Hazardous and Solid Waste

What’s In a Waste Analysis Plan

To that end, the WAP must contain all information necessary to treat the waste(s) in accordance with the requirements of 40 CFR Part 268, including the selected testing frequency.  Regulations at 40 CFR 264/265.13(b) and (c) spell out the information that must be included in the WAP.  Components of the WAP are as follows:

    • The parameters for which each hazardous waste, or nonhazardous waste if applicable under 40 CFR 264/265.113(d), will be analyzed and the rationale for the selection of these parameters (i.e., how analysis of these parameters will provide sufficient information about the waste’s properties as specified).
    • The methods that will be used to test/analyze these parameters.
    • The method that will be used to obtain a representative sample of the waste to be analyzed. 
    • The frequency with which the initial analysis of the waste will be reviewed or repeated to ensure that the analysis is accurate, up to date, and representative of the waste over time.
    • For off‐site facilities, the waste analyses that hazardous waste generators have agreed to supply.
    • For permitted TSDFs, the methods that will be used to meet the additional waste analysis requirements for specific waste management methods as specified in RCRA regulations (e.g., 264.17, 264.314, and 264.341).
    • For interim‐status TSDFs and activities, where applicable, the methods that will be used to meet the additional waste analysis requirements for specific waste management methods as indicated in RCRA regulations (e.g., 265.200, 265.225, and 265.252).
    • For surface impoundments exempted from LDRs, the waste analysis procedures and schedules required by 264/265.13(b)(7).
    • For owners and operators seeking an exemption to the air emissions 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 owners or operators 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.

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    Other Points Regarding WAPs

    • If a waste exhibits a hazardous waste characteristic, the generator or TSDF must determine whether the hazardous waste contains underlying hazardous constituents (UHCs) (there are no UHCs for listed waste).  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 treatment standards (268.2).
    • Under the manifest and LDR programs, generators of hazardous waste must provide the TSDF with waste analysis information, the applicable RCRA codes (e.g., K061), and the applicable LDR treatment standards.  The TSDF should also be provided with a description of the process that generated the waste.  Similarly, a treatment facility must provide waste analysis information (including any information supplied by the generator as well as waste analysis data developed by the facility before and after treatment) to any off‐site storage or disposal facility receiving the waste.
    • Waste analysis information can be acquired by either collecting a representative sample and conducting laboratory analysis or by using published data and generator knowledge of the waste-generating process (known as acceptable knowledge, generator knowledge, or process knowledge).  Acceptable knowledge can include, but is not limited to:
      • Process knowledge, whereby detailed information about 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; or
      • Data from analysis or testing performed by the generator; or
      • In cases of newly listed wastes, data from recent waste analyses performed before the effective date of the listings.
    • Regulations establish more robust waste analysis requirements for TSDFs that may have process‐related permit requirements that exceed generator determinations.  At all times, the owners and operators of TSDFs are responsible for obtaining sufficient information required for compliance regardless of the completeness or quality of any information received from the generator or other parties.
    • TSDF WAPs should include criteria for preacceptance screening to avoid accepting waste the TSDF is not permitted to handle.  Typically, generators are required to submit a waste profile sheet with the waste shipment.  Waste acceptance procedures can also include laboratory or field sampling or rapid qualitative observations, also called fingerprinting, such as visual identification of color or number of phases (e.g., water or solid).
    • Waste acceptance procedures should also address metal concentrations in a highly variable wastestream to document compliance with permitted feed rates.  This type of acceptance sampling could require sophisticated analysis using laboratory methods.
    • Waste analysis based on acceptable knowledge may be used for both preacceptance profiling and to meet permit requirements.  However, the EPA cautions that acceptable knowledge is generally appropriate only under well-defined circumstances; for example, the processes that generate a waste and the waste’s hazardous constituents are well documented; the wastes are discarded, unused commercial chemical products; and health and safety risks prohibit laboratory sampling.  In other cases, a combination of laboratory analysis and process knowledge may be appropriate, for example, with construction debris.  “All available information must be considered and weighed in making a knowledge-based hazardous waste classification,” states the EPA.  Accordingly, use of acceptable knowledge should be accompanied by supporting documentation, including but not limited to safety data sheets (SDSs) or previous test data for other locations managing the same type of waste. 

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    The bottom line is that accurate identification of hazardous waste is one of the most important tasks for generators and TSDFs.  Generators who are not familiar with RCRA waste determination requirements should make it a priority to learn the appropriate federal and/or state regulations; speak with personnel at the site and compile paperwork to develop a collective knowledge of generating processes and potential wastes; and develop a system for staying abreast of regulatory changes.

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