multiple or frequent
samples are obtained.

Generally, one grab
sample is used for
enforcement compliance
with LDR nonwastewater
treatment standards.
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's hazardous
constituents are desired.
Note: If collecting
samples to determine
compliance with LDR
treatment standards, you
may not be able to collect
composite samples.
Please check the
applicable 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). May not be appropriate in a number
of situations. For example, compositing
samples from multiple containers is not
appropriate for hazardous waste
determination  if each container represents a
completely different point of generation, if
the waste-generating process dramatically
changes between/during accumulations, or if
the containers' wastes are largely unknown.

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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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.

A disadvantage of composite sampling
is   that   "hot   spot"   contaminant
concentrations  can  become  diluted.
This  problem  may be alleviated by
dividing  a do-not-exceed action level
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 lower limit of quantitation
(LLOQ] is less than  or equal to  the
newly adjusted (lower] action level.
EPA  believes  this approach can be
useful  as a   conservative  screening
approach in certain situations. Indeed,
dividing  a do-not-exceed action level
by the number of aliquots will result in
a lower,  more conservative  level.  A
facility  may,  for  example,  initially
decide to take a composite sample for
comparison  to a  conservative  action
level.  If the composite sample exceeds
it,  the facility  may  then decide to
collect and analyze  grab samples for
comparison to the original action level,
which  is  generally preferable.    For
further   information,    refer  to   the
Superfund guidance on  representative
sampling, Volume 4 (see Section 2.3.2
"Composite Sample" in  the Superfund
guidance] and Chapter 9 of SW-846, as
referenced below.
            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
concentration-based treatment standards for non-
wastewaters typically is to be determined using one "grab"
sample 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, a grab sample is 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 [§268.40(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. See 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. See Treatment Standards Based on Single
   Facility Data, Grab Samples Versus Composite Samples,
   and Waste Analysis Plans.
•  Land Disposal Restrictions Phase IV: Second
   Supplemental Proposal on Treatment Standards for
   Metal Wastes and Mineral Processing Wastes, Mineral
   Processing and Bevill Exclusion Issues, and the Use of
   Hazardous  Waste as Fill. Federal Register 62:91 (May
   12,1997) p. 26047. See Demonstrating Compliance by
   Grab or Composite Sampling.
•  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. See
   Development of New Treatment Standards for
   Hazardous Wastes Containing Metals: Measuring
   Compliance by Grab or Composite Sampling.
Another factor to 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 homogenization of the aliquots.
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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 the LDR requirements
as specified (e.g., compliance with UHCs is measured by an analysis of a grab sample unless
otherwise noted in the regulations}. EPA established treatment standards for wastes based
on grab sampling  as  it  reflects maximum process variability,  and  thus  reasonably
characterize the range of treatment system performances.

While EPA established treatment standards and the basis for LDR enforcement on a grab
sampling approach, a  RCRA WAP may  authorize a different mode  of  sampling and
monitoring in the permit. For example, a demonstration of statistical equivalence  between
a composite sampling protocol and one based on grab  sampling  could be provided for
particular wastes. Another example might be to demonstrate why monitoring for a subset
of pollutants would assure compliance of those not monitored.  A RCRA WAP may require
numerous grab samples to predict compliance for wastes that are not homogeneous while
a composite sampling approach, possibly comparing results to a  level of performance more
stringent than the treatment standard, might also be justified with fewer total samples. For
additional information, refer to the preamble in these final rules: Land Disposal Restrictions
for Second Third Scheduled Wastes fFederal Register 54:120 (23  Tune 19891  p. 266061 and
Land Disposal Restrictions for Third Third Scheduled  Wastes  (Federal Register 55:106 (1
Tune 19901 p. 225391

EPA notes, however, that enforcement of the LDR treatment standards is based on grab
samples, not the facility's waste analysis plan (§268.40(b}}.  For more information, refer
to the preamble  in the LDR Second Third  rule.  While  a  facility's WAP may include
sampling protocols that differ from those used to determine the  treatment standard, it
only requires a single grab sample above  the regulatory level for an enforcement official
to determine  noncompliance with the LDR treatment standards. If multiple grab samples
are taken, each sample must meet the treatment standard prior to land disposal without
exception.  If one grab sample fails to meet any applicable treatment standard, the  waste
must be retreated and tested  to ensure compliance with applicable LDR  treatment
standards prior to land disposal.
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                                        Representative Sampling:
                             Strategies for Problematic Wastes and Materials*

  1.  Materials Comprised of Particles of Extremes in Density or Size

  Example: A large pile of smelter slag where particles range in size from dust particles to 1300 Ib casts, making it
  difficult to get a representative sample.

  Possible Approach: Non-random sampling based on the experience and judgment of the person performing the
  sampling may be employed (e.g., collecting particles less than 1/2 inch in diameter). This non-random sample
  could provide a reasonable approximation to a random sample since large particles are expected to have similar
  composition to smaller ones because they resulted from the same process. Furthermore, this non-random sample
  is expected to be "representative" of the pile since the composition of small and large particles are similar. Care
  must betaken to ensure that the purpose of the sampling is considered when conducting nonrandom sampling.
  For the above example, the chemical composition of the waste may be independent of particle size; however,
  properties of the waste such as its leaching potential may still be dependent on particle size.

  2.  High-Volume Wastes

  Example: Mining wastes may occupy hundreds of acres,  making representative sampling of the entire waste
  very difficult.

  Possible Approach: In such cases, replicate composites composed of random grab samples of the readily
  available material (e.g., residues within 12 inches of the surface) may be taken. Conclusions regarding the level
  of hazard of the waste can be drawn by examining the variability of the values obtained on replicate composites.
  The sampling, compositing and data evaluation process is then  repeated until the confidence in the
  representativeness of the mean reaches the desired level (e.g., less than 10% probability that the true mean is
  above an appropriate regulatory threshold).  While each individual sample or even composite may not be
  representative of the residue, the sum total of samples taken will represent the average property of the waste
  even though the entire wastestream was not sampled.

  3.  Numerous, Highly Varied Wastes

  Example: A disposal site is found that contains components of qualitatively different properties (e.g., color,
  composition, physical state) and the question to be answered is whether hazardous waste was disposed of at
  the site.

  Possible Approach: In this case, one is faced with the situation, not of sampling all components at the site, but
  rather of sampling one  or more individual components of the body of waste at the site. Each of the qualitatively
  different components (materials) could be a discrete waste, and the concept of representative sampling would
  refer to sampling of each discrete waste rather than sampling all of the waste at the site as a whole. Therefore,
  when faced with such a situation, the sampler would identify the  components of the waste site to be
  characterized and would obtain data representative of the properties of each component of  interest. The
  decision as to whether  or not the site contains hazardous waste would, therefore, hinge on whether any of the
  individual components  disposed were hazardous, and not on whether the average of all of the components at
  the site exhibit the properties of hazardous waste.

  * These examples are taken from an EPA notice: Hazardous Waste Management System; Testing and Monitoring
  Activities. Federal Register 55:27 (8  February 1990) pps. 4443-4444. Representative Sample Definition.
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Further information on sampling strategies and the optimum applications for each strategy
is included in the following guidance documents, methods, and standards:

   EPA Observational Economy Series, Volume 1: Composite Sampling, EPA  230-R-95-005.
   U.S. Environmental Protection Agency, Washington, B.C., 1995.

   Guidance  for  Obtaining  Representative  Laboratory  Analytical  Subsamples  from
   Particulate Laboratory Samples,  EPA/600/R-03/027. U.S.  Environmental Protection
   Agency, 2003.

   Guidance on Choosing a Sampling Design for Environmental Data Collection for Use in
   Developing a Quality Assurance Project Plan, EPA/240/R-02/005. U.S. Environmental
   Protection Agency, Washington B.C., Becember 2002.

   Hot Spots:  Incremental Sampling  Methodology  (ISM) FAQs, Interstate  Technology &
   Regulatory Council (ITRC}, 2014.

   Incremental Sampling Methodology, Interstate Technology & Regulatory Council (ITRC}
   Web site.

   RCRA   Waste  Management: Planning,  Implementation, and Assessment of Sampling
   Activities, Manual 42. American Society of Testing and Materials, 2000.

   RCRA   Waste Sampling  Draft  Technical  Guidance, Planning, Implementation  and
   Assessment, EPA 530-B-02-002. U.S. Environmental Protection Agency, Washington,
   B.C., August 2002.

   —  Chapter 5: Optimizing the Besign for Obtaining Bata
   —  Chapter 6: Controlling Variability and Bias in  Sampling
   —  Appendix  C:  Strategies for Sampling Heterogeneous Wastes

   Superjund Program Representative Sampling Guidance, Volume 4:  Waste, EPA 540-R-95-
   141. U.S. Environmental Protection Agency, Washington, B.C., 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.
   —  Chapter Nine: Sampling Plan

Sampling Frequencies

The RCRA regulations  state that the waste analysis conducted under §§264/265.13(a}(l}
must  be  repeated as  necessary to ensure  that it is accurate  and  up to  date"
[§§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 [§§264/265.13(a}(3}(i}].
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   For off-site facilities, when the results of the inspection required in §§264/265.13 (a] (4}
   (e.g., fingerprint analysis] indicate that the hazardous waste received at the facility does
   not match  the waste  designated on the accompanying manifest  or shipping paper
   [§§264/265.13(a}(3}(ii}].

In addition, 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.  [§§264/265.13(a}(4}]

Although there are no required time intervals for re-evaluating wastes that were originally
analyzed under §§264/265.13(a}(l}, 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
[§§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 RCRA permit operating conditions. In
particular, 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}.
                                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 non-hazardous.
  •  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 Part 19.
  •  The facility may be financially responsible for the clean-up of the improperly disposed waste, which may
     now be blended with and indistinguishable from other wastes in the unit.
  •  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. (TSDFs must do so in accordance with their permit.}
That is, you may consider conducting a full and accurate initial characterization of each waste
and then slowly reduce the frequency of re-evaluation over time as long as the hazardous
constituents are consistently below the action level (defined in Section 2.3}. For example, if
a site generates a new wastestream during its manufacturing operations, the number
of manufacturing batches to sample should be determined through a sound statistical
basis and with an understanding of the potential for variability in the wastestream.
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
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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
state how you will determine re-evaluation frequencies based on waste data.

2.5.2    Selecting Sample Equipment

Following are four broad criteria  relating to  waste that should 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}.

Specific physical parameters affecting this selection include:

   Physical State
   —   Liquid (free flowing or highly viscous} or
   —   Solid (crushed, powdered, or whole} or environmental media (soil, sediment}.

   Distribution
   —   Homogeneous or
   —   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  have been  identified and evaluated, appropriate sampling  equipment can be
selected. The  equipment most typically used in sampling includes:


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   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
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. Further, it is important to ensure that facility personnel follow the strategy and
use equipment appropriately.  For example, to obtain a representative sample  of a waste
using a coliwasa, the entire contents of the coliwasa must be placed into a single  sample
container. A representative sample would not be  obtained by putting the  contents into
multiple  different  containers, each  being analyzed for a separate parameter. This is
particularly true for multi-layer waste.
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                         FIGURE 2-4: Samplers for Liquid Wastestreams
              Coliwasa
Weighted Bottle
                   II
                  II
                      6.35 cm (2 1,'2'j
                      152 cm (60')
      Stopper
                     J
                      Varighp Clamp
                                           Dipper
                                     Telescoping Aluminum Pole
                                     25 to 4.5 Meters (8 to 15 ft.)
        Beaker
      15010600ml
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                        FIGURE 2-5: Samplers for Solid Wastestreams
                          Thief
Trier
             60- 100cm
                       1 27 - 2 54 cm
                                                        60- 100cm
                                                                   1.27-2.54 cm
                                            Hand Augers
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                                      TABLE 2-6: Applicability of Sampling Equipment to Wastestreams
Waste Location or Container


Free-flowing
liquids and slurries
Sludges
Moist powders
or granules
Dry powders or
granules
Packed Sand or
powders and
granules
Large-grained
solids

H^CT
Coliwasa
Trier
Trier
Thief
Auger
Large
Trier

^^^R
N/A
N/A
Trier
Thief
Auger
Large
Trier

Open Bed Closed Bed Storage Tanks
TRUCK Truck Or Bins
N/A
Trier
Trier
Thief
Auger
Large Trier
Coliwasa
Trier
Trier
Thief
Auger
Large Trier
Weighted
bottle (a)
Trier
Trier
(b)
Thief
Large
Trier

^^H^g ^Wu2
N/A
(b)
Trier
Trier
Thief
Large
Trier
Dipper
(b)
Trier
Thief
(b)
Large
Trier


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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2.5.3    Maintaining and Decontaminating Field Equipment

Some analyses, such as pH tests, can be performed at the facility using field equipment. In
order 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 waste needs to be free of residual materials so
that it would not 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  should be cleaned thoroughly and decontaminated prior to use. Also, all
sampling  equipment  should  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. It is EPA's expectation that all
decontamination and rinse solutions,  especially  in enforcement cases, will be properly
collected, characterized and managed.  If material or debris removed from field equipment
qualifies as RCRA hazardous waste, it must be managed accordingly.

The level of decontamination that is appropriate  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  should 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 should 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,  or
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, should  be taken. Furthermore,  used  containers that have not  been
decontaminated generally should be avoided to reduce the potential of cross-contamination.

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 need preservation. If a sample
is not preserved properly, the  constituents of concern  in the sample may be chemically,
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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, refer to  SW-846, Chapter  2, and  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 testing, 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.  Finally, note that a number of the topics discussed in this
section dealing with sample collection/management (e.g., precision and bias} also apply to
laboratory analysis, which is  discussed later in this manual.

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.
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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 is important for facilities to document any deviations from the WAP and the reasons for
them.

Quality Control

QC procedures, as tools to measure the attainment of QA objectives, lend themselves to be
measured more quantitatively. Control samples are QC samples that are introduced into a
process to monitor the  performance of the system.   Control  samples can  be  used in
different phases of the data collection process beginning with  sampling and continuing
through transportation, storage, and analysis.

The representativeness of a statistical sample  (i.e., a set of samples} can be described in
terms  of precision and bias. Precision is the  degree  of agreement among  repeated
measurements of the same analyte on the same sample or separate samples.  It tells how
consistent and reproducible the methods are by showing how close the measurements are
to each other. It does not mean that the sample results actually reflect the "true" value, but
that the methods are giving consistent results under similar conditions.  Bias, on the other
hand, refers to  the  systematic or persistent distortion of a measured value from its true
value.  Bias can be measured, for example, by whether QC data fall into an acceptable range
as determined by the lab or other reliable source.

The analogy of a target often is used to illustrate the concepts of precision and bias. In Figure
2-6, the center  of each target  (A  through D} represents the true (but  unknown} average
concentration in a batch of waste. The holes in the targets represent measurement results
from samples taken to estimate the true concentration. The precise holes in the targets are
those clustered  together, irrespective of whether they are near the bull's eye (see targets A
and B}. The unbiased holes are those close to the bull's eye, irrespective of whether they are
clustered together (see targets  A and C}. For example, target A indicates high precision and
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                                                FIGURE 2-6: Precision Versus Bias
                                            A) unbiased, precise
  B) biased, precise
low bias in the sampling and analysis
results. Generally, high precision and
minimal bias are required when one
or more chemical constituents in a
solid    waste   are   present    at
concentrations close to the applicable
regulatory  threshold or action level.
On the other hand, target  D depicts
the situation where the sampling and
analytical  process  suffers from both
imprecision and bias.  The bias  will
result in an incorrect estimate of the
true     concentration,     even    if
innumerable samples  are collected
and analyzed to control the impact of
imprecision (i.e., bias will not "cancel
out"  with   increasing  numbers  of
samples}.

For more  information on  precision,
bias, accuracy, and representativeness,
see the RCRA Waste Sampling Draft
Technical     Guidance,    Planning,
Implementation and Assessment (EPA 530-D-02-002].

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 (causing cross-
contamination],  or equipment (that is contaminated] were contributing to the levels of
hazardous 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.
                                            C) unbiased, imprecise
D) biased, imprecise
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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.  An example chain-of-custody record is shown in Figure 2-7 Example Chain-of-
Custody Record.  Chain-of-custody 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 should  specify  the following information 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 sample, including what type  of composite sample;  (4]
names and signatures of any persons involved in transferring samples; and (5] if applicable,
the shipping number, such as an airbill number, for samples shipped to off-site laboratories.
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                                                    FIGURE 2-7: 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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2.5.6    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
should 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, employees should 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, 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 dangerous wastes such as
   radioactive, acute toxicity or pyrophoric waste.

You may want to consult the Occupational 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 (October 1985}. which was developed through the
joint efforts  of OSHA, NIOSH, the U.S. 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, protective operating tool at your facility.


2.6  Selecting a Laboratory and Laboratory Analytical  Methods


2.6.1    Selecting a Laboratory
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  laboratory  has  demonstrated experience  in
performing test  methods for your particular waste
types and is capable of providing documentation of its
proven analytical capabilities, available  instrumentation, and standard operating procedures.
40 CFR 264/265.13 do not require WAPs to
address how laboratories will be selected.
However, this manual recommends that
the rationale for selecting a laboratory be
addressed in the WAP.
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Furthermore, you may want to consider selecting a laboratory able to substantiate its 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 acceptable
                                                         knowledge.
                                                         Learn if your state 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 organizational
structure and  management  policies,  sample
handling and tracking procedures, documentation
procedures,  internal  audits,  and  proficiency
testing.  Table  2-7   Important  QA  Elements
describes each QA element and what to look for
when choosing a lab.

The laboratory will generally also be able to
provide  standard operating procedures (SOPs]
                                                         On-Site Facility Operated Labs

                                                   On-site testing capabilities can be important to
                                                   confirm that 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 chosen laboratory has an
                                                   adequate QA/QC program.
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for any of the test methods that it performs. This includes having SOPs for SW-846 and/or
ASTM  methods.22 These 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 a test method 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 Characteristic Leaching Procedure}.

                            TABLE 2-7: Important QA Elements
 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 avoid mistaking 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 it is attaining its objectives as stated in
the LQM.
 Proficiency testing
The laboratory regularly participates in a proficiency-testing program. Proficiency-
testing programs give a lab 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
it performs.
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 2-8
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.
 '' See the ASTM web site at http://www.astm.org/.
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     QC technique
 Method Blank
                                                  TABLE 2-8: 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
 Sample 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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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 should consider  its ability to achieve the
lower limit of quantitation appropriate for your needs. Lower  limits of quantitation may
need to be compared to regulatory or permitting thresholds to ensure that the laboratory
method(s} provide sufficient sensitivity (i.e., lower limits of quantitation are less than the
regulatory levels}. Laboratories that are  equipped with only limited or outdated analytical
instrumentation may be incapable of meeting analytical requirements of the regulations.

Information Management

It is important for the laboratory to 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 testing 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.
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2.6.2    Selecting Laboratory Analytical Methods

To  sustain regulatory and  permit compliance, the
WAP must specify testing and analytical methods. The
selection of an appropriate methodology is dependent
WAP must specify testing and analytical methods. The    40 CFR 264/265.13(b)(2) require that
           r   J      &        J                     WAPs address test methods which will
                                                     be used to test for selected parameters.
upon the following considerations to provide reliable
data to ensure protective 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 lower limits of quantitation, 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 helps to
ensure the accuracy of data generated from your facility's waste management program.  For
further guidance on choosing the correct procedure, see Chapter 2 of SW-846.

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. If more information is required on the application of a
particular cleanup method, the information can be obtained from SW-846.


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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 2-8 Analytical Methods Selection
Flowchart is presented to facilitate the selection of the most appropriate preparation and
analytical methods to use when performing waste testing. 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., 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 method. 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.
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 lower limits of
quantitation are for the methods and analytes
you want them to analyze.  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 lower limits of
quantitation may need to be well below the RCRA regulatory levels. Low 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
limits of quantitation below the regulatory level may be required to ascertain waste
variability and calculate a confidence level.
   The Lower Limit of Quantitation (LLOQ)

A common measure of laboratory analytical
sensitivity is the lower limit of quantitation.

The lower limit of quantitation is the lowest
concentration at which the laboratory has
demonstrated target analytes can be reliably
measured and reported with a certain degree of
confidence, which must be > the lowest point in
the calibration curve.
See Update V to SW-846 for additional
information, especially Chapter 1. Note that
some laboratories use terms other than LLOQ,
such as reporting limit.
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                                                 FIGURE 2-8: Analytical Methods Selection Flowchart
                                                                             Sample*
                                                                            Analytical
                                                                         Determination

                        Inorganic Analysis (Metals)
                                                                                                           Organic Analysis
  Inductively
Coupled Plasma
 Analysis 6010
      ICP/MS
I      6020    J
   Atomic
 Absorption
Analysis 7000
 Series Flame
  & Furnace
 Aqueous
3510  3520
 |
J
                                                                         [Is Sample    j
                                                                      Cleanup Needed?!
f Solids 3540
^ 3550
1 —
Oils 3580

(
Sludge
3520

](



Solid, Soil,
Sludge & Oil
5035
V y
	 1
         SAMPLE CLEANUP** Alumina Column 3610, Alumina for
       Petroleum 3611, Florisil Column 3620, Silica Gel Column 3630,
      Gel Permeation 3640, Acid Base Partitioning 3650, Sulfur 3660,
                    Sulfuric Acid Permanganate 3665
                                                      GC/MS
                                                   Analysis 8270
                                              GC ANALYSIS Phthalate Esters 8061, Organochlorine Pesticides
                                               8081, Polychlorinated Biphenyls 8082, Polynuclear Aromatic
                                                  Hydrocarbons 8310, Chlorinated Hydrocarbons 8121,
                                             Organophosphorous Pesticides 8141, Chlorinated Herbicides 8151
                                                                       GC ANALYSIS
                                                                     Nonhalogenated
                                                                     Volatile Organics
                                                                      8015, Aromatic
                                                                      & Halogenated
                                                                     Volatile Organics
                                                                     8021,Acrylonitrile
                                                                     8031,Acetonitrile
                                                                           8033
   *Sample refers to the actual waste or a leachateof the waste as required by TCLP (Method 1311). Note: Not all methods are needed for the TCLP, depending on the analytes of interest (e.g., chromium VI,
   PCBs, chlorinated hydrocarbons, etc).
   "Note: Not all cleanups are applicable to all of the GC Analysis methods. Consult the SW-846 manual for guidance on applicable cleanup procedures for each analytical method and sample matrix.
   The above figure is for illustrative purposes only and may not reflect all potentially applicable procedures. Please consult the SW-846 manual and project DQOs to determine the methods of
   preparation, cleanup and analysis. Note: The methods referenced above may contain subsets of analytes; please consult each method for a list of those analytes (e.g., Method 8310, Polynuclear
   Aromatic Hydrocarbons applies to a subset of 16 analytes, including Acenaphthene and Pyrene).
   The methods referenced in the above figure are from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846).  SW-846 methods are updated frequently. Please consult the
   current SW-846 online for any subsequent method updates or changes before selecting testing methods. Chapter 2, in particular, is devoted to choosing the correct procedure.
   http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/index.htm
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                                       Data Reporting

   Owner/operators of TSDFs are required to keep records and results of waste analyses and waste
   determinations performed as specified. The facility may also want to maintain 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 off-site for analysis.
   In addition, for facilities conducting waste testing:
   •  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 sample results and acceptance criteria (e.g., calibration standards,
      blanks, reference samples, etc.).
   •  Instrument maintenance and repair records.
2.7   Quantifying Data Uncertainty

As  part of the  waste  analysis  process, waste handlers
routinely  use  analytical  data  to make decisions  and    40 CFR 264/265.13 do not specify
determine  if the  data are  capable of  supporting those    the method of quantifying data
                                                              uncertainty as described in
                                                              Section 2.7. However, facilities
                                                              are encouraged to use methods
                                                              for quantifying data uncertainty
                                                              that result in an effective basis for
                                                              decision-making.
decisions. For example, suppose you analyze a waste for
organic  halogens to determine  if it is a candidate for a
particular waste  management  method that  you have
tentatively selected. In addition, suppose this method can
be  used  only if the waste  contains an  organic halogen
concentration below 500 ppm. The decision you need to
make is whether to manage the waste using this method 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 use the management method 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
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analytical result is nearing the action level. This will vary by situation and may need to be
determined by considering the consequences of making a wrong decision (e.g., determine a
waste is not hazardous when it is hazardous}.

For example, suppose  that, if  the waste has elevated levels of organic halogens, the
consequences could be extensive and include potential  damage to the  management unit,
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
mean organic halogen concentration is greater than 500 ppm to justify a decision to use the
management method even when the analytical results  are less than 500 ppm. This may be
accomplished by establishing a confidence level for the mean. 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
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 you can say
that you 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 statistical estimates 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:

    Calculating Upper Confidence Limits for Exposure  Point Concentrations at Hazardous
    Waste Sites, OSWER 9285.6-10. U.S. Environmental Protection Agency, December 2002.

    RCRA  Waste Sampling Draft  Technical  Guidance,  Planning,  Implementation   and
   Assessment, EPA 530-D-02-002. U.S. Environmental Protection Agency, Washington,
    D.C., August 2002.
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                       Calculating the 90% Upper Confidence Limit (UCL) On a Mean


  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 lookup 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/Jri)

                         90% UCL = 420 + (1.886 X 9.07/^3) = 430
  The upper bound 90% confidence limit of the analytical results (430 ppm) was below the action limit of 500
  ppm. The data sufficiently demonstrates that the waste is acceptable for the particular management method
  you have chosen.
  Note(s):
  *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. If 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.
  ** Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous Waste Sites, OSWER
    9285.6-10, U.S.  Environmental Protection Agency, December 2002.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
2.8   Determining Re-Evaluation Frequencies

The RCRA regulations  require  that  waste  analysis
performed under 40 CFR 264/265.13(a](l] be repeated
as necessary to ensure that it is accurate and up to date.
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 [§§264/265.13(a](3](i]].

    For  off-site  facilities,  when  the  results  of the
    inspection    required   in    §§264/265.13 (a] (4}
    (fingerprint  analyses]  indicate that the hazardous
    waste received at the facility  does not match the
    waste designated on the accompanying manifest or
    shipping paper [§§264/265.13(a](3](ii]].
 40 CFR 264/265.13 specify waste re-
 evaluation frequencies in certain
 situations. In other situations, waste
 re-evaluation frequencies are left to
 owner/operator judgment. Section
 2.8 recommends an approach for
 determining re-evaluation
 frequencies when owner/operator
 judgment is needed. This may
 include the use of acceptable
 knowledge in certain situations, if
 allowed by the permit. For
 example, if a facility assumes its
 material exceeds applicable LDR
 treatment standards and performs
 treatment, there may be no need to
 test until after treatment. Of
 course, a permitted facility's re-
 evaluation frequency may be
 reduced only in accordance with
 conditions set forth in its permit.
In addition, 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 [§§264/265.13(a}(4}].
Although the above regulations address the frequency
of waste analysis, judgment is left to owner/operators
to determine more exactly what the analytical frequency
will  be in  certain instances.  It is important  for your
WAP to  identify how you will determine re-evaluation
frequencies in cases where  a frequency is not explicitly
prescribed by regulation.  In doing so, keep  in mind
that, in an  enforcement case, regulators may request a
demonstration that the facility is in compliance with
specified requirements, and more frequent testing may
be helpful  in such cases.  For example, regulators may
ask a facility to demonstrate that it is not performing
impermissible dilution under the Land Disposal Restrictions (LDR} program, as provided at
§268.3. An effective demonstration could involve the submission of test data showing the
concentration of regulated hazardous constituents in the untreated waste. Facilities should
keep this in mind when considering a reduction in re-evaluation frequency under the LDR
or other program and whether to test or use knowledge.

If you would like to enhance your ability to make changes to your waste  re-evaluation
frequency over time, you may want to prepare your WAP to enable a tiered approach for
     LDR Dilution Prohibition

The LDR dilution prohibition at
§268.3(a) forbids the dilution of
wastes that do not meet applicable
LDR treatment standards as a
substitute for adequate treatment,
such as the addition of soil or water
to waste, in order to reduce the
concentrations of hazardous
constituents.
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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  with each subsequent
shipment as long as the regulated hazardous constituents are protectively below the
action level and their mean concentrations do not change significantly over time. For
example, if a facility generates a new wastestream 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 it is
important to state in your WAP how you will determine re-evaluation frequencies based on
waste data.

A possible approach for determining re-evaluation frequency is to compare the average of
the previous and current waste testing 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 accurate records so that previous data are 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 do 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. You could then 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 wastes shipped or generated on-site at least monthly.

The examples show how you may want to determine re-evaluation frequencies using historic
data for an off-site shipment of a wastestream. Note that the  examples apply when the goal
is  to  evaluate general  waste  characteristics to  assess changes in  protective handling
requirements or to monitor long-term average  concentration of specific constituents (e.g.,
to demonstrate  that the time-weighted annual  average organic  concentration remains
below  the  10 ppmw regulatory threshold for Subpart AA applicability}.  Because this
method is not affected by data  trends or the probability that short-term limits might be
exceeded, it is rarely applicable to determining sampling frequencies when the resulting
data are used to demonstrate continuous compliance with a feed rate threshold or limit. In
those applications, sampling frequencies should be based on the likelihood that any one
sample would exceed an applicable target.
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                   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 that it may be advisable to consult a statistician if you are uncertain as to the choice of an
  appropriate parameter, limit, etc., or have concerns with data variability.
                              TABLE 2-9: Re-Evaluation Frequencies
                  If the average difference 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
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                  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 that it may be advisable to consult a statistician if you are uncertain as to the choice of an
   appropriate parameter, limit, etc., or have concerns with data variability.
2.9       Special Procedural  Requirements
2.9.1    Procedures for Receiving Wastes Generated Off-Site
An off-site facility's WAP must  specify the waste
analyses that the generator  of  the  waste  will
provide  to  substantiate its waste  determination
[§§264/265.13(b}(5]].  It is  important for the WAP
to describe the procedures to be  taken by the TSDF
during   pre-acceptance   to   determine   if  the
generator's data accurately  and fully represent the
wastes to be managed.  This can  include describing
40 CFR 264/265.13(c) require WAPs to
specify procedures which will be used to
inspect and, if necessary, analyze each
movement of hazardous waste received at
the facility to ensure that it matches the
manifest.  Sections 2.9.1 and 2.9.2 address
some of these procedures, as specified.
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in the WAP what data will be compiled and how the facility will verify it (e.g., are there any
discrepancies between the generator's profile data and lab results performed on a sample
of the waste?}.

It is also important for the  WAP to identify the facility's decision-making criteria for
approving a candidate waste. Examples of decision-making criteria include:

   Management methods available at the facility.

   Conditions or limitations of existing permit and regulations.

   Capability to protectively and effectively manage the waste.

   Facility's technical experience and judgment.

If a candidate waste is approved, the facility is required to inspect and, if necessary, analyze
each incoming shipment (e.g., fingerprint tests] to ensure that it does not accept incorrectly
identified or  unacceptable wastes [§§264/265.13(a](4}].  As discussed in Part One of this
manual, two key objectives are to 1} ensure that the parameters being tested (e.g., pH) meet
permit requirements and fall within acceptable limits  for protective and effective treatment
and management and 2} verify that the incoming shipment matches the manifest and is the
same waste that was approved during pre-acceptance. In this regard, the shipment may need
to be sampled and analyzed to the extent necessary to verify that it matches the manifest and
profile.   Some  off-site facilities accomplish  this by  performing a systematic  process of
screening and analysis that allows for monitoring of key indicator  parameters.  In some
cases, however, more  stringent waste  analysis may be required.  Figure 2-9 Shipment
Screening provides a methodology that can be used to screen waste shipments.

Shipment screening is especially important 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,
during pre-acceptance, it may  be  advantageous for off-site facilities to  obtain from  the
generator detailed information regarding:

   The process that generates the waste.

   The physical and chemical description of the waste, including hazardous waste codes.

   The  analytical procedures and results used to characterize  the waste or  acceptable
   knowledge documentation.

   Certifications and notifications as applicable to LDR wastes.

   Other pertinent information about the waste.

An example of a waste profile sheet is provided in Figure 2-10 at the end of Part Two.
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                              FIGURE 2-9: 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
                                           Recharacterize Waste
                                            (TSDF or Generator)
                                                    I
Evaluate Analytical Data
                              Reject Waste
                               Shipment
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Based  on the facility's screening, it may identify a  discrepancy between  an incoming
shipment and its manifest or waste profile. For example, a waste's profile sheet might
indicate  that it has  a  pH range of 2 to 5, but the screening results might indicate  the
incoming shipment has a pH of 8.  In such a case, it is important for the facility to take
further action to resolve the discrepancy.  This could include possibly a comprehensive
recharacterization of the waste before acceptance and,  if necessary, preparing a new waste
profile (i.e., if the facility determines it is a new or different wastestream}.  Or, it could
include rejecting the waste if the facility determines it  cannot be accepted on-site (e.g., the
waste is restricted from acceptance in the permit}.

Sections   264/265.13(a)(3)(i) and  (if)  identify situations  when  recharacterization is
necessary at  a  minimum  (e.g., when the results of the  inspection indicate  that  the
hazardous waste received at the facility does not match the waste designated on  the
accompanying manifest or  shipping  paper}.  The  procedures  for  reviewing  and
recharacterizing waste must be specified in the WAP [§§264/265.13 (b] (4}].  Facilities are
encouraged to specify any additional criteria that would trigger recharacterization and the
follow-up procedures for resolving problems found.

2.9.2    Procedures for Combustion Facilities

As discussed in Section 2.4.4 of this manual, hazardous waste incinerators,  cement kilns,
lightweight aggregate kilns, boilers,  and hydrochloric  acid production furnaces are RCRA
TSDFs that are also subject to the CAA NESHAP program.  A  RCRA WAP continues to be a
required component of the RCRA permit for these HWCs; however, the combustor-specific
feedstream  analysis requirements that ensure compliance with the 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 CFR Part 63
Subpart  EEE}. There may be limited cases where a RCRA WAP  continues  to  contain
combustor-specific feedstream analysis requirements,23 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 the RCRA permit prohibits (e.g.  metal-bearing wastes
prohibited  from  dilution  per  Appendix   XI  to   Part   268,  radioactive   wastes,
reactive/explosive wastes, etc.] from going to the combustion unit.24 The CAA FAP focuses
on the waste before being fed to the combustor  to ensure that the feedstream is  adequately
23 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.
24 For HWCs that are not subject to the CAA NESHAP, the RCRA WAP serves the same purpose, but also usually requires
additional waste analysis and feedrate monitoring as necessary to ensure compliance with RCRA permit limits.
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characterized and the concentration of feedrate-limited pollutants (e.g., chlorine] in the
feedstream are known.  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 protective
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 a gap,
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 reference the
CAA FAP requirements, and not include details in its RCRA WAP regarding the waste analysis
requirements used to ensure compliance with the RCRA requirements or for the CAA FAP to
simply reference the RCRA WAP requirements and not include details in its CAA FAP about
feedstream analysis requirements 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 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 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.}

With respect to the CAA FAP, the regulatory requirements are at §63.1209(c}.  This section
currently states:

       (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;
       (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;
       (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.
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       (3) Review and approval of analysis plan. You must submit the feedstream analysis plan to the
       Administrator for review and approval, if requested.
       (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/1)); 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]  that are used to comply with
applicable feedrate limits must be outlined in detail in the HWC's CAA FAP and recorded in
the operating record.25 These characterization protocols are site-specific and waste-specific.

Despite  the  fact that the  regulatory requirements  for  sampling and analysis of  the
combustion unit feedstream  are primarily under  the CAA  HWC NESHAP, many of  the
concepts in this manual can 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  §63.1209(c)(2)(vi) is nearly identical to the requirement
under RCRA at §264.13. Therefore, the regulated  community and permit officials may wish
to review the  discussion in  this manual  to  assist in determining  how  often a HWC
feedstream should be sampled and analyzed.26

Determination of feedstream sampling frequency may depend  on considerations such as:
(1} trends in historical waste data; (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 wastestreams based on process  knowledge 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 protectively handled at the treatment facility; and (2} the treatment
25 Again, it may be possible to combine both RCRA WAP and CAA FAP requirements into one document.  However,
the FAP requirements must be recorded in the HWC's operating record.
26 The Draft 1994 Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, although never finalized,
contains information related to combustor constituent feedstreams and the associated sampling and analysis
strategies (e.g., batch, qualification, and statistical) for determining compliance that readers may still find useful.
(EPA530-R-94-019, October 1994).
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facility is complying with  its applicable feedrate and  emission limitations.27  Only in rare
instances, such as those discussed in the next paragraph, would the use of process knowledge
be an acceptable substitute for actual sampling and analyses in the initial characterization of
HWC feedstreams.  However, process knowledge may often be used to reduce the number of
constituents  analyzed  in  subsequent  characterizations  if the   initial characterization
demonstrates that the constituent is not reasonably expected to be present at a level that
could affect compliance with feedrate or emission limitations.

In cases where it  is dangerous, impractical, or unnecessary to use direct sampling and
analysis, characterization (initial and  subsequent] of the feedstream based on process
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 the physical nature of the waste, or
because the  composition of the wastes are known.  Examples of materials for  which
sampling can be impractical (or unnecessary] include lab packs  and lab wastes, "RCRA"
empty  used  containers,  cylinders,  aerosols,  household  hazardous  wastes,   mixed
Pharmaceuticals, and unused commercial products/chemicals.

As discussed  earlier in this manual (Section 2.4 Selecting Waste Analysis Parameters], the
selection of parameters is important in determining what can be protectively managed
while maintaining regulatory and permit  compliance. Specific to HWCs, the selection  of
parameters to be analyzed in the combustor 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].

The sampling  frequency and selection of parameters for analysis discussions are two examples  in
which this  manual  can be  of assistance  to permit  officials  from both the  RCRA  and CAA
programs, as well as the regulated  community, when developing a HWC RCRA WAP and CAA
FAP.  Again,  readers may refer to Appendix D for a crosswalk table illustrating the similarities
between the RCRA WAP and CAA FAP requirements.
27 Process/acceptable knowledge can encompass a variety of sources such as analytical information, product label
information, safety data sheets, and manufacturer information.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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
    *.    4- /in /~m o/- A lire -\n T       4--ui      *-   -f    the methods that will be used to
wastes at 40 CFR 264/265.17. Incompatible  wastes, if
                                                        40 CFR 264/265.13(b)(6) require
                                                        WAPs, where applicable, to specify
                                                        meet the waste analysis
                                                        requirements for ignitable, reactive,
                                                        and incompatible waste at
                                                        §§264/265.17.
brought together, may result in heat generation, toxic 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 if
they exhibit at least one of the eight properties  identified in §261.23. As EPA does  not
currently have a set of approved methods for determining reactivity, generators will need
to use 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.  The  EPA  document,  A Method  for
Determining  the  Compatibility  of Hazardous   Wastes  fEPA-600/2-80-076).  contains
procedures to evaluate qualitatively the compatibility of various categories of wastes.

2.9.4    Procedures for Complying with LDR Requirements

Generators  and  TSDFs  have  special waste analysis
requirements under the LDR program. 40  CFR  268.7
requires generators and TSDFs to conduct waste analysis
.,...,       ,  .     .  .    c    ,     ..,       .     the methods that will be used to
to determine the regulatory status of wastes with respect
                                                        40 CFR 264/265.13(b)(6) require
                                                        WAPs, where applicable, to specify
                                                        meet the waste analysis
                                                        requirements for the LDR program
                                                        at §268.7.
to the treatment  standards in 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  regulated  hazardous  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 either (1}  testing the waste or (2} using  knowledge of the  process  or
materials used to produce the waste (for  generators only}.  It  is important for acceptable
knowledge to be supplemented with analytical data on the regulated hazardous constituents.

For treatment standards expressed as  concentrations in the waste extract [§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 §268.40(a}.} The extract will then  be tested subsequently
for the specific hazardous constituents  associated with the treatment standard. Treatment
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


standards based on total waste concentrations in §268.40 should use an appropriate total
waste analysis procedure for its respective hazardous constituents. Please note that many
wastes have treatment standards expressed as both extract concentrations and total waste
concentrations depending on their form, i.e., wastewater or nonwastewater.

For wastes with treatment standards expressed as specified technologies in §268.42, and
for hazardous debris treated to meet the alternative debris treatment standards in §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.

As previously  discussed, compliance with LDR treatment standards that are defined as
concentration-based  standards is  based  on  a  single  grab  sample for D004-D011
wastewaters  and for all  nonwastewaters (see §268.40(b)).   For  purposes of LDR
compliance, a grab sample is a  one-time sample taken from any part of the treated waste
prior to land disposal.  Using grab sampling to measure compliance with  the treatment
standards ensures conformity with the LDR program goals such that all of the hazardous
waste to be land  disposed is treated to minimize the threats to human health and the
environment. (See the LDR Phase IV Second Supplemental Proposed Rule (Federal Register
62:91 f!2 May 19971 pps. 26041 and 2604711   If a single grab  sample fails to show
compliance with the LDR standard, then the treated waste must be re-treated before it can
be land disposed as  defined in  §268.2.  Retreatment compliance is also based on a single
grab sample. If, for any reason,  multiple grab samples are taken, all samples must meet the
LDR treatment standards to be LDR compliant.

EPA established treatment standards for prohibited wastes based on grab sampling for two
principal reasons. (See the  LDR Second  Third Final Rule (Federal Register 54:120 (23 lune
1989) pps. 26594 and 26605).)  The first is that it is normally easier and more expeditious
for EPA to enforce on the basis of grab samples. Basing compliance on a single grab sample
allows the enforcement personnel to take a grab sample as an explicitly required method
for determining compliance, rather than having to replicate a sampling program designed
by the TSDF that could require the regulatory agency to make multiple trips to the facility.

Second, grab samples as  used for LDR compliance  normally reflect  maximum process
variability and thus reasonably characterize the ranges of treatment system performance.
In choosing the 95th  or  99th  percentile as  the  compliance  value  (i.e., LDR treatment
standard) from a  treatability study data distribution, EPA has ensured a high  statistical
probability that the entire batch of treated waste, irrespective of the concentrations of the
hazardous constituents, will  be at or below the calculated treatment standard  when the
standard is met by a randomly collected sample.  Hence, the treatment standard represents
a level of treatment that is believed to be achievable between 95% and 99% of the time by
a well-designed, well-operated  treatment system.  If the treatment standard is  exceeded,
then clearly some fraction of  the waste is non-compliant.  All current numerical LDR
treatment standards are based on such an analysis of the treatability study data underlying
the compliance value, and since the compliance values are based on a single grab sample
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


per batch or treatment event, grab sampling is the most appropriate sampling method for
determining LDR compliance.

Further,  in 1994, EPA issued the universal treatment standards (UTS] to simplify and
provide consistency in the LDR requirements, establishing a single set of requirements that
applied to  most hazardous wastes.  (See the LDR Phase II Final Rule [Federal Register
59:180 (19 September 1994) p. 47892).)  Prior to this rulemaking,  facilities  managing
hazardous waste were required to meet the LDR treatment standards established for many
different listed and characteristic hazardous waste before the waste was land disposed.  In
some  cases, a constituent regulated under the treatment standard for one waste was also
regulated in  another waste  to a different level.  The Phase  II rule eliminated these
differences and provided a better  assessment of treatability, reduced confusion  and eased
compliance enforcement. Consequently, the establishment of one treatment standard for
each  hazardous constituent  resulted in a significant number of numerical  treatment
standards increasing to a higher standard. This increase from the  original  treatment
standard (pre-UTS) could be seen as further increasing the likelihood that a single grab
sample would meet the specified treatment standard if the unit was well-designed and
well-operated.

By contrast, composite sampling,  which is a combination of samples  collected  at various
locations or times for a given waste, may result in only an average portion of the waste
being treated.   (See the LDR Phase IV Second Supplemental Proposed Rule (Federal
Register  62:91  f!2  May 19971 pps.  26041 and 2604711  If the Agency had intended for
compliance to be based on composite sampling, or some other averaging method, the mean
(or median) value of the underlying treatability data distribution would have been used as
the compliance value. However, a mean or median value would be substantially lower than
a value taken from the 90th or 95th percentile of the data set.

A facility's waste analysis plan will need to provide the basis for the facility's compliance
monitoring. This plan must be adequate to assure compliance with Part 268 and not allow
hazardous waste management practices that are clearly in violation of LDR requirements.28
A facility remains strictly liable for meeting the treatment standards, so that if the facility
disposes of a waste that does not  meet a specified treatment standard, it is in violation of
the LDR  regulations. A waste analysis plan cannot immunize land disposal of prohibited
wastes, although such plans can be written to authorize types of sampling and monitoring
different from those used to develop or verify that land disposal can occur.

As such, a facility may choose to employ alternative sampling protocols. If a waste analysis
designated a different mode of  sampling or monitoring, there would need to be a
demonstration  that the plan (and the specific deviating feature) is  adequate  to assure
compliance with Part 268. EPA has stated, however, that enforcement of the rule is based
28 See, for example, the Land Disposal Restriction (LDR) Requirements Memorandum from Barnes Johnson,
Director, Office of Resource Conservation and Recovery, U.S. Environmental Protection Agency (RCRA Online No.
14843), dated April 11, 2014.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
on the  treatment standard, not the facility's waste  analysis plan, so the enforcement
officials  would  normally take  a single  grab sample and  analyze for all  constituents
regulated by the applicable treatment standards.  See Section 2.5.1 Sampling Strategies and
Sampling Frequencies and Section 2.8 Determining Re-Evaluation Frequencies for relevant
information.


2.10  Discrepancy Policy

Two types of discrepancies can arise during waste acceptance: 1} manifest discrepancies and
2} discrepancies between the incoming waste shipment and its profile.  Therefore, it is
recommended for a facility receiving off-site shipments to state its discrepancy policy and
include detailed procedures in the WAP 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
r  .,..,,.            ,.   .   ,        ,.   .  ,   ..,     issues and noncompliance with permit
facility s discrepancy policy to be coordinated  with       .      t ,
     J        r   j r   j                           requirements for waste acceptance.
its rejection policy discussed in Section 2.11.
40 CFR 264/265.13 do not require WAPs to
include discrepancy policies or procedures.
However, this manual recommends that
such policies and procedures be
established and described in the WAP since
not addressing them could lead to safety
2.10.1   Manifest Discrepancies

40 CFR 264/265.72 define 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.

   Container  residues, which  are residues that  exceed the quantity limits for  "empty"
   containers set forth in §261.7(b}.

The  facility's  policies should be consistent with the requirements  of §§264/265.72, as
applicable. For example, upon  discovering a significant difference in quantity or type, the
facility must 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
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 protective, 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
issue and how it will be prevented in the future.

2.10.2   Discrepancies Between Incoming Waste and Profile
                                                       Some Consideration for the Facility

                                                     It is recommended that the facility
                                                     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 manual (e.g., Section
1.2], it is  recommended that the  facility 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 wastestream.
New wastes, as well as modified wastestreams 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
protectively 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
protective, 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
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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.


2.11  Rejection Policy
                                                    40 CFR 264/265.13 do not require WAPs to
                                                    include rejection policies or procedures.
                                                    However, this manual recommends that
                                                    such policies and procedures be
                                                    established and described in the WAP since
                                                    not having a policy in place may lead to
                                                    potential safety issues.
It is recommended that a facility receiving off-site
shipments to have a rejection policy that is closely
coordinated with  its discrepancy  policy  because
some discrepancies may  lead to rejection. The
policy would ensure that all applicable federal and
state requirements for rejections (e.g., §264.72} are
followed. For example, the policy could 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 would ensure that it is properly
stored in a secure manner. This would 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.


2.12  Recordkeeping
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
protective and effective management of the waste.
Therefore, it  is recommended that the  facility develop a well-organized  system  for
recordkeeping that provides the easiest, most straightforward way for addressing these
objectives.
                                                    40 CFR 264/265.13 do not require WAPs to
                                                    address recordkeeping. However, this
                                                    manual recommends that recordkeeping
                                                    related to waste analyses and evaluations
                                                    be addressed in the WAP because it may
                                                    help to determine compliance with
                                                    regulatory or permit requirements.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


Because of the volume and frequency of waste receipts, it may be advisable for a TSDF
receiving  off-site  shipments  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  database can
maintain information on a range of parameters of relevance to the waste analysis process
(e.g., quantity/types of hazardous  wastes of each  generator}. It may also  be helpful  to
have systems to  track each shipment from  receipt at  the facility through its ultimate
disposition or re-shipment off-site.  Examples of information include:
   Basics  of
   time/date,
   customer}.
shipments
  quantity,
received  (e.g.,
 waste   type,
   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., if it was 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. For example, §264.73 states that a facility operating record must include
records and results of waste analyses and waste determinations performed as specified in
§§264.13, 264.17, 264.314, 264.341, 264.1034, 264.1063,  264.1083, 268.4(a}, and  268.7.
  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.
It is recommended that a facility's recordkeeping
system (including electronic system) 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


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}.  This includes records of analyses that both your on-site facility
personnel and, if applicable, off-site laboratory perform.

Similarly, if you are a generator, it is recommended that you 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
recommends information for  generators  to retain  on  their hazardous waste  and LDR
determinations.
           Some Suggested Recordkeeping for Generator Hazardous Waste Determinations (§262.11)
                               and LDR Determinations (§268.7(a)(l))*


  •   List or inventory of all wastestreams 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 on-site 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.


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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


2.13     Corrective and Preventative Action Measures

It is recommended  that your facility  establish a
                                                   40 CFR 264/265.13 do not require WAPs to
                                                   include corrective and preventative action
                                                   measures. However, this manual
                                                   recommends that such measures be
                                                   established and described in the WAP to
                                                   help prevent undesirable situations due to
                                                   a deficiency in current practices.
waste analysis corrective and preventative action
program, which could be described in the WAP.
Corrective and preventative action, in this context,
is defined as the steps that a facility will take to
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.
Following are  some issues that you may want  to  address in your corrective and
preventative action program:

   How deficiencies will  be identified and reported.

   How a remedy to the  deficiency will be determined.

   What the timeframes/deadlines are 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.

   Whether contractors  (e.g., labs], if used by your facility, have their own corrective and
   preventative action program and whether  it is sufficient to meet the needs  of your
   facility.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


                               FIGURE 2-10: Example Waste Profile Sheet
                                   (Other formats may be acceptable)
Waste Profile #:
                                     EPA Facility ID #:_
I.   GENERATOR INFORMATION
       1.   Generator Name:	
       2.   EPAIDtt:
       3.   Mailing Address:	
       4.   Plant Address:	
       5.   Business Contact:_
       6.   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.)
    WASTESTREAM CHEMICAL COMPOSITION**
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





        15.
           * 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 VIM 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)
Nickel (ppm)
Selenium (ppm)
Silver (ppm)
Thallium (ppm)
Silicon (%)
Sodium (%)
       18.  Does this waste contain PCBs > 50 ppm? No.
                                           Yes
           If yes, give the concentration regardless of amount and attach supporting documentation:,
       19.  Does this waste contain insecticides, pesticides, herbicides, or rodenticides? No	Yes _
           If yes, identify each and the concentrations (ppm):	
           (Include the SDS for each)
       20.  Does this waste contain dioxin?                      No	Yes	
       21.  Does this waste contain free cyanide > 250  ppm?       No	Yes	
       22.  Does this waste contain free sulfide > 250 ppm?        No	Yes	
v. Toxicn
23.
Y
Check Applicable Data
Eye
Inhalation
Dermal
Ingestion
Other
Carcinogen (suspected or known)
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?_
       38.
       39.
(in accordance with Design and Development of Hazardous Waste Reactivity Testing Protocol, EPA-600/2-84-057,1984)
Is this material stable?             No	Yes	 If no, explain:	
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.
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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.  Restricted waste treated to performance standards? No	Yes	Method:	
           B2.  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:	
                                                                           Yes	
                                                                                 Yes
           B3.  Good faith analytical certification for incinerated organics  No	
               Method:	
           C.   Restricted waste subject to a variance? No	Yes	
               Date/Type:	
           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? 1 No 1 Yes
Can this waste be heated to improve flow? 1 No
Is this waste soluble in water? 1 No 1 Yes








Yes

Particle Size: Will the solid portion of this waste pass
through a 1/8-inch screen? 1 No 1 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:
                             Checklist29



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?






29 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

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?
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. Have sampling quality assurance and quality control
procedures been documented?
k. Are proper packing and shipping procedures documented?
I. Have procedures for the maintenance of all sampling
equipment been documented?
m. Have 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?






PART THREE: Checklist

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

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?
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 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?
























PART THREE: Checklist

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

i. Are procedures in place to ensure that wastes meet
applicable LDR treatment standards prior to land disposal?




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)?












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
requirements. 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  (CMFj,  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
PART FOUR: Sample WAPs

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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
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.
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 methodfs]  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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   Quality Control Policy - Section A-10  outlines the quality control policy this site will
   follow to achieve high quality analytical results.
   Data Reporting - Section A-11 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
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   264.13 (a] (1} 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 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:
      Lab packs. 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
                                                        Sampling During Pre-Acceptance

                                                       Analysis of a sample may be
                                                       necessary during pre-acceptance
                                                       (e.g., if the receiving facility has
                                                       treatment or disposal, such as LDR
                                                       numerical limits).
      to a portable container which has been emptied
      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 2 68}.

   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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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
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;
                    0
                                                       going improvements and assist
                                                                    compliance
   The results of inspection or analysis indicate that the
   waste received at the facility does not match the
   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:
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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
                                                         This is not a mandatory WAP
                                                         element under 40 CFR 264.13.
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 supersedes 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
include  container  receipt inspection.  It  also
includes  chemical  screening  according  to the
frequencies   specified  in  this   section.   Any
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.
                                                     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
                                                  and graphics are helpful.  See Tables A-l
                                                  and A-2 for example. Subsequent sections
                                                  of the WAP can go into greater detail.

                                                  Note that this WAP does not summarize
                                                  testing of wastes generated by ACE;
                                                  however, there should be some discussion
                                                  of this.
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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 Facilitya
     1. Indicate
     Parameters
Acceptance
icoming Shipments        4. Process Operations Procedures
                    A. Storage of  B. Stabilization
                       coming     of Incoming
                           nts    Shipments   C. Landfillb
Physical Description
pH Screening
PCB Screening
Suitability for Landfill
Water Mix Screening
Flammability Potential
Screening
Sulfide Screening
Radioactivity
Screening
Ash Screening
Compressive Strength
Conductivity
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
O
O
O
X
X
X
X
X
X
X
X
X
X
X
NAC
NAd
O
O
O
X
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 offsitethat 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
 Pre-Acceptance
On each waste
undergoing pre-
acceptance,
except as
otherwise
specified
                                               TABLE A-2: Summary of Frequency of Analysis
                           Verification of Incoming Shipments
  Mandatory Verificat
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.4.1.2 of this
   WAP for additional
   information.
     ipplement
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
                                                                                            abihzation
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 effectiveness15
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,
and 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
                                                       for confirming the physical
                                                         Visual Inspection of Containers

                                                       This WAP requires visual inspection
                                                       of 100% of shipments received,
                                                       including opening some containers to
                                                       view their contents. This is important
                                                       description of the waste and
                                                       supplementing the chemical
                                                       screening, which is performed on
                                                       only a subset of containers.
document discrepancies or damaged containers before
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.

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 wastestream 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
 "*er 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%
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.
   stratification would appear to create a problem, the materials will not be combined.
                                         If
   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 elsewhere 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
                                                         This is not a mandatory WAP
                                                         element under 40 CFR 264.13.
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:

   Radioactive wastes.

   Military or civilian ordnance.

   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.
                                                         This is not a mandatory WAP
                                                         element under 40 CFR 264.13.
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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 safety 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:
                                                         This is not a mandatory WAP
                                                         element under 40 CFR 264.13.
   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 (described further
   below}; rejected waste; and container residues. Significant differences include:

   —  For bulk wastes, variations > 10% difference in weight.
   —  For containerized waste, variation in piece count.
   —  Variations in type discovered by inspection or waste analysis.

   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 issue(s] results in the
   failure of a shipment, the  chemical screening  frequency  for all  streams  that could
   exhibit a similar issuefs] from the generator are  adjusted to 100 percent until the
   issue(s] 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 streamfs] 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                       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
 ASTM E300a
 ASTM D346a
 ASTM E300a
 ASTM D420a
 ASTM E300a
ASTMD14523
 ASTM E300a
ASTMD22343
 ASTM E300a
 SW-846B or
 ASTM E300a
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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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 ACE Method #
Not applicable
SW-846 9045
ASTM D4980
SW-846 3580
SW-846-8000
SW-846 8082
SW-846 1311
ASTM D4982
ASTM 505
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 method(s] 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
  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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   falls 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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


A-10   Quality Assurance /Quality Control

A-10.1  Introduction
The following Quality Assurance/Quality Control (QA/QC)    Thjs js not a mandatory WAP
                                                        element under 40 CFR 264.13.
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
specified 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  equipment 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.
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 Data 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.
PART FOUR: Sample WAPs
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


Waste tracking, laboratory data  management and process  control interface  are  major
components of waste disposal that are automated by the LDMS.

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 preparing 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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   The frequency at which treated wastes do not meet the LDR treatment standards. The
   report indicates the steps taken by the facility to 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
                                                         This is not a mandatory WAP
                                                         element under 40 CFR 264.13.
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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Example WAP 2: Waste Analysis Plan of
Container Management Incorporated (CMI)
PART FOUR: Sample WAPs

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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  Sample Tracking Documentation	4-46
     9.3  Sampling Personnel	4-46
     9.4  Sample Labels	4-47
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
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

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
PART FOUR: Sample WAPs

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                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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.
PART FOUR: Sam pie WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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
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-generated 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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 2.1 and 2.2, 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
„„„. ,     j        .     j   .    .,    . . ,  TT     j       This is not a mandatory WAP
RCRA hazardous  waste codes in  the states  Hazardous               anr~rr,\r* -,->
                                                        element under 40 CFR 264.13.
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:
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   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
Parameters
% 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)

Incoming Shipments3
Pre-Qualification Level 1
X
X
X
X
X
X
X
X
X
X
X
X
NA
NA
Xc
NA
Level II Level III
NA
NA
NA
X
X
X
X
X
NAb
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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
                             TABLE 2: Frequency of Analysis
                                            Incoming Shipments
Pre-Qualification

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
Level II

If Level 1 analysis
identifies a discrepancy
between the waste and
WIPand 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 loan 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
PART FOUR: Sample WAPs

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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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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
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
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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.

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
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.
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};
PART FOUR: Sample WAPs
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   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;

   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    This is not a mandatory WAP
attempting to resolve discrepancies.                        element under 40 CFR 264'13'
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
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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.


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.
PART FOUR: Sample WAPs

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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.


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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
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:

   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)
CMI-1
CMI-2
CMI-3
CMI-4
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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Parameter Method Rationale for Selection
Ignitability
Reactive Cyanides Screen
(Spot Test)
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-5
CMI-6
CMI-7
CMI-8
CMI-9
CMI-10
CMI-11
CMI-12
CMI-13
CMI-14
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.
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]
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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.

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.

   Pyridine-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
   The procedure for liquid and sludge waste consists of wetting a strip of KI-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

   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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


12.0  Quality Assurance and Quality Control

The following quality assurance/quality control (QA/QC or
«   i-4_ «•» •  r    4.-   r  4-1 •  r  -i-4_ •  i  •        • j  j       This is not a mandatory WAP
 quality ) information for this facility is being provided as               ,nr~rn\rn -,-,
 n    J  J                        J       & r             element under 40 CFR 264.13.
required by 40 CFR  270.30(ej 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
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


employed by the company demonstrate quality control practices that are comparable to
CMI's practices.

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 is 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
                                                        This is not a mandatory WAP
                                                        element under 40 CFR 264.13.
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:
                                                             Issue to Consider

                                                      Note that some states have state-
                                                      specific requirements for reporting.
      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.
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   —  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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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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:
Pump Start Time:
Container #



































Initial:
Pump Stop Time:

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
RCRA  Section 3001 provides  EPA  with  the authority  to develop  criteria for the
identification of hazardous wastes. Under Section 1004(5} 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 (40 CFR 261.3} defines two ways that a
waste may be hazardous. First,  solid wastes are hazardous wastes if EPA lists them as
hazardous wastes; the lists of hazardous wastes are found in Part 261, Subpart D. 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  four  characteristics  of a  hazardous waste.  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}. Definitions
of these hazardous waste characteristics are found in Part 261, Subpart C.  Exclusions to the
regulatory definitions of solid waste and hazardous waste are found in §261.4.

Generators must conduct a hazardous waste  determination according  to the approach
specified  in §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 §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 Part 268, the generator must
determine if the waste exhibits a characteristic  of a hazardous waste, either by testing the
waste or by utilizing acceptable knowledge about the waste or process or materials used to
generate the waste.


Listing Determination

Once the generator  determines that a solid waste is not excluded from regulation as
hazardous, 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,"} and  specific sources (i.e., K-listed wastes}.   F-listed
APPENDIX A: Hazardous Waste Identification

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


wastes include spent solvents, electroplating wastes, and dioxin-bearing wastes. The  K-
listings include 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 includes 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 non-hazardous 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 (i.e., ignitability [I], corrosivity [C], or reactivity [R]}  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
constituent's  toxicity]  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
delistthe waste according to procedures outlined in §260.22.

The hazardous waste listings also apply to solid wastes derived from the treatment, storage,
or disposal of a listed hazardous waste. The "derived-from rule" (§261.3(c)(2)) defines
residual solid wastes derived from the treatment, storage, or disposal of a listed hazardous
waste as a hazardous waste and retain their listing designations unless the hazardous waste
is listed solely based on a particular characteristic and the derived-from wastes no longer
exhibits any of the hazardous waste characteristics. 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-in policy" states that materials containing a listed hazardous waste
must be managed as hazardous wastes until the other material no longer contains the
listed waste.  This  provision mainly applies to mixtures of listed hazardous wastes and
environmental media (e.g., contaminated ground water, contaminated soil}. 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-l: Hazardous Waste Identification
                                                                                                        Not a Hazardous Waste
             Listed
           Hazardous
             Waste
No
                                                                                                         Not a Hazardous Waste
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?
                         \   Yes
                                                   Yes
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?
                                                                          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**
                                                                    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)(i).
   ** Under 268.9(b), a listed hazardous waste exhibiting a characteristic is not identified as characteristically hazardous provided that the treatment standard for
   the listed waste includes a treatment standard for all of the constituents that cause the waste to exhibit the characteristic.  (For such listed waste, there is no
   requirement to treat underlying hazardous constituents (UHCs) under Part 268. See Section 1.1.1 of this manual for additional information on UHCs.)
APPENDIX A: Hazardous Waste Identification

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Characteristics Determination

A solid waste that is not excluded from regulation and does not meet a listing description of
a hazardous waste must be evaluated by  the  generator to determine if  it exhibits a
characteristic of a hazardous waste. A generator must evaluate representative samples of
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 acceptable knowledge of the process or materials used to produce the waste.

The characteristic of ignitability is described in 40 CFR 261.21. A waste is ignitable if it is a
liquid,  other than an aqueous solution containing less than 24 percent alcohol by volume
and has flash point less than 60 °C (140 °F], as determined by a Pensky-Martens Closed Cup
Tester, using the test method specified in ASTM Standard D 93-79 or D 93-80,  or a Setaflash
Closed Cup Tester, using the test method  specified in ASTM Standard D  3278-78.   In
addition, a waste is ignitable if it is not a liquid and is capable, under standard temperature
and  pressure, of causing fire through friction, absorption of moisture or  spontaneous
chemical changes and, when ignited, burns so vigorously and persistently that it creates a
hazard. Further, a waste is ignitable if it is an ignitable compressed gas meeting the criteria
at §261.21(a](3] (e.g., any material or mixture having in the container an absolute pressure
exceeding 40 p.s.i. at 70  °F or, regardless of the pressure  at 70  °F,  having an absolute
pressure exceeding 104 p.s.i. at 130 °F].  Finally, a waste is ignitable if it is an oxidizer
meeting the criteria at  §261.21(a](4].  For purposes of the ignitability  characteristic, an
oxidizer is a substance such as a chlorate, permanganate, inorganic peroxide, or a nitrate,
that yields oxygen readily to stimulate the combustion of organic matter. Wastes that are
ignitable are classified  as EPA Hazardous Code  D001. Examples  of ignitable wastes  are
certain spent solvents (e.g., mineral spirits], off-specification jet fuels, or perchlorates.

The  characteristic of corrosivity is described in §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 test used for this pH determination is  EPA Test Method
9040C in SW-846 (pH Electrometric Measurement]. A waste is also corrosive if it is a liquid
and corrodes steel (SAE 1020] at a rate greater than 6.35 mm (0.250 inch] per year at a test
temperature of 55 °C (130 °F] as determined by Method 1110A  in SW-846 (Corrosivity
Toward Steel].  Corrosive wastes are designated as EPA Hazardous Waste Code D002.
Corrosive wastes include spent sulfuric acid and concentrated waste sodium hydroxide
solutions. Note  that,  under the federal program,  corrosive solids are not included in the
corrosivity definition and so are not hazardous wastes.

A waste exhibits the characteristic of reactivity if itmeets any of the criteria in §261.23:

   It is normally unstable and readily undergoes violent change without detonating.

   It reacts violently with water.

   It forms potentially explosive mixtures with water.
APPENDIX A: Hazardous Waste Identification

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   When  mixed with water, it  generates toxic gases, vapors  or fumes in a  quantity
   sufficient to present a danger to human health or the environment.

   It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between
   2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present
   a danger to human health or the environment.

   It is capable of detonation or explosive reaction if it is subjected to a strong initiating
   source or if heated under confinement.

   It is readily capable of detonation or explosive decomposition or reaction at standard
   temperature and pressure.

   It is a forbidden explosive as  defined in 49 CFR 173.54, or is  a  Division 1.1, 1.2 or 1.3
   explosive as defined in 49 CFR 173.50 and 173.53.

Wastes that exhibit the characteristic of reactivity are classified as EPA Hazardous Wastes
CodeDOOS.

The toxicity characteristic (TC) is described at §261.24. To test the waste, generators
must obtain an extract of the waste using Test Method 1311 (the  Toxicity Characteristic
Leaching Procedure TCLP}. The extract is subsequently analyzed using the appropriate test
methods to determine the level of TC constituents.  The results are compared to regulatory
thresholds for the TC constituents at §261.24.  Determinative methods in this step may
include, but are not limited to, 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.

   EPA Test Methods 5030 and 8260 - for volatile organics.

   EPA Methods 3510 and 8270 - semivolatile organics.

   EPA Test Method 8151 - herbicides.

Note: Additional options for sample preparation and analysis can be found in the most
recent version of SW-846 Chapter Two.

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.
APPENDIX A: Hazardous Waste Identification

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


Certain states may also have additional requirements for identifying hazardous wastes,
which  apply only to wastes generated and/or managed within the state. States authorized
to implement the RCRA hazardous waste  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 rules.

   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 Parts 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 Rules

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 rule (Federal Register 73:211 (30 October 2008) p.
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. 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 contained 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  considered:  (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 December 10, 2014, the EPA Administrator signed the revisions to the definition of
solid waste rule. The rule (80 FR 1694; January 13, 2015} modifies the 2008 rule to protect
human  health and the environment from the mismanagement of hazardous secondary
material, while promoting sustainability through the encouragement of protective and
environmentally responsible recycling of such materials. It includes several provisions that
result in both resource conservation and economic benefits by encouraging certain types of
in-process recycling and remanufacturing:

   The  rule addresses significant regulatory gaps in the 2008  rule by requiring off-site
   recycling at a facility with a RCRA permit or verified recycler variance, which will allow
   EPA and the states to verify that a facility has the equipment and trained personnel to
   protectively manage the material, adequate financial assurance, is prepared to respond
   in case of an emergency, and can demonstrate that the recycling is not disposal in the
   guise of  recycling.  The  new  verified  recycler  exclusion  also includes  a  public
   participation requirement  for recyclers seeking variances, so that communities are
   notified prior to the start of recycling operations.

   The  rule affirms the legitimacy of the pre-2008 DSW exclusions, such as the scrap metal
   exclusion, and does not change the regulatory status of material  legitimately recycled
   under these long-standing exclusions.

   The  rule  includes a  revised definition  of legitimate  recycling that  re-affirms  the
   legitimacy of in-process recycling and of commodity-grade recycled products, such as
   metal commodities. The rule retains the exclusion for recycling under the control of the
   generator, including  recycling on-site, within the same company and through certain
   types of toll manufacturing agreements, which recognizes those generators who follow
   good business practices by taking responsibility for their recycling and maintaining
   control of their hazardous secondary materials.

   Finally, the rule includes a targeted remanufacturing exclusion for certain higher-value
   hazardous spent solvents, which are being remanufactured into  commercial-grade
   products. This allows manufacturers to reduce the use  of virgin solvents, resulting in
   both economic and environmental benefits, including energy conservation and reduced
   greenhouse gas emissions.
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 [Federal Register 73:231 fl December 2008) p. 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, tailored 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 more protective laboratory practices and increased awareness of hazardous
waste management. Eligible academic entities may  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 12, 1997, EPA published  regulations that clarify  when conventional and
chemical military  munitions become a hazardous waste under  RCRA [Federal Register
62:29 [12 February 1997) p. 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.

The  rule conditionally exempts  from the RCRA manifest   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. The rule also conditionally exempts from the 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 unused munitions
are 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
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 under RCRA for the hazardous waste component and  under 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
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 published a rule (Federal Register 66:95 (16 May 2001) p. 27218)
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 the 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.
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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, while the Subpart CC organic emission control standards became
effective on November 25,1996 fFederal Register 61:228 f25 November 19961 p. 599311

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 §§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. 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 §§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 §§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
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   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 for  as long  as the waste remains
hazardous. 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 protective 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 the 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 using acceptable knowledge,  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 §268.7(a](5], the plan should be written in
accordance with the procedures prescribed in this manual (i.e., describe the 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 the LDR treatment standards.

Treatment/storage facilities are responsible for including in their WAP (§§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 standard(s]. These facilities will receive the generators' certification and any
available waste  analysis data  provided  by the generator (§§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  the  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.
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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 published the Phase II Rule on September 19,  1994 fFederal Register 59:180 f!9
   September 1994) p. 47982). This rule consolidated the existing treatment standards
   into §268.40, created  the  Universal Treatment Standards (UTS],  and  established
   treatment  standards for  toxicity characteristic organic wastes,  and the coke  by-
   products and chlorotoluenes listed wastes.

   EPA published the Phase  III Rule and subsequent partial rescission  on April 8, 1996
   fFederal  Register 61:68 f8 April  19961 p.  15566 and Federal Register 61:68 f8 April
   1996) p. 15660). These rules modified treatment standards for reactive wastes and
   decharacterized  wastewaters,  and  established new treatment  standards  for  the
   carbamate  and  spent aluminum  potliner  listed  wastes. Even  though  Phase  III
   established treatment standards  for these newly identified carbamate wastes, in the
   case, Dithiocarmbamate Task Force v. EPA, the B.C. Circuit Court  of Appeals vacated
   several carbamate hazardous waste listings, thus nullifying their corresponding LDR
   treatment standards. EPA thus amended its regulations to conform with the ruling
   fFederal Register 62:116 f 17 Tune 19971 p. 329731

   EPA published the first half of the Phase IV Rule on May 12,1997 fFederal Register 62:91
   [12 May 1997) p. 25997).  This  rule established treatment standards for the wood
   preserving listed wastes  and  streamlined the  LDR notification  requirements.  EPA
   promulgated part two of the Phase IV Rule on May 26,1998 [Federal Register 63:100 [26
   May 1998) p. 28555). This  rule established treatment standards for several metal-
   containing listed wastes and certain newly identified mineral processing listed 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.

Further discussion of LDRs is available in:

   Land  Disposal   Restrictions:  Summary  of  Requirements,  EPA530-R-01-007.  U.S.
   Environmental Protection Agency, Revised 2001.

   Introduction to Land Disposal Restrictions  (40 CFR Part 268), EPA530-K-05-013. U.S.
   Environmental Protection Agency, September 2005.


Test Methods for Evaluating Solid Waste (SW-846) and The Methods
Innovation  Rule (MIR)

The EPA publication SW-846, Test Methods for Evaluating Solid Waste, Physical/ Chemical
Methods, is the official compendium of analytical and  sampling methods that have been
APPENDIX B: Regulatory Summary

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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. Additionally, SW-846 is periodically updated to incorporate
advances in analytical instrumentation and techniques, to support changes in the regulatory
program, and to improve method performance and cost effectiveness.

While SW-846  was originally  intended  to  serve  as  a guidance manual of generally
appropriate and reliable analytical methods,  some of the regulations required the use of
SW-846 methods.  Therefore, all of the publication had to be incorporated by reference
in 40 CFR 260.11(a). To address this, EPA proposed to remove certain required uses of
SW-846 methods, and to allow more flexibility in test method selection. This amendment
has come to be known as, "The Methods Innovation Rule" (MIR],  which includes  the
following revisions (see MIR Web page):

   Certain  SW-846 testing regulations will allow the use of other practical test methods. In
   other instances, some required uses of SW-846 methods, referred to as method-defined
   parameters,  remain in the regulations because they involve determinations (e.g., TCLP),
   which can only be made by the method specified.   See §260.11 for a complete list of
   required test methods in RCRA.

   Removes requirements to use Chapter Nine, "Sampling Plan," of SW-846 in certain
   circumstances.

   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.
   -  Threshold levels from conditional delistings.

For additional information, including the latest method updates, guidance and  Federal
Register notices, visit the SW-846 homepage.
APPENDIX B: Regulatory Summary

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                          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 2014.  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
Regulation
r Permitted Interim status
Generator TSDFa TSDFa
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
262.11
Subpart J of Part
262
Subpart K of
Part 262







TSDFs (Pa rts 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 VIII 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 qua ntity 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

1.     Remediation Waste Identification

Many 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 the 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 hazardous wastes, derived
from a listed waste or identified as characteristically hazardous waste. Environmental
media  are likewise subject to RCRA Subtitle C only if they contain listed hazardous
waste,  are derived from a listed waste or are identified as characteristically hazardous
waste.  These distinctions are discussed more completely in the guidance document,
Management of Remediation Waste under RCRA ^530^-98-026.19981

2.     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.

      A.    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.

      B.    When Is Wastewater Treatment Sludge NOT a Hazardous Waste?

The treatment of wastewaters is generally 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 wastewaters 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 wastewaters  are not  subject  to  a
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


hazardous waste 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. However, sludges generated from a POTW are solid  and may be
hazardous wastes.  Note that the CWA may prohibit discharges of certain chemicals and
wastes into a sewer system.

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 also presumes that the
mixture actually arrives at the POTW. In addition, the exemption is lost for any mixture in
the municipal sewer system that leaks from the system prior to arrival at the POTW.

       C.    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.

       D.    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
physical and chemical nature, you might have a number of management options.  You
might have to dispose of it as hazardous waste at a  permitted hazardous waste landfill or
incinerator. You might be able to  manage it under  different 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}.
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
      E.     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}

The Agency has never defined "wastewater"  in the Subtitle C regulations, except for the
wastewater definition in Part 268 for the Land Disposal Restrictions (LDR} Program (the
definition in Part 268 applies only to the LDR program}. Typically, EPA has used a very
broad interpretation of "wastewater" in other regulatory programs (e.g.,  the Effluent
Guidelines Division's Development Document for  Electroplating Pretreatment Standards
defines wastewater as "any water that has been released from the purpose for which it was
intended to be used"}. (See RCRA Online No. 11551.J
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—Parts 264 and 265, Subpart I

Containers are portable devices used to treat, store, transport, 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 used. Before
selecting a container for storage or treatment of the waste, you should identify its physical
and chemical characteristics to ensure that it is compatible with the waste. 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— Parts 264/265, Subpart J

Tanks are stationary devices constructed primarily of non-earthen materials  designed to
contain an accumulation of hazardous wastefs}. 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—Parts 264/265, Subpart K

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  for
treatment (as provided by 268.4 for managing prohibited waste], or for storage or disposal
as long as the wastes already meet the LDR treatment standards.

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
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


materials, including polyethylene, polypropylene, and polyester. Surface impoundments
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—Parts 264/265, Subpart N

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— Parts 264/265, Subpart DD

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}. However,
containment buildings can be used to manage hazardous wastes containing free liquids,
but 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.  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.  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— Parts 264/265, Subpart L

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 Part 268, Subpart D.


Land Treatment Units—Parts 264/265, Subpart M

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 §268.6.


Miscellaneous Units—Part 264, Subpart X

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 146,
containment building, corrective action management unit, unit  eligible for a research,
development,  and demonstration permit under  §270.65, or staging pile.  Permits for
miscellaneous  units are to  contain such terms  and  provisions as necessary  to protect
human health  and the environment, including, but not limited to, as appropriate, design
and operating requirements, detection and monitoring requirements, and requirements for
responses to releases of hazardous waste or hazardous constituents from the unit. Permit
terms  and  provisions must include those requirements  of Subparts I  through 0  and
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


Subparts AA through CC of Part 264, Part 270, Part 63 Subpart EEE, and Part 146 that are
appropriate for the miscellaneous unit being permitted.


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 Subtitle  C 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 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 Part 63, Subpart EEE.

In order to avoid  (to the extent practicable} having duplicative emission standards and
operating requirements in the RCRA permit and the CAA notification  of compliance and
Title V permit, EPA established 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  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 §63.1209(c} to similar requirements for RCRA WAPs  and  waste analyses at
§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 eachfeedstream 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 non-hazardous 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
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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

                             Appendix E:
                    Glossary of  Key Terms
Captive TSDF: A TSDF that receives hazardous wastes only from generators within its
own corporation. Such generators 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 the
applicable LDR requirements. Certifications are required for, among other things, 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 may be significant penalties for submitting false
information, including fines and imprisonment.

Commercial TSDF:  A  TSDF engaged in the conduct of commercial (i.e., far-profit] waste
management that receives hazardous wastes generated by other companies.

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. The term
disposal  facility  does not include a  corrective action  management unit into which
remediation wastes are placed.

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:  Per  RCRA Section 1004,   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. Per 40 CFR Part 260.10,  hazardous wastes are defined
in §261.3,  which includes  listed wastes  and/or wastes  that  exhibit one of the four
characteristics  (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: A facility that can operate without a RCRA Subtitle C 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 an interim
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, 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.

Lower Limit of Quantitation:  The  lowest concentration at which the laboratory  has
demonstrated target analytes can be reliably measured and reported with a certain degree
of confidence, which must be > the lowest point in the calibration curve.  Laboratories may
use alternative terms,  such as "reporting limit." Regulated entities  should consult their
state agency for the appropriate use of terms because it can depend on the context in which
the term is  used. For more information, see Update V to SW-846.

Notification: In the context of the LDR program, 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
APPENDIX E: Glossary of Terms

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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.

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, 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 RCRA Subtitle C permit]

Reporting  Limit: The lowest reported concentration of analytes provided on a laboratory
report after adjustments have been made for sample dilution, sample weight and amount of
moisture.  Laboratories may use alternative terms, such  as "lower limit of quantitation."
Regulated entities should consult their state agency for the  appropriate use of terms
because it can depend on the context in which the term is used. For more information, see
Update V to SW-846.

Resource Conservation and Recovery Act (RCRA): The Resource Conservation and
Recovery Act of 1976 (which amended the Solid Waste  Disposal Act of 1965} regulates
both hazardous wastes and non-hazardous wastes. RCRA has been amended three times,
most significantly, on November 8, 1984. The 1984 amendments known as the Hazardous
and Solid Waste  Amendments (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, disposal facilities (e.g., landfills, surface impoundments], treatment
facilities, (e.g., incinerators] and storage facilities.
APPENDIX E: Glossary of Terms

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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; appropriate to  transport, store, or dispose of; or
amenable for recovery, amenable for storage, or reduced in volume.

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. Use of the  phrase "waste analysis" refers to both waste testing and
applying acceptable knowledge

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 waste  testing as  opposed  to relying  solely on just generator acceptable
   knowledge. Procure a laboratory with a state laboratory certification program 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 and custom software programs].

   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 shows a certain percentage variance (trigger level to be negotiated with the
   permit writer] 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
   conditions that occur after the waste has passed acceptance criteria and waste is
   accepted into the facility (e.g., a tank farm].
APPENDIX F: Key Considerations and Tips

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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"}.

   Include a permit condition requiring notification of any changes to the WAP or 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 you do not have the expertise at your facility, consider using a qualified  consultant or
   TSDF for assistance in identifying, collecting, and characterizing your waste, but note that,
   as the  generator,  you are ultimately  responsible  for the proper identification and
   characterization of 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] waste  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}.

   Support any claims that secondary materials are NOT solid and/or hazardous waste
   with documentation.
APPENDIX F: Key Considerations and Tips

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
   It is important to not rely on a single analysis to characterize subsequent wastestreams.
   Waste-derived residues should 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.

   Be aware of what happens if the waste contains Appendix VIII constituents but does not
   meet the definition of a hazardous waste (e.g., if UHCs are present in de-characterized
   waste, the LDRs still attach to the waste.  See Section 1.1.1 of this manual for additional
   information}.

   Be  aware of the need to  characterize your waste more frequently if the process that
   generates the waste 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.

   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}.

APPENDIX F: Key Considerations and Tips

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


   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.

   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, 1980.

Burning of Hazardous Waste in Burners and Industrial Furnaces. Federal Register 56:166
[27 August 1991). p. 42509. See Discussion on Retroactive Hazardous Waste Designation.

Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous Waste
Sites, OSWER 9285.6-10. U.S. Environmental Protection Agency, December 2002.

Characterizing Heterogeneous Wastes: Methods and Recommendations, EPA 600-R-92-033.
U.S. Environmental Protection Agency and U.S. Department of Energy, February 1992.

Clean Water Act Analytical  Methods Web Site. U.S. Environmental Protection Agency,
Washington, D.C.

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. See Discussion on 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.

EPA Observational Economy Series, Volume 1: Composite Sampling, EPA 230-R-95-005. U.S.
Environmental Protection Agency, Washington, D.C., 1995.

Guidance for Obtaining  Representative Laboratory Analytical Subsamples from Particulate
Laboratory Samples, EPA/600/R-03/027. U.S. Environmental Protection Agency, 2003.

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.

Guidance on  Choosing a Sampling Design for Environmental Data Collection for Use in
Developing a Quality Assurance Project Plan, EPA/240/R-02/005. U.S. Environmental
Protection Agency, Washington D.C., December 2002.
Hazardous Waste Management System: Petroleum Refining Process Wastes; Identification of
Characteristically Hazardous Self-Heating Solids; Land Disposal Restrictions: Treatment
APPENDIX G: References

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Standards for Spent Hydrorefining Catalyst (Kl 72) Hazardous Waste. Federal Register
68:202 (20 October 20031 p. 59935.

Hazardous  Waste Management System; Testing and Monitoring Activities. Federal Register
55:27  [8 February 1990) pps.  4443-4444. See Discussion on Representative  Sample
Definition.

Hazardous  Waste  Treatment,  Storage,  and Disposal Facilities and Hazardous  Waste
Generators;  Organic Air Emission  Standards  for  Tanks, Surface Impoundments,  and
Containers. Federal Register  59:233 [6  December  1994)  p. 62916.  See Examples  of
Acceptable  Knowledge.

Hot  Spots:  Incremental Sampling Methodology  (ISM)  FAQs, Interstate Technology  &
Regulatory Council (ITRC), 2014.

Identification and Listing of Hazardous Waste  (40 CFR 261.31 and 261.32), Background
Document, U.S. Environmental Protection Agency, Washington, D.C., 1980.

Introduction to Land Disposal Restrictions (40 CFR  Part 268), EPA530-K-05-013. U.S.
Environmental Protection Agency, September 2005.

Joint NRC/EPA Guidance on  Testing Requirements for Mixed Radioactive and Hazardous
Waste. Federal Register 62:224 f20 November 19971 pps. 62079-62082. See Discussion on
Mixed  Radioactive  and Hazardous  Waste Testing  and  Use of Waste  Knowledge for
Hazardous Waste Determinations.

Land Disposal Restriction (LDR) Requirements Memorandum from Barnes Johnson, Director,
Office of Resource Conservation and Recovery, U.S. Environmental Protection Agency (RCRA
Online No. 14843). dated April 11, 2014.

Land Disposal Restrictions for Newly Identified and Listed Hazardous  Wastes and Hazardous
Soil.  Federal Register 58:176 (14 September 1993) pps. 48111-48112. See Discussion on
Demonstrating Acceptable Knowledge.

Land Disposal Restrictions for Second Third Scheduled Wastes. Federal Register 54:120 (23
June 1989}. pps. 26605-26606. See  Discussion on 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. See Discussion  on 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. See Discussion on LDR Lab Packs
under Phase II Rule.
APPENDIX G: References

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes


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. 28561. See Discussion
on Treatment Standards for Hazardous Wastes Containing Metals: Measuring Compliance
by Grab or Composite Sampling.

Land Disposal Restrictions Phase IV: Second Supplemental Proposal on Treatment Standards
for Metal Wastes and Mineral Processing  Wastes, Mineral  Processing and Bevill Exclusion
Issues, and the Use of Hazardous Waste as Fill. Federal  Register 62:91 [12  May 1997) p.
26047.  See Discussion on Demonstrating 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. See Discussion on Treatment Residuals, New Point of Generation, and UHCs.

Management of  Remediation  Waste  under  RCRA, 530-F-98-026.  U.S. Environmental
Protection Agency, Washington, D.C.,  1998.

Methods Innovation  Rule (MIR) Web  Site. U.S.  Environmental  Protection  Agency,
Washington, D.C.

National Emission Standards for Hazardous Air Pollutan ts: Final Standards for Hazardous Air
Pollutants for Hazardous Waste Combustors (Phase I Final Replacement Standards and Phase
II). Federal Register 70:196 f!2 October 20051 pps. 59433-59434.

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, U.S.
Department of Health and Human Services, October 1985.

Permit Applicants' Guidance Manual for the General Facility Standards of 40 CFR Part 264,
SW-968. U.S. Environmental Protection Agency, Washington, D.C., 1983.

Permit Applicants' Guidance Manual for Hazardous Waste  Land Treatment, Storage, and
Disposal Facilities,  EPA  530 SW-84-004.  U.S.  Environmental   Protection  Agency,
Washington, D.C., 1984.

RCRA Orientation Manual, 2011, EPA 530-F-11-003. U.S. Environmental Protection Agency,
Washington, D.C., 2011.

RCRA Waste Management: Planning, Implementation, and Assessment of Sampling Activities,
Manual  42. American Society of Testing and Materials, 2000.

RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation and Assessment,
EPA530-D-02-002. U.S. Environmental Protection Agency, Washington, D.C., August 2002.
APPENDIX G: References

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Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes
Revision ofWastewater Treatment Exemptions for Hazardous Waste Mixtures ("Headworks
Exemptions"). Federal Register 70:191 f4 October 20051 pps. 57769-57771. See Discussion
on 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.

Superjund Program Representative Sampling Guidance, Volume 4: Waste, EPA 540-R-95-141.
U.S. Environmental Protection Agency, Washington, B.C., 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.

Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, Draft, EPA 530-R-94-
019. U.S. Environmental Protection Agency, 1994.
APPENDIX G: References

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