c; 

c 

Heritage Therm.ul Services, Inc. 

SECTIONC 

OH0980613541 

Revision: 31 

September 18,2014 

WASTE CHARACTERISTICS AND WASTE ANALYSIS PLAN 

Heritace Thennal Senlces, lne. 

East Llvupoot, Ohio 

Revision 31 - Seplember 18, 2014 

VES016298 
TABLE OF q>NTENTS 

Heri~Wfl, Inc. 

OHD980613541 

Revision: 24 

Aprill, 2010 

Introducticn ···-·····--··--···-····-····················--···-·-··-···--·----···-·-··--··············-···-·····-C-1 

C.. I CRI!MICAL AND PHYSICAL DESCRIPTIONS OF WASTE TO BE PROCESSED ........... C-3 

C-la W&JM to be Incinerolod or Treated ·-·····-······ ... ·····-····-··········································C-4 

C-Ia(!) C1au 1 -Prohibited Wastcs .................................................................. C-4 

C-18(2) Clas• 2 · Restricted Wastes ................................................................ C-12 

C-1 a(2)(i) Wastes with Handling and/or Storage Restriction .............................. C-13 

C-1 a(2)(i)(a) Off-Site Trausfa (Third Party) or Fuels Blooding ofWo.ste ..... C-13 

C-1a(2)(i)(h) Mixed Infectioua and Haurdoa$ Waste .................................... C-14 

C-1a(2)(i)(c) Compressed Gu and Gas Mixlu:res ........................................... C-14 

C..la(2)(ii) Wastes with Treatm::ot Rtslrictions .................................................... C-15 

C-la(2)(ii)(a) Asbestos and Asbestos Waste ...........•.......•..•.••......•..•............... C-16 

C..la(2)(ili) Wastes with LDR Treatment S1anda:ni Restrictiona .......................... C-16 

C..la(3) Class 3 · Acceptable Wastes Whleh Contain Inorganic 

~ Materiah .••..••.. --··-··-···-···············-···-·----·-·-····-············-····C-19 

'-•· C..Ja(4) Class 4- Acceptable Wastes Whleh Contain Organic 

Maseriah ·····-·-···---·····-·······-······-·----·············- ············-·····C-20 

C..la(S) Clan 5 • Wue Codes Not CWTallly Pcmxittcd in Part A ................. C-21 

C-lb Wa.steApproval System :... ................................... _ .................................................... C-21 

C-lb(1) Corulitiooal Approvai ........................... .............................. _ ............. C-22 

C..lb(2) Waste Cbaraeterizatioo Pn>-Aceeptancc Procedu:es .......................... C-23 

C-lb(2)(i) Wutc Profile Sheet (WPS) Description ............................................. e-26 

C..lb(2)(u) Miaeellaneous Sp<Ci.a1 Wuuc .•..•• ·-···-·-···-·-··-·-····-···-···········-C-27 

C-lb(2)(iii) Wutc Approval Ptoccss ........................................................ - .........•. C-32 

C..lb(2)("1V) Exceptiooa to the Waste Awtoval Process ....................................... C-35 

C-1b(2)(iv)(a) RcservecL ................................................................................... C..35 

C..ib(2)(iv)(b) Waste Streams Not Requiring Pre-AeecptBDCC Sample 

Prior to Waste Rcccipt ........................................................... C-40 

C-1b(2)(iv)(b)(l) Third Party Wa.ste ................................................. - ... C-40 

C-1b(2)(v) Revision Procc::dures ............................................................... _ .•••.•.•• C-41 

C-lb(2)(Y1) W ute Profile Copy-0-Proccdurcs ............. - ................................ C-42 

C..lb(3) Waste Characterization Fingerprint Procedures ................................. e-44 

Al'R lli 2010 

VES016299 
, ....... 

' .· 

' ·' 

Heritage - WTI, Inc. 

OHD9806l3541 

Revision: 22 

November 10,2009 

C.lc Facility-Spoel:fic Chemical and Physical Analysis Requirements ................................ C-46 

C-lc(l) Contain<rir.ed Waste ........................................................................... C-46 

C.lc(2) Waste in Tank Systems ....................................................................... C-46 

C-l c(3) Waste in Piles. ................................................................. : ... - ... C-48 

C-lc(4) Landfilled Wastes ...................................................................... C-48 

C.lc(S) Wastes Incinerated cd Wa.otes Used in PerformlliiCe Tests .............. C-48 

C·lc(6) W&SUs.to be Land Treated .................................................................. C-49 

C.!c(7) Wastes in ~.1Jaocous Units ........................................................... C-49 

C.lc(8) Wa.rte Used in Lieu of Product ................. - ...................................... C-49 

C-!c(8)(i) NOD-Hazardous w..-..................... - ...................................... C-50 

C-lc(9) Third Party Waste .......................................................... : ........... C-5 1 

C-2 WASTE ANALYSIS PLAN ..................................... - .............................................................. C-52 

C.2a Parameters and Ratiooale .............................................................................................. C-53 

C-28(1) Pre-Acceptance Analyses .................................................................... C-55 

C-28(2) Fingerprint Analyses ....................................................................... ... C.SS 

C.2a(3) Suppltmenlal AriaJyses ..... - ........................................ - .................... C-60 

C-28(4) lAod Disposal Resttictio11 AD&lyses ......... - ................................ - .... C-62 

C.2b Analytical Toot Metbocls ................ - ...................................................... _ .................. C~3 

C2b(l) Dcscripti.<m of Analytical TestMethods ............................................. C-63 

C.2b(2) Description of Quality Control Program ................ : ........................... c~ 

C-2c Sampling Melhods ....................................................... ~ .............................................. C~5 

C.2c(l) Containers and Taclcs ........ - ............................................................... c~ 

C.2c(2) Spray Drye.-Feed Sy$1CIDOI ............................................. - ................. C-67 

C.2c(3) Stora~ Taclcs ................................... - ........................ ___ ................ C-67 

C.2d Frequency of Analyses ........................................................ - ....................................... C~7 

C.2d(!) Pre-Acceptance Analyscs ........................... - ........................ : ............. C-67 

C.2d(2) Flngc:rprint.Analyses .......................................................................... C-69 

· C-2d(3) Supptemeotal Analyses ....................................................................... C. 70 

C.2d(4) Land Disposal striction Analyses ............................ - .................... C-70 

C.2d(4)(i) Asb Residue and Scrobber Blowdown W-Sampling Freqnency ..... C-71 

C-2d(4)(ii) Slag Residue and Used Kiln Brlck. ........ -·-·---·---·-··--- ·-......... C-72 

ii JAN 1 5 2010 

OHIO EPA NEDO 

VES016300 
·"''\ 

' -··' Heritage - WTI, Inc. 

-- . 

. OHD980613541 

Revision: 22 

November 10, 2009 

C-2e Additional Requirements for Wastes Generated Off-Site ............................................ C-73 

C-2e(l) General Procedures for Acceptance of Wastes Generated OffSite .................. - ................................................................................. C-73 

C-2e(2) · Specific Procedures for Acceptance ofLabpack Shipments ............. C-77 

C-2e(3) Specific Procedures for Acceptance of Loose Pack Shipments ......... C-86 

C-2e(4) Specific Procedures for Acceptance ofMlxed Infectious aod 

Hazardous Waste ..................... - ......................................................... C-93 

C-2e(S) Specific Procedures for Acceplllnce of Compressed 

Gases and Gu Mlxtures (Gases) ....... , .............................................. C-121 

C-2f Additional Requirements for Ignitable, Reactive or Incompatible Wastes ................ C-122 

C-21(1) Storage .............................................................................................. C-123 

C-21(1 )(i) Waste in Containers ........ _ ................................................................ C-123 

C-21(1Xil) Waste in Tanks .................................................................................. C-124 

C-21(2) Incineration ....................................................................................... C-126 

C-3 WASTI!ANALYSlS REQUIREMHNTS PERTAlNINO TO LAND DISPOSAL 

RESTRICTIONS-·-·-· ................................................................................. ........................... C-127 

C-3a Applicablllty ofTreaimcnt Standards.·--·- ·-·· .................. - ................................. C-127 

C-31(1) Waste Cbaracteri7.otion --- ·- .............................. - ................. - ...... . C-127 

C-3b Ptohibitions ................ · ....... - ....................................................................................... C-129 

C-3b(l) Dilution Prohibition as a Substitute for Tru!ment ........................... C-129 

C-3b(2) Wastes That are Prohibited from Combustion .................................. C-129 

C-3b(3) Dilution Prohibition for Lead Containing Wastes- ......................... C-130 

C-3b(4) WIISte Specific Prohibitions; Wood Preserving Wastes ........... - ..... C-130 

C-3b(S) WIISte Specific Prohibitions; Dioxin-Containing Wastes ................. C-131 

C-3b(6) Waste Specific Prohibitions; Toxicity Characteristic Metal 

C-3b(7) 

C-3b(8) 

Wastes ................................................... - ........ - .............................. C-13 I 

Waste Specific Prohibitions; Petroleum Refining Wastes ................ C-131 

W a..m Specific Prolnbitlons; Wastes With Ignitable and 

Corrosive Characteristies .......... - ....... ......................................... _ .. ,C-132 

JAN 1 5 2010 

iii 

OHIO EPA NEDO 

VES016301 
' . ' 

1\ 

\... .. : 

C-3b(9) 

C-3b(l0) 

Heritage • WIT, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

Waste Specific Prohibitions; Organic Toxicity Wastes, CokeBy-Product Wastes, and Chlorotolueoe Production Wastes.-.......... C-132 

Waste SpecifiC Prohibitions; Spent Aluminum Pot Liners, 

Reactive Wastes, and Carbamate Wastes ------·-·------·--····--"---....... C-132 

C-3c Sampling and Analytical Requimnents for Treatment Residues ............................... C-133 

C-3e(l) Sampling and Analytical Procedures ................ _ .............................. C-133 

C-3e(2) Wastes or Contaminated Soils with Treatment Standards 

Expressed as Coocentrations of the Waste Bldract. .......... : ............... C-133 

C-3e(3) Wastes or Contaminated Soils with Treatment S1andards 

&pres ted as Concentrations of the Waste .................................. -... C-133 

C-3c( 4) Frequeocy of Anaty.is ................... ·-................................................ C-134 

C-3d Notification and Certification Requiremeots ...... -...................................................... C-134 

C-3d(l) Retention of Generator Notices and Certifications .............. -......... _C-134 

C-3d(2) Notification and Certification Requirements for Treatment 

Residues Shipped to Land Disposal Facilities .................... _ .. _, __ c-134 

C-3d(3) Notifications and Certification Reqlriremeots for Wastes widl 

Organic Constitueots .............................................................. -..... -.. C-135 

C-3d( 4) Notifications and Certification Requirements fur Characteristic 

Wastes ....................... -...................................................................... C-135 

C-3d(S) Notifications and Certification Requirements for Wastes to he 

Further Managed ........................ , ...................................................... C-135 

C-3d(6) Notifiestions and Certification Requirements for Land Disposal 

Facillties ............. -... -...... - ........... - .................... _ ..... -................... C-135 

C-3d(7) Notifications and Certification Requirements for Facilities 

Treatiog Hazardous Debris ............................................................... C-135 

C-3d(8) Notifications and Certification Requirements for Facilities 

Trealin$ Contaminated Soil ...................................... ........................ C-136 

C-3d(9) Notifications and Certification Requirements for 

Recyclable Materials Used io a Manner Constitutiog 

Disposal ............................................................................................. C-136 

iv JAN 15 2010 

OHIO EPA NEOO 

VES016302 
, _, 

1\ 

\.../ 

SECTJONC 

Heritage - WIT, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

WASTE CBARACfERISTICS AND WASTE ANALYSIS PLAN 

Tnh))duttion 

Section C defines the Waste Characteristics and Waste Analysis Plan t;y{ AP) for the Heritage -

wn, Inc. (WO) facility. It is designed to meet the requirements of40 CFR264.13 and OAC Rule 

3745-54-13. The plan bas been developed as an integral part of the Part B Ohio Hazardous Waste 

Installation and Operation Permit Application for the Permittee, a commercial waste management 

facility localed in East Liverpool, Ohio. The pro<:<dures set forth in this plan ensure that this facility 

will be in compliance with regula!ory requirements. A copy of this pl8D will be available at the 

facility at all times. 

lt is the policy of the Pennlttee that waste handled by this facility will be subjected to the 

procedures presented in this plan, which bas been written to assist in the facility's compliance with 

applicable pemrits and regulations. The Pemlittee Slrives to mainlain compli~ with the 

hazardous waste regulations and its operllling permits. New requirements, however, often become 

eifeclive prior to the time Waste Cbaracteristics and Waste Analysis Plan revisions can be formally 

made and approved. In some instances, it may be impossible to have in place an approved plan 

meeting all the conditions of the· immediately effeclive requirements. The Pennittce will submit the 

appropriate revisions to this Waste Cbamaeristics and Waste Analysis Plan as required by newly 

promulgated regulations·in a timely manner. 

In ligh! of Qlese facts, in the interim time between promulgation of ocw rules and modification to 

this section, the fa.cility will have in place a written protocol spccify:ing the new requirements, such 

as testing and frequeocy, prlor to receipt and/or processing of the regulated waste. The facility may 

periodically revise the protocol to reflect scientific advances and chaoges in operation or equipment 

at the facility. 

JAN J .5 nun 

OHIO EPA NEDO 

C-1 

VES016303 
Heritage- WTI, Inc. 

ORD980613 541 

Revision: 22 

November I 0, 2009 

In general, the Waste Olaraderistics and Waste Analysis Plan is divided inlo three main sectiODS. 

The fu:st section, C-1 titled Chanica! and PbJ!Sieal Dcsaiptinns of Wasil: to he Pma:ssed presents 

the characteristics of the waste streams accepted by the Peunittee, the Waste Approval System's, 

and requirements for analyses. The second scctioii, C-2 titled Waste Analysis Plan (!NAP), 

· provides the framework for eoswing that appropriate methodologies arc employed U> properly 

sample and analyze waste. The third section, C-3 titled Waste Anai)!Sis Requirements pmaining to 

I •od Disposal R esttiotiaos, pr=ts information on the Permittee's compliance with ibe land 

disposal restriction program. 

Throughout the Waste Ounctrristics and Waste Analysis Plan, ibe following terms are defined as 

follows: 

• "Laboratory,' for the purpose of sampling and testing, means the Pennittee's laboratory, or 

(""'.. any laboratory designated by the Penoittee after review and approval of their quality 

\.. .. procedures. 

~""' 

\, . 

• "F I!Cility maoagernent'' means one or more of the following designees: President, Vice 

Presidezlt and GerJenl Manager, Product Munagemcot ·Manager, Environmental, Health, & 

Safety Manager, Vice President of Madceting or conesponding titles or positions, or their 

designees. 

• "WPSK is used throughout this document as an abbreviation for Waste Profile Sheet (see 

section C-lb(2)(i)), wbicb is completed to provide infonoation necessary for proper waste 

storage and treattnent. 

• For wastes, the operatiug definitions of physical state are as follows: 

Sbldac 

Particle Si= Less than %" in diamet« 

Absolute Viscosity: 300-500 cP (1500-2500 SSU) 

Fails Paint Filter Test 

Liljllid 

Particle Size: No particles greater than 1/8" in diameter 

Absolute Viscosity: Less than 300 cP (1500 SSU) 

Filtered Solids: 5% or less 

Falls Paint Filter Test 

C-2 

JAN J 5 ?mr. 

OHIO EPA NEDO 

VES016304 
0 

\.. . . • 

~ 

Particle Size: Less than W' in diameter 

Absolute Viscosity: Less than 300 cP {1500 SSU) 

Fails Paint Filtec Test 

Solid 

Passes Paint Filter Test 

!.las 

Vapor Pressure greater than atroosphedc pressure at 20°C 

Waste 

H.awdous waste as defi.oed by OAC Rul~ 3745-51 

Heritage - wn. Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

C l CHEMICAl. AND PBYSlC AI . DFSCRTPTIQNS OF WASTE m BE PROCESSEII 

,/\ OAC Rule 3745-S0-44(AX2), 3745-54-13 

\.../ 

/"'") 

\. ,..: 

The Pennittce is a commercial ~te management facility that serves the waste treatmcot needs 

of a broad range of waste gener:ating industries. The introduction of new regtilations can cause 

signi:ficant changes in (he waste composition, i.e., if large volumes of non-regulated waste 

become hazardous waste due to regulation changes. The evolution of processes that generate 

wL'lle and the introduction of new products also contribute to the dynamic nature of the 

composition of waste to be treated. O!anges in waste composition are expected to continue, 

thef'eby making it difficult to predict accurately what the chemical and physical romposition of 

the waste will be throughout the life of the facility. 

'JAN J ~ • ···' 

OHIO EPA NEOO 

C-3 

VES016305 
C-ta Waste to be Incinerated orlluted 

Heritage - Wfl, Inc. 

OHD980613541 

Revision: 22 

Novemba 10, 2009 

Wastes can be divided into five gen<:ral clasSC6 rclative to their acceptability for treatment at the 

facility. The following sections provide a description of the five classes of waste: (I) Prohibited 

Wastes, (2) Restricted WaStes, (3) Acceptable Wastes Which Contain Inocganic Materials, (4) 

Acceptable Wastes Which Contain ()rglmic Material. and (5) Waste Codes Not Currently Permitted 

in Part A-of this pemrit application. 

C-la(l) Class 1- Prohibited Wastes 

Certain wastes containing Polychlorinated Biphenyls (PCBs), dioxinslfurans., infectious waste, 

chemical w~ agents, radioactive wastes and compressed gases (except for gases used as 

propellant in actosol caos and approved gaseous wasto listed in Table C-la(2Xi)) are prohibited 

from management at the facility. These wastes, as further described in this soction, are 

Q proluoited from acceptance at the facility because of permitting requirements. 

c 

The permittee will not accept, store, or treat prohibited wastes from any facility, including those 

· faci1ities that m.cct the definition of Conditionally Exempt Small Quantity Generator (CESQG) 

as defined by the Ohio Adminis1rative Code (OAq Rule 3745-51-0S(A). This is because OAC 

Rule 3745-5!-0S(B) e><empts CESQGs from many o~the regulations governing the management 

ofhazardous waste. For example, CESQGs are required to characterize their waste as hazardous, 

non-hazardous, or solid waste, but they are not required to follow the regulations governing 

labeling, applying applicable codes, manifesting, and LOR requirements. However, C8SQGs are 

requited to ensure the hazardous waste is being treated at a permitted hazardous waste treatment 

facility. 

'JAN 1 5 2010 

C-4 OHIO EPA NEOO 

VES016306 
0 

Heritage· WTI, Inc. 

OIID980613541 

Revision; 22 

November 10,2009 

• Polychlorinated jpb~ls (PCB() - The Permittee will not accept, store, or treat waste 

that has a source concentration greater than SO parts per million (ppm) PCB or waste that 

is, or was at one time, regulated by TSCA, 40 CFR ·761 - Pnlycb!orinatcd Bipben:yls 

CPCBs) ManJJfartuing Processing Djstribntjon In Commerce, and lise Pmbihjtims. 

This waste is prohibited because the faality does not have systemS in place t.o meet the 

rcquixcmeots of the above citation. 

• Djmjns/Ftmms - The Permittee will not acoept, store., or treat any waste Slreams that are 

assigned hazardous waste codes F020, F021, F022, F023, F026, F027, and/or F028. 

These waste codes are presented in Table C-l(a)(2), the Prohibited Waste Code Table, 

and indicated by the Jetter "d" at the end of each description. These wastes arc listed 

specifically because of dioxin/furan content. The Permittee will not accept, store, or treat 

any waste streams that cont'Bin dioxio/furan concentrations above applicable LOR 

treatment standards. 

Dioxinlfuran-bearing wastes require· more stringent treatment tec::hoology than that 

required for hazardous waste incineration. A Destroction And Reinoval Efficiency (ORE) 

of 99.9999"/o is required for ill<:inerllling dioxinlfuran-bearing waste, where as ORB of 

99.99"/o is required for incinerating a hazardous waste. Treatment standards are 

presented in OAC Rule 3745-57-43. Compliance with these performance standard' must 

be demonstrated in order for the incineration system to treat waste stn:ams eharact.e:rizcd 

with waste codes F020, F021, F022, F023, F026, F027, and/or F028. Fulfillment of these 

requirementS has not been pursued by the facility at this time. 

'JAN l ·li 2010 

OHIO EPA NEDO 

C-5 

VESD16307 
c 

Heritage - WTI, lnc. 

OHD980613541 

Revision: 22 

November 10, 2009 

• · lnfectjou s Waste The Permittee will not accept, store, or treat any waste streams that are 

characterized as infectious by OAC Rule 3745-27. The Permittee has not pursued 

approval to manage infectious wastes at the facility. · Infectious waste that has been 

rendered non-infectious, and certified by the ge:lerator as non-infectious, may be accepted 

for disposal subject to Ohio EPA approval of the WPS. 

The Penni~ may manage (accept, process, stage, s1ore, and/or treat) infectious waste that 

is also hazardous waste as specified in OAC rule 3745-51.03, and thus requim the 

application of one or more haz.azdous waste codes to be managed as hazardous waste. 

Infectious waste must be hazardous waste to be managed at the facility . Infectious waste 

which is also hazardous waste is referred to as mix¢ infectious and hazardous waste 

(M!Hw) throughout the permit application. 

Specific infonnation regarding the management MIHW can be found in this section of the · 

permit application dealing with restricted wastes, specifically C..1a(2)(iXc), Mimi 

lnferzjmls 3nd Hazardous Waste, and in C2e(4), Specific Procedures For Acprptancc of 

Mixed Jnfemmts And HazauJons Wag1c . 

The Pc:n:nittee is prohibited from accq>ting MlHW conlaining prion waste, prionoonlm:ninaled debris, prion-related waste, or prion related contaminated debris. 

• Ou:mical Warfare Aaents (pi/A) and Other Chemical Weapons· The Permittee will not 

accept, store, or treat any chemical warfare agents or other chemical weapons or debris 

generated from the manufactw'e and I or c leanup of CW A. Waste characterized with 

waste codes identified in Table C-la(2), Prohibited Waste Code Table, and indicated by 

the letters "cw'' after the description, cannot be accepted, stored, or treated at The facility 

without a permit modification. 

'JAN I 5 2010 

OHIO EPA NEDO 

C-6 

VES016308 
0 

Heritage • Wfl, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

The Chemical Weapons Convention (CWC), an active treaty with which the United· 

States complies, provides definitions and lists of prolnoited toxic chemicals and their 

precursors. Chemical warfare agents not included in Table C-IA{!) which are llQt 

prohibited by the convention will be considered for management ot the facility, and 

inclnde the following: (a) industrial, agricultural, research, medical, pharmaceutical or 

other peacefu.l purposes; (b) protective purposes, namely those purposes directly related 

to protection against toxic chemicals and to protection against chemical weapons; (c) 

military purposes not coonected with the ~ of chemical weapons and not dependent on 

the usc of the toxic properties of chemicals as a method of warfare; and (d) law 

enforcement including domestic riot control purposes. Prohibited toxic chemicals and 

their precursors listed in Schedule I of the ewe, which is presented in Table C-l (a)(l), 

will not be accepted at The facility. Debris contaminated with chemicals listed in 

Schedule 1 also lllilllllll be accepted at the facility. Wastes contaminated with chemical 

warfare agCOJt(s) that have been treated to remove the agent(s) may be accepted for 

treatment allcr obtaining written certification from the generator or treatment facility that 

the chemical warfare agent(s) have been deactivated or e!iminated, subject to Ohio EPA 

approval of the WPS. 

"JAN 1.5 7010 

C-7 OHIO EPA NEDO 

VES016309 
0 

0 

Heritage -WTI, loc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

Table C-l(a)(l)- Chemical Warfare Agents from Schedule 1 

Chemical Category I Claemk:al Names & CAS Numben 

A: Toxic Clwnk:als: 

( Q ().Ali:JI ~C O, ir>el. qdoalkyl) lllkyl (M" El, n- Sarin (O·bopropyl mcthylpboSpboao&oridotc) (107~) 

Prai-Pr~dales s-(Q.Pinocol)'l ~oOuoridale) ~) 

(l)().AJ)cyt ~CIO, incl. qoloolkyl) N,N..tlal(yl (Mr, Tlobuo:O.Ello)1~(71-ll~ 

Q. .. Pro:~P:)pbo~ 

(l) (MJieyl (B or ~CIO, io<l. qdoallr:yl) S.J- VX: o.all)'l S.Uiisopop)'l~l plloopdioll:yi(M<, El, o-Pt or i-Pr )ominodbyl all;yi(Mc.l!l. D-Pr (507-112-69-9) or 1-Pr) pbos1..., oe:<lliolOics ODd ccrrcopondq ollr;ybr.d "" 

_....soolts 

(I) SUUIJrmwwds l..cb.lOtOdbylcl!lotomclbyiiOllfide (26l$. 76-$) 

MtiiWd cas: Bls(l<ltlorodl>yl)sol.Gde ~$·60-2) 

Bis(l-chlorodbylthio)methane (63869-13·6) 

Se~ 1,2-ll!s(2-<ltloro<lbyllhio)c1bane (JS63·36-8) 

1,3·811(~)-o-ptopaoo (63905·10·2) 

1.4-B~)-o--(14286H3·7) 

l ,.S.BiJ(l-chlorodbylthio}«·pcn-(142861-9(..8) 

BiJ(2o<:blorodbyl1hlomcCbyl)dhcr ( 63918-oo.l) 

~B~cd,yl)dher(63918-119-8) 

(S) l.cwisi1a Lcwisiu: ~ 2-0olorovi!lyldichlomonille (,.1·25·3) 

J..ewHi>el: Bis(l~(44334-69-l) 

Lcwisiu:l T~(0334-70.1) 

(1)~..-ds IINI: B~lamioe(53J.4U) 

RNl: BIJ(l~(Sl·7S.l) 

I!Nl T~(55S.77·1) 

(I)Salloxln 8&xltoxh> (35SlJ..BU) 

(I) Ricin Ricin (9009-116-3) 

B. l'r«vn<~rs: 

(9) Alkyl (Me, Et, n·Pr or I.P,) phosphoayldilloor\dcs DF: Mdhylpbospbonyldif!Ucride(676·99-3) 

(I 0) O·Aikyl (B cr < o.-CJO,II>d. eyelolilcyl) 0.1-<llallcyl QL: ().EJieyl ().2-diisopropylaminoethylmethylpllospboolte 

(Me, El, A•Pr or 1-Pt)..minoedlyt lllkyi(Me. El, n·Pr or I· (l'18S6-li·B) 

i'r) photpbocllcs onclcorrospoodinslllcyl-.d or 

jii"Ut<IDOtocl soils 

(I I) Cblorosarln: O.isop<opyl meth)'lpllospbcmncbloridlllc Cblnmsorin: ().Isopropyl tndlrylpbcspbooocblorldoooe (1445-76·7) 

(1445-76-7) 

(12) Cblornsamm: 0-Fiaaa>lyl Clllorotocnoo: O·l'inacoll'l m<lhyl"""""'onoeblorlclale (7040.57· 

Dd!Jy~b q~- .cbJoridlltc (7040.57·5) S) 

JAN 16 2010 

C-8 

. OHIO EPA NEDO 

VES016310 
-"'· \ ..._ ,.;· 

Heritage · WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

• Radioactive Wastes • The Permittee will not accept, store, or 1reat any waste where the 

measured radioactivity exceeds background radiation. The Permittee bas not pursued the 

necessary pemilis to manage radioactive wastes. 

• Compressed Gases The Permittee may accept arid treat compressed gases that are well 

characterlzed and have beeo evaluated for safe handling and maoagem~t . Some of the 

constituents contained in waste presently accepted by the Penpittee are gases at standard 

temperature and pressure (STP), however, these constituents are either dissolved in a 

solution or are absorbed in other material, thus making the physical state of the accepted 

waste a liquid or a solid or a mixture of both. These wastes are acceptable, whereas 

wastes that have a vapor pressure gteater than atmospheric pressure at STP are considered 

to be. gllSOOUS waste streams, and are evaluated as such. Gaseous materials that carry 

waste codes which are prohibited from management at the facility are listed in Table Cl(a)(2), and we indicated by the letter "V: following the description. 

Compressed gases in aerosol cans are acceptable for treatment at the facility, with some 

conditions. Aerosol cans are limited to thin-walled metal containers, one liter or less in 

volume, which are designed to hold liquids. These containers may contain small amounts 

of gas under pressure, as long as the gas serves as the propellant to expel the liquid from 

the container. 

JAN 1 5 2010 

C-9 OHIO EPA NEDO 

VES016311 
0 

c 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

• Prohibited Waste Code Table - The following table lists specific waste codes that are 

prohibited from acceptance, storage, and treatment at the facility. Chemicals that are not 

characterized by waste codes have been excluded from Table C-1a(2) due to the large 

number that meet the d escriptions given above but are not characterized by a specific 

waste code. Wastes that contain a small percentage of a certain constituent may not 

require a waste code, and therefore are not prohibited, if none of the other reasons for a 

prohibition apply. For example, a waste that contains 100 ppm of cyanogen m·a liquid 

suspension, but is not characterized with the waste code P031 would be acceptable for 

treatment at the facility if the vapor pressure were less than atmospheric pressure. 

.JAN 15 2010 

OHIO EPA NEDO 

C-10 

VES016312 
I 

0 

Heritage - WTI, fnc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

T a hi e ...- r 1( )('-) P h ihl"'d l£ t r .t T hi I - r;o as..e o e • e 

EPA Hazardous 

Waste Number 

F020 

F021 

F022 

F023 

F026 

F027 

F028 

P03! 

P033 

P0 56 

P063 

P076 

Description of the Waste 

Wastes from tbe production or manufacturing use of tri- or 

tetracblorophenol, or of intermediates used to produce 

their pesticide derivatives. (d) · 

Wastes from the production or manufacturing use of 

peatacbloropbenol, or of intermediates used to produce its 

derivatives. (d) 

Wastes from the manufacturing use.oftri· and 

tetrachloropbenols. (d) 

Wastes from the production of material on equipment 

previously used for the production or manufacturing use 

oftri- and tetrachloropbenols. (d) 

Wastes from the production of certain chlorinated 

aliphatic hydrocarbons, by free radical catalyzed 

processes. These chlorinated aliphatic hydrocarbons are 

those haVing carbon chain lengths ranging from one to and 

including five, with varying amounts and positions of 

chlorine substitution. (d) 

Discarded unused foiDlulations containing hi-, tetra·, 

penta-, or hexachlorobellzeoe under alkaline conditions. 

(d) 

Residues from incineration or thermal treatment of soil 

contaminated with: F020, F021, F022, F023, F026, and 

F027 

Cyanogen (g) 

Chlorine Cyanide(Cyauogea Chloride) (cw, g) 

Fluorine (g) 

Hydrocyanic Acid (Hydrogen Cyanide) (g) 

Nitrogen (ll) Oxide (Nitric Oxide) (g) 

C-ll .JAN Ui 2010 

OHIO EPA NEDO 

VES016313 
0 

c 

P078 

P095 

P096 

P112 

U033 

Ul35 

d oo CJIO.IIA>DCII"WWJ 

C-b(2) 

Heritage Thermal ~rvices. Inc. 

OHD980613541 

Revision: 31 

September 18,2014 

Nitrogen (IV) Oxide (Nitrogen Dioxide) (g) 

Carbonyl Chloride (Phosgene) (cw, g) 

Hydrogen Phosphide (Phosphine) (cw, g) 

Tetranitrometbane (cw) 

Carbon Oxyflooride (Carbonyl Fluoride) (g) 

Sulfur Hydride (Hydrogen Sutrlde) (&) 

Restricted wastes consist of three types of was~e, (I) those with handling and/or storage 

restrictions, (2) tboS¢ with ll'Calmellt restrictions, and (3) those with LOR treatment sUlndard 

restrictions. Restricted wasteS wiil he accepted only if they are received in a form aad quantity 

which allows for packaging, shipping, receiving, unloadjng. handling. holding. aad management 

of wastes in a safe and environmentally acceplable mnnner. 

C- 12 

VES016314 
0 

0 

C-la(2)(1) Wastes with Handlin& and/or Storage Restriction s 

Heritage· WT!, Inc. 

OHD9&0613541 

Revision: 22 

November 10, 2009 

Handling and/or storage restrictions are necessary for those wastes that· are unusually toxic 

(meaning that there is significant risk to human health even when proper PPE is used), reactive, 

shoclc sensitive, temperature sensitive, or explosive yet not specifically excluded as a prohibited 

waste. Wastes with handling and/or storage =trictions are typically recognized as more difficult 

to manage. Restrictions in pacbging, conceotration, quantity, aodlor storage are designed to 

ensure safe handling and incinaati.oo. Table C-1 8(3), presents the waste codeslcbemicals and 

corresponding desaiptions of a few chemicals identified as restricted at the facility due to 

handling and/or storage m;trictioos. ln addition to those waste codes identified in the table, other 

materials may have storage restrictions but do not correspond to a single waste code. Examples 

include temperatll{e-oontrolled organic pero"ides, Class lA Flammables (defined by OSHA 

regulations as materials that have a flash point less than 73°F and a boiling point of less th1111 

I oo•F), MIHW, waste processed for off-site transfer or fuels blending, aod specific compressed 

gas and gas mixtures as described in section C-la(2)(iXd}. 

C-la(2)(i)(a) Off-site Transfer (Ihlrd Party) or Fuels Blending of Waste 

Other baodli.og and/or storage restrictions will be applied to waste s1reams that may be processed 

for off-site truJsfer or fuels bleoding. The Permittee will restrict water reactive waste streams, air 

reactive waste streams, inoQlanie metal-bearing liquid waste streams, and Class lA Flammable 

Liquid waste s1reams from being processed for off-site transfer or fuels bleoding. 

C-13 'JAN 1 5 ZOW 

OHIO EPA NEOO 

VES016315 
0 

0 

C-la(Z)(i)(b) Mixed Infectious :wd BazaTdou s Waste (MIHW) 

Heritage- Wil, Inc. 

OHD9&0613S41 

Revision: 22 

November 1 0, 2009 

The Permittee may manage (accept, process, stage, store, and/or treat) infectious waste that is 

also buanlous waste as specified in OAC Rule 3745-51-03, and thus requires the application of 

one or more hazardous waste codes to be managed as hazardous waste. Pre-acceptance and 

6.o.~ samples for MIHW will not be onalyz.ed at the facility. However, this wa.ste will be well 

chanlcterized by the waste geaerator and/or custQmer to ensure the waste received is as desaibed in 

the waste profile. The Penni.ttee will obtain a signed califi.cation from the gcncra!Or that 

documents the waste is MIHW. 1hc waste will be restricted in packaging, concentration, size, 

quantity, staging, and/or storage prior to incineration. Specific information regarding the 

management of Ibis waste can be found in C-2e( 4), Spmific Procedures for Ac.tq~ta c" of Mjxed 

Inftctjnus and Hazanious 'n'aste. 

C-la(2)(i)(c) Compressed Gas and Gas Mixtu.res (gases) 

The Pern:tittee is· authorized to .Jept and treat through the incineration system, specific 

compressed gas and gas mixtuRs. Please refer to Table C-l a(2)(i) for the compressed gases 

cuntnJ.Iy pemritted for acceptance and trealmeot at the fzcility. The compressed 811$CS are 

RC:eived in various types of tanker truclcs and are off-loaded and fed direclly to the incineration 

system (ldln) through Direct Organic Tanker East (bay 1, also known as E-Bay). E-bay is 

described in Section D, PmQ"SS Dcsaiptinn, of the approved Part B permit application. 

The Permittee is not authorized to store compressed gases on-site, but may stage the waste in 

approved staging areas as described in Section D. The Permittee may stage compressed gases up 

to 72 hours. Anticipated time over this period must be brought to the atteotioo of the Ohio EPA 

on-site inspectors. 

C-14 "JAN 1 1i 2010 

OHIO EPA NF..OO 

VES016316 
0 

0 

Heritage Thernull Services, Inc. 

OHD980613541 

Revision: 31 

Sepuonber 18,2014 

The geAC11110f will certify throu&h chemic:U ~~nalyses, malerial safety dotn sheets (MSDS), or 

other a~:ceptable dau that ~h waste shipment of collljl<CSSCd g45 received is accurately 

charncteriud by the waste profile for thot specirtc; gas mlx.ture. 

The ~a! maxlnwm quintity of gaseous ,..;_,,. trcoled will be U.Ditcd by the total volume of 

!\laste penni !led to be tre:>ltd by incineration. 

TABLE c .tll(l)(l) 

APPROVED COMPIU!SSED GAS AND GAS MIX'I'IJRBS 

• .... :--.·.-:--~;)· .: , ....... .. :·/'· .. ·~;.. \{r.•t.'\ ' :.;:,; . .'> .. ,:-;.:, · ••. •k • ~ •' ;l 

TelomerOas 

Chlorodifluorometbnne 

Trifluoromedlane 

Dlchlorotetrafluoroetllone 

1.1,1.2-Tetralluoroelbnne mixture CHFC-134A) 

1.2-Dicbloro-1,1.2-Trifluoroc:Olanc lliCFC-123a) 

DiciiJorodilluoromethuc 

C-18(2){11) Wut.:s wltb Tnatooen.t Ratridloos 

Tnentment restrictions are neoessruy for wastes thut CIJinot be lreated by inclnerotion, but coo be 

srored at the facility and la!et sent to an oltcmllle facility for proper tteatmen~ reclamation, Of 

reuse. EKltmples include some (1101 all) inorranlc wastes cbar.u:terized with 0004-0011 waste 

CXldes, asbestos, asbestos waste. and waste codes which require tteannent technolo,ies currently 

Ull3vailllble at the facility. 1"he5e was~CS miy be accep!ed by the [aciJity COl" storage and rt· 

manifesled to other approved llealment facllhiu. 

C·lS 

VES016317 
c 

C-la(l)[u)(a) Asbestos and Asbestos Waste 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

The Pennittee may accept and store asbestos and asbestos waste at the facility, but the waste will 

not treat the asbestos and asbestos waste on-site. Instead, the asbestos a.od asbestos waste will be 

transferred to an alternate treatmeot facility. 1be Permittee will follow applicable regulations, 

~~ , in regard to handling and storage of asbestos and asbestos waste. 

C-la(l)[J.h) Wastes with LDR Treatmmt Standard Reslriclions 

Wastes assigned federal hazardous waste codes of F032, F039, K043, and/or K099 are required 

to meet tbe LDR !Ieatment standard prior to !Ieatment at the facility, unless lite LOR treatment 

standard is combustion. Customers shall provide certified documentation that the waste cazrying 

(' tbe hazardous waste codes F032, F039, K043, and/or K099 meet the LOR treatment standards 

'-.-/ for dioxins and furans. This can be in the fonn of generator lcnowledge or analytical results. 

,.... 

C·l6 

.JAN I 5 2010 

OHIO EPA NEOO 

VE$016318 
EPA Hazardous 

Waste Number 

F032 

F039 

K043 

K099 

P009 

P065 

POSJ 

P105 

P122 

U017 

0 

Heritage - WIT, Inc. 

OHD980613541 

Revision: 22 

·November 10,2009 

Table C-1 a(3) - Restricted Waste Code/Restricted Chemical Table 

Type of 

Description of the Waste Restriction 

Wastewat= (except those that have not rome into contact with process LOR 

contaminants), pro= residuals, preservative drippage, and spent 

formulations from wood preserving processes generated at plants tbat 

currently use or have previously used chloropbenolic formulations (except 

potentially cross-cool2minated wastes that have bad the F032 waste rode 

deleted in accordance with §261.35 of this chapter or potentially crosscontaminated wastes that are otherwise currently regulated as hazardous 

wastes (i.e, F034 or F035), and where the generator does not resume or 

initiate use of cblorophenolic formulations). This listing does not include 

KOO 1 bottom sediment sludge from the treatment of wastewater from wood 

preserving processes that use creosote and/or peotacbloropheool. 

Leachate (liquids that have percolated through land disposed wastes) LOR 

resultiog from the disposal of more than one restricted W11Ste classified. as 

hazardous under subpart D of this part (Leachate resulting from tbe 

disposal of one or more of the following EPA Hazardous Wastes and no 

other Hazardous Wastes retains its EPA Hazardous Waste Nwnbet(s): F020, 

F021, F022, F026, F027, and/or F028.) 

2,6-Dicbloropbenol from the production of2,4-D LOR 

. Untreated wastewater from the production of2,4-D LOR 

Ammonium Picrate HIS 

Mcrcucy Fulminate HIS 

Nitroglycerine HIS 

Sodium Azide HIS 

Zinc Phosphide HIS 

Ben.zal Chloride HIS 

------· 

JAN 15 ?010 

OHIO EPA NFI10 

VES016319 
EPA Hazardous 

Waste Number Description of the Waste 

U023 Beozotricbloride 

U096 Alpla, Alpba-Dimethylbenzylbydroperoxide 

Ul33 Hydrazine 

U142 Kepone 

Ul60 Methyl Ethyl Ketone Peroxide 

U234 sym-Trinitrobenzcne 

HIS - Handling/Storage Restrictions 

LDR - LOR Restrictions 

0 

C-18 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

Type of 

Restriction 

HIS 

HIS 

HIS 

HIS 

ws 

HIS 

'JAN 15 2010 

OHIO EPA NEOO 

VES016320 
C-la(3) 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

Class 3-Acceptable Wastes Which Coot:aiD. Inorganic Materials 

The Permittee is permitted for an Inorganic Waste Treatment Operation, but these operations 

remain undeveloped. Tbe incinerator is capable of treating both organic and inorganic wastes. 

However, some inorganic wastes are prohibited from treatment technologies that use 

combustion. This section will discuss the Pennittee's current management of inorganic waste. 

Any future development of the Inorganic Waste Treatment Operation will affect this section. 

OAC Rule 3745-270-03 is the state land disposal rule that Prohibit dilution as a substitute for 

treatment The rule states that treatment technologies utilized to treat hazardous waste must 

perfonn treatment, and dilution does not constitute treatment lbis concept affects the use of 

combustion technologies when treating metal-bearing hazardous wastes. Tbe rule identifies 

r) specific hazardous waste codes for which combustion technologies are prohibited, !Jilless the 

\.. / waste can be demonstrated to comply with one or more of the criteria listed in the rule. The 

specific criteria and waste codes can be found in rule 3745-270-03 of OAC and the 

corresponding Appendix. However, wastes that are prohi.bited from incineration by this rule may 

be accepted, stored, and repackaged at the faality. The Permittee may ~e-manifest these wastes 

to treatment facilities that utilize treatment technologies other than incineration as the appropriate 

treatment and/or disposal option. 

c 

.JAN 1 5 2010 

C-19 

OHIO EPA NEOO 

VES016321 
(' 

\ . 

C-la(4) 

H eritagc -wn, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

Class 4 - Atttptable Wastes Which Con biD Orgllllic Material 

Organic wastes that are in a fonn that can be treated in a safe and envirorunentally accqitable 

manner, except for those prohibited or restricted in the prior sections, may be accepted for 

storage, processing, and treatment at the facility. Due to the V1lriability in the chemical and 

physical nature of individual waste streams accepted by the facility, The Pennittee has grouped 

wastes according to general waste categories. Attachment C. I lists the categories of waste, the 

hazard characteristics associated with each category, and the basis for hazard identification for 

the waste categories. 

As also described in Attachmeot C. I, a large number of wastes with varying characteristics are 

accepted by the facility for storoge and 1reatmcnt. A waste category may include any 

combination or all four characteristics (i.e., ignitability, corrosivity, reactivity, and toxicity). For 

/''\ this reason specific hazard characteristics could not be listed for each waste category. Prior to 

\.. / accepting waste for storage and treatment, the hazard characteristics will be determined for ea.cl:t. 

wtSte stream from a combination of generator provided information and analytical testing. The 

procedures used by the Permittee to assign hazard characteristics to each waste stream are 

desaibcd in section C-lb. 

{\ 

\ ... ' 

Dlle to the large number of hazardous wastes that are approved for acceptance, the list of waste 

CQdes was not incorporated in Attachment C. I. For a complete list of the waste codes that are 

accepted by the facility, please refer to the most current Part A Hazardous Waste Permit 

Application. 

Limitations in the composite waste fed to the incineration systems may also be impootd by other 

penni! conditions. Limitations include concentrations of chlorine, sulfur, and certain restricted 

metals. The general limitations reglllding tbe wastes that can be received and 1reated at the 

facility were determined during the initial trial bum and most recent Trial Bum/ MACT 

Olmprebeosive Performance Test (CPT) conducted in September 2003, December 2003, and 

April2004. 

C-20 'JAN 1 5 2010 

OHIO EPA NEOO 

VES016322 
0 

0 

· C-la(S) Class 5-Waste Codes Not Cuneotly Pennitted in Part A 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 24 

April!, 2010 

Any waste assigned a specific waste code 1hat is not cwrc:otly included in Part A of the permit 

application will not be accepted for treatment until all the applicable pemrits have been modified 

81 requi!ed by federal and state lawa. Request for inclusion into the faci.Ji.ty's pamita will not be 

made if 1 he waste cannot be packaged, accepted, stored, tnaiJaged, and treated in a safe and 

Cll.vironmentally acceptable manna. The profile approval system, desaibed in the next section, 

wi II be followed for all waste slleam.s. 

Varying concentrations of coostitncnts in wastes will not always result in the application of a 

specific waste cod.e. However, if the variation results .in the designation of a waste code that is 

rot included in the .Part A permit application, then the waste would be considered to have a 

beatrnent restriction, or be prohibillld, and be bandied accordingly. 

C-lb Waste Approval System 

'!be waste approval system was developed by the Permittee to ensure only waste that can be 

ICCCp!ed, baodled, siOred, and trealed in a safe and c:nviromnentally aoceptable lllallllCI' will be 

JIUlDa&ed by the filcility. The Qpp'Oval system OOIISists of two ~: (1) waste cllaracteri:wio 

prc-a=ptance poced=s (as desaibcd below) that oa:ur prior to storage and/or treatment of the 

waste; aod (2) wast.e charactt:rizstioo fingclprint prooednres that occur once the waste is received on 

site, but prior to acceptance of the waste by the facility. This approach to waste cbaractcrization and 

scceptance enables the facility to adequately identify wastes, conb:ol waste acceptance, define 

operational parametas for lwvlling waste, n>maoifest waste to another facility when appropriate or 

ne=ary, and CllSW'e proper treatment prior to land di.ooposal. This waste approval system only 

upplies to w.astes generated off•site. The system includes approval by 1he Environmental, Health, & 

Safety Department; Laboratory, and Plant Operations. 

C-21 

APR I 5 2010 

VES016323 
Heritage - WT1, Inc. 

OHD980613541 

Revision: 24 

Aprill, 2010 

Specifics reganling exceptions to the waste approval process are descn'bed in section C-1 b(2)(iv). 

There are occasions when a pre-acceptance sample may be obtained upon waste receipt ratha 

th.m in advance as pert of the profile process. Upon =cipt of the first shipment of the waste 

received at the filcility, a sample will be collected and analyzed for both pre-acceptance and 

~~ parame!e!S. Specifics regarding exceptions to the ~acoeptance sampling 

requirement = dcsa-J'bed in section C-lb(l). Conditional AppmyBL and section C-lb(2)(iv), 

Bxceptjons to the Waste APProval ProcesS. 

C-lb(l) Conditiooal Approval 

On occasion, the Permittee may include conditions for certain waste streams. The conditional 

approval may m andate how a particular waste stream is received, sampled, andler processed (e.g. 

conditions also include no storage for material such as class lA flammable liquids and 

tc:mpcr.lturc sensitive wastes). 

In some situations, the Penuittee may allow a conditional approval of a waste stream in order to 

obtain a pre-acceptance sample wb= the waste shipment is first received at the facility. 

When the waste stream first arrives at the facility, a wnple will be collected and analyzed for 

both pre-acceptance and fingerprint parameters. 

The Waste Approval Manager and the Wa.~e Acceptaoce Cbemist will review the analytical to 

cnsnre it is 1qxcsenlative of the waste as profiled. If the analytical and profile are compatible, the 

waste stream is approved for acceptance and the waste profile sheet is reviewed by the Permittee to 

ICmove the condition. 

C-22 APR 15 ZO!O 

VE$016324 
0 

C l b{2) Waste Char aderization P~aecept:auu hoeedures 

Heritage- WTl, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

A cluuacterization of eacb. waste stream is supplied to lhe Permittee by the waste generator on the a 

Waste Profile Sheet (WPS) as descn'bed in section Clb(2)(i). The WPS is used to provide brief 

descriptions of waste generating processes and physical cbaracteristics, identny applicable 

ous waste codes, and provide the basis for hazard designation for lhe waste to be treated. 

The goal of the WPS is to provide !he Permittee with information reqtrired to accept, lll8Dage, store, 

treat or dispose of the waste propciy. 

In addition to info11D81ion provided on the WPS, the Permittee requires the genemor to provide a 

repx=talive sample of the profiled waste stream, when possible. This sample, also known. as the 

pre-acceptance sample, is subjected to specific testing/analyses in accordance with section C2A OF 

the W.AP prior to shipment, Section C2, the Waste Analysis Plan. describes !he analysis required 

on all waste received from off-site facilities. The Permittee will utilize their on-site laboratory to 

perlonn the pro-w:cq>tance mandatory analyses. lf for some reason !he on-site laboratory cannot 

perlonn the required analysis, then an off-site labonltory will be used as discussed in section C2b. 

Representative samples will be Jdained until the profiles are approved or for 30 days, whichever 

oa:unfim 

Certain waste streams will not require a pro-acccptmce sample prior to waste ~pt at the facility. 

Miscellaneous Special Wastes (MSW), as described later in section Clb(2)(ii), are exempt from 

the pr&acceptance analysis. In addition, there ore occasions, when conditional approval will be 

given for tbe Permittee to collect !he sample of the waste upon anival. In this situation and upon 

waste receipt, a representative sample will be collected and analyzed for both pr&acoeptance and 

fingeqnint parameters. Please see section C-lb(2)(iv)(b) for additiooal informa on 011 waste 

streams not requiring a pr&acceptmce sample prior to waste receipt. 

C23 "JAN 1 5 2010 

OHIO EPA NEDO 

VES01 6325 
{\ 

\,. . Heritage - wn, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

Other supporting documentation may be provided to the Permittee during the waste 

cbaractc:rization phase. This docummtation may include material safety data sheets (MSDS), 

product ingredient illformation, and chemical analyses. lnfumlation of this type is required when 

waste is cha!acterized as a MSW. The Permittee, however, is in the practice of requiring generators 

to provide all documentation used by them to chamcterizc their waste. 

Facility n\anagcment is responsible for evaluating the waste cbaracterizalion documents provided 

by the generator. The evnlnation is CX>ncluded with documentation of the decision regarding the 

acceptability of the waste. Fecility management decisions are based on the following as 

appropriate: 

• Mano.gement methods available; 

r--. ' Conditions or limitations of existing permil, and regulations; 

\,. , · • Capability to safely manage the waste; 

c 

• WPS description of the process generating the waste; 

• WPS description of the i-bemical and physical properties of the waste; 

• Any additional documentation supplied by the generator, including infonnation that the 

waste is subject to the Land DiSpOSal Restrictions of 40 CFR 268 and OAC Rule 3745-59 

ns appropriate; 

• Results of pre-acoeptance analyses, as appropriate; 

• Results of supplemental analyses, as appropriate; 

• Management's teclmlcal experience and judgmcat; 

• Operational conditions or rcsb:ictioos. 

JAN 1-li 2010 

C-24 OHIO EPA NEOO 

VES016326 
Heritage - WTl, Inc. 

OHD98061354l 

Revision: 22 

November I 0, 2009 

The Pennittee will reject a waste stream dwing tbc pre-w:eptance phase fur the following 

reason(s): 

• The facility is not peunitted to accept, store, treat, or dispose of the puticular waste in 

question (e.g. the waste is ndioactive) as dcsaihed in section C.l(aXI), Prohibited Wastes 

• The waste exceeds restrictions as descn"bed in section C-l(a)(2), Restricted Wastes, unless 

such waste is to he sent to an off,site facility fur disposal or repackaging 

Tbe Pennime may reject a waste stream dming !he ~acceptance phase for the following 

reason(s): 

• Incomplete or outdated infonnation supplied by !he waste generaior. 

r'\ • J>re.acceptanoe sample analyses and WPS do oot agree and noo-<:enfonnance cannot be 

\.../ resolved with the gmcrator. A non-conformance would he defined as a significaDt 

difference in composition between the pn>accep!anoe sample and WPS description of the 

cill:mical and physical cbmicteristics (e.g. obvious difft:reooes sucb as waste solvent 

substilllted fur waste acid or tmc constinu:nts DOt reported on lhc WPS). 

• The facility does oot have tho capacity to treat, stnre, manage, or dispose of the waste 

stream in question. 

C-25 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016327 
0 

C lb(l)(l) Waste Profile Sheet (WPS) Description 

The WPS will provide the following information: 

Heritage - WTI, tnc. 

OIID980613541 

Revision: 22 

Novembec 10, 2009 

• Generawr Infurmation: In this section the generator or broker is identified, along with their 

USEP A ID Number, lhe site addrus, mailing e.ddnss, a contact name, and phone nwnber. 

• Shipping. Processing, and Handl.iDglnformation: [n this secli.on a brief desaiption of the 

waste generating process(cs) is gi\IQI, a brief description of waste (ie. !he name of the WMe 

used by the generator), approximate quantities of the waste to be managed, and the type of 

packaging I oontainen that wiU be utilized when shipping the waste to the facility. 

• Waste Code Information: ldcntificotion of all applicable federal and state hazardous waste 

codes perOACRule 3745-51. . 

• Physical Property lnfotmation: Physical property information including, but not limited to, 

the free liquid range, pumpability, affect of beat on ma\Crial pumpability, viscosity, flash 

point, boiling point, pH. 

• Restricted I Proluoited Waste lnfonnation: A list of prohibited and restricted waste will be 

listed on the profile to provide easy identification of waste streams with these 

clwacteristics, which include: Asbesms, Carcinogen, Dioxin, Explosive, Compressed 

Gases, lnfeclious Waste, MIBW, Oxidiza", PcB, Pyropboric, Radinadive, Sboclc Sensitive, 

and Strong Odor. A gcnezator' s indieatioo that one or more of these properties apply does 

not necessarily mean the waste is prolnoited, ralber it triggen facility persoDDd to eval021e 

acceptance and processing aiteru.. This evaluation, however, may result in rejection during 

the reyiew prooess. Olber categories may be added as deemed necessary by facility 

management 

• Waste Composition lnformation: hlfOrmatioo on the waste composition must be provided. 

This infurmati.on will primarily consist of chemical names and percentage ranges by weight 

in the waste stream. For some waste streams, however, it may be necessary to usc generic 

terms such as inert materials (meaning non-regulated chemicals that cannot be specifically 

identified), soil, debris, sludge, etc. 

C26 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016328 
0 

Heritage - WTl, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

• Transportation Information: If the waste is a Department Of Transportation (001) 

hazardous material, the DOT shipping name, hazard class or division ID Number, 

Packaging Group (PG) and xeportable quantity (RQ) will be identified. Because waste 

streams can be variable, the DOT shipping information may deviate from the DOT shipping 

information on the profile. 1bis deviation, however, must be ~nsistent with the chemicals 

8lld ranges provided in the composition section of the profile. 

The Pennittee reserves the right to request information in addition to that listed above. The 

information presented in this section will be a minimum requirement to eomply with this plan. 

C.lb(2){l1) . Miscellaneous SpecW Wastes (MSW) 

Certain materials will not be sampled because: (1) they are of such a nawre that their contents arc 

suflicientiy known with reliable chemical and physical detail that sampling 8lld analysis is not 

wananted; (2) are of such physical natute that a sample which accurately represents t,he waste 

would be CJttremely difficult to obtain; (3) present extraordinary health 8lld safety bazazd.s. 

Wastes meeting the above listed aiteria are considered an MSW. For these types of wastes, preacceptance samples arc not required, however, the generator wiD supply the Pennittee v.ith 

suffici.ent chemical and physical characteristic infurmation for proper management of the waste, as 

discussed in Section C-lb(2). Likewise, when any MSW arc received at the facility for stor.tge or 

treatment, they wiD, when appmpriate, be visually inspected. 

The following lists categories of MSW based on the above listed eri1cria. 

JAN 1 5 2010 

C-27 

OHIO EPA NEDO 

VES016329 
,.--... 

\ ' ' ··· 

c 

c 

Heritage - Wrt, Inc. 

OHD980613S4l 

Revision: 22 

November 10, 2009 

Category 1: Waste whose contents are sufficiently known, typically through a MSDS, aoalytical 

supplied by the generator, and/or other information that sufficiently documents the 

waste's cbaraaeristics, lllld include: 

a. Commercial products or chemic:als that are off-specification, oll!datcd, slightly 

contaminated, banned, discontinued, or otherwise detmni.ned to be unusable. A MSDS 

must be made available for the prodlld or chemicals and . include concentrations of 

contaminants when applicable.. 

b. Consumer products are products which are readily available in commerce for houscbold 

use, andlor.wbich may be individually purchased and discarded by the general public. 

These types of waste are typically sbipped.in the original paelc:aging. Examples include 

nail polishes, paint , health care products, cleaners, pesticides, etc. Ths category may 

include containers packed within another container; but the number of products 

identified on the WPS is lim.ited to seven. Profiles with grealCr than seven different 

products per WPS will be managed as a Loose Pack, a.S discussed below. MSDS may 

be available. 

c. Loose Packs. These are a sulx:at.egozy of COlllDlCicial producls that c;an be fi:om 

industrial processes or possess unique l=ards that m;uire special paclcaging Industrial. 

process materials includ~ those that are to be discarded in the original paclcaging or 

poUR:d together into a larger container. There is no inherent environmental benefit in 

removing lhe waste fi:om its original container. The original containers require disposal 

and are not present to provide secondary containment. Examples of loose packaged 

material include solvents, acids, bases, paint cans, cleaners, oils, etc., and wastes 

generated dnring household hazardous waste collections. An inventory sheet is not 

required because the WPS provides a complete description of the properties, 

constituents, and ranges that are occeptnhle. 

JAN J 5 2010 

C-28 

OHIO EPA NEDO 

VES016330 
c 

' / 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

Consumer materials that possess unique hazards may best be addn:ssed through 

=trictive J"'clc•ging For these loose .packs, inm:r containers and/or special storage 

may be used by the facilily to be protective or to meet operational constraints of the 

facility. The packaging and perhaps the actual hazards of the material may preclude 

pre-acceptance and fingerprint analysis Ot" other stipulations as diSOJSsed later in this 

plm. Examples include those types ofw-.ste listed in sec6on C-la(2) of this document, 

whic:h discusses Restricted Wastes. 

d. Residues and debris from the cleanup of spills or releases of a single chemical substance 

or commercial product or a single waste wbicb would otherwise qualify as a MSW. 

e. Waste produced fiom the demolition or dismantling of industrial process equipment or 

facilities contaminated with chemicals fiom the process. 

f. Compressed gas or gas mixtures generated fiom a specific process that is well known 

and stable so as to generate a gas or gas mixture wbich is consistent in composition and 

well .characterized in nature. The information used to characterize the waste will be 

based on chemical analyses or MSDSs. 

JAN 1 5 2010 

C-29 OHIO EPA NEDO 

VES016331 
Category 2: Waste that cannot be repres=tively sampled: 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

a. Debris and personal protective equipment that are impraciical to sample, and difficult to 

obtain accurate and representative analysis. This includes rags, gloves, boots, and 

disposable gannents. 

b. Lab pack. Under this category, lab packs shall be defined as an outer container Wlit that 

contains inner containers of different chemical wastes intended for treatment'· or 

disposal. This shall include such multiple-waste containers generated from laboratories, 

research facilities, and other commercial and industrial activities where chemical wastes 

are generated. Because of the multitude of chemicals that can be contained in the 

various small containers, the WPS does not include any constituent information. 

Instead a detailed packing inventory sheet, which provides a list of the inner containers 

and their contents, is prepared for each lab pack container. The inventory sheets for 

each lab pack must be individually evaluated and approved prior to acceptance. A copy 

of the inventory sheet must accompany each lab pack as described in section C-2e(2)-

Specific Proced.ures for Acceptance of Lab Pack Shipments. Lab paclc does not include 

"Loose pack." 

c. RCRA empty containers of waste commercial products or chemicals. This category 

applies to a portable container which has been emptied, but which may hold residuals of 

the product or chemical. Examples of portable containers are tanks, drums, barrels, 

cans, bags, and liners. 

JAN 1 & 2010 

C-30 

OHIO EPA NEOO 

VES016332 
0 

Heritage -wn. Inc. 

OliD980613 541 

Revision: 24 

April I, 2010 

a. This category includes wastes which present extraordinary health and safety hazards to 

the sampler or laboratory technicians; examples include those waste listed in section Cla(2) Restricted Wastes. 

b. Wastes th81 pose an UDUSU8l sampling or analysis problem due to low odor tlm:shold 

cornpoo.ent(s) in lhe WBSte. In order to be COMideRd a MSW due to a low odor 

threshold, the odor properties of the components causing tbe problem must be well 

documented. 

C-31 APR 1 5 ZOJO 

VES016333 
c 

0 

C-lb(2)(W) Waste Approval l'rcx:eu 

Heritage- WTI, me. 

OHD980613541 

Revision: 24 

April!, 2010 

The profile approval process for wastes generated off-site coosists of four steps: (1) WPS review, 

(2) supplemental physical/chtmical analyses if necessary, (3) waste app<OVal by !he facility, and (4) 

waste IIPJIIOval adalowledgrm.em. This section discusses 1he details of these steps. The wiS1e 

approval process for lab packs will follow acceptllnee procedures as desaibed in section C-2c(2). 

Exceptions to !he waste approval process arc dcsaibcd in sectinn C-1 b(2)(iv). 

(I) WPS Review - The waste approval group and a designated representative of 1he 

laboratoty, incinerator oper-.ttions, and Environmental, Health, & Safety dep811mcnt will 

each coni!.uc:t an evaluation of the data contained in 1he generator's WPS, which includes 

1he pre-acccpCancc analytical results if available. Each department will examine the 

III:C8S of the Wl'S tbat are pertinent to their specific area. If there axe inconsistencies in 

the infonnation provided in the waste profile, a conec:ted profile will be rtquirod prior to 

final approval. Waste approval fur each department will be documented on the approval 

p~ of the Wl'S. Overall the filcitny managancot is responsible fur ensuring all 

infuonalion is reviewed aod evalua!Cd fur proper management accordina to regllialions, 

permit conditions, and opentiog procedures. 

The l.aboratocy rqxese:otalive is primarily responst"ble for reviewing analytical data for 

correctness. They are also responsible for verifying results wheo questioned by the 

generator or o1her facility rcpreseotatives that review the profile infortnal:ion. Tho 

laboratoty eosures that the proper test methods are utilized in accordance with 

regulations and this section of the permit application. 

C-32 APR 1 5 2010 

VES016334 
Heritage • WTI, Inc. 

OHD98061354l 

Revision: 22 

November I 0, 2009 

The health and safety representative is flZPODSible for reviewing the profile for safe 

storage and handling requirements, assigning the proper HMIS (Hazardous Material 

Infonnation System) information, determining the proper personal protective 

equipment, and providing fire extinguishing infoJ:mation. 

The environmental representative is responsible for reviewing the applicability of the 

EPA ID number, and any exclusions, ex<mptions, and variances. Their review will 

ensure that an permit requirements, an applicable regulations, and all reporting 

requirements are being met during the profiling process. 

The incinerator operations representative is typically fulfiUed by someone from the 

waste approval group. This person is responsible for Jcnowing the facility's waste 

management capabilities. When questions arise about handling specific waste streams, 

it is the waste approval group's responsibility to communicste with the Operations 

Manager and I or the Materials Processing Manager and determine bow to proceed. 

The waste approval group reviews the entire profile for consistency, including the 

process generating the waste with the chemical constituents, the analytical results, the 

assigned waste codes, chemical names, and. the physical properties. They also identifY 

prohibited and restricted waste streams and ensure proper management, wbich may 

include special packaging or processing, or in some cases, the denial of a waste stream 

submittal. 

JAN I 5 2010 

C-33 OHIO EPA NEDO 

VES016335 
Heritage- WTI, Inc. 

OHD980613S41 

Revision: 24 

Aprill, 2010 

(2) Supplemental physical/cbemical anal~ can be pctformed by the facility's laboratory if 

needed (see Supplc:mcmal ADalysis, section C-2a(3)). The results from these analyses 

will be included as dalll in thc evaluation of the WPS. 

The Pennittee will direct qua;tions that may arise during the waste approval process to 

c1icnt reprc:sentalives designa1ed by the firms requesting tbc sennces of the facility. The 

facility's customer serviee personnel will be responsible for documenting any 

discxepancies and then work with the client representative to m.ake corrections. The 

. client represemative must change or IWlhori.zc any changes to the WPS. These changes 

will be documcntod by thc facility and kept to resolve questions until the profile is 

approved. 

(3) Waste Approval - The review and subsequent approval by facility personnel will be 

c!ocumcntcd on the approval page that becomes part of the WPS documents. 

(4) Waste Approval Acknowledgement- A letter to the clienllsenerator will be sent th4t 

spcci.fies that the Pemtittee ~ accept the waste for incineration or management within 

the client-gmerator ccn!Iact aud facilitypemlit specifications. This letter will document 

waste approval acknowiedgemcot md aceeptance of the waste by the facility. 

C-34 APR 1 5 Z010 

VES016336 
C-lb(2)(1v) Exceptions to the Waste Approval Process 

C lb(2)f1V)(a) Reserved 

c 

C-35 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 24 

April I, 2010 

APR 1 5. 2010 

VES016337 
•• 

• ""RESERVI!lD" 

C-36 

Heritage- WTI, lnc. 

OHD980613541 

Revision: 24 

April!, 2010 

APR 15 ZOIO 

VES016338 
• 

• 

• C-37 

Heritage - WTI, Inc, 

OHD980613541 

Revision: 24 

April I, 2010 

APR 15 ZOIO 

VE$016339 
• 

•• 

• C38 

Heritage • Wfi, Inc . 

OHD9806!3541 

Revision: 24 

Aprill,2010 

APR 15 2010 

VES016340 
• 

• 

• C-39 

Heritage- WTl, me . OHD980613S41 

Revision: 24 

April I, 2010 

APR 15 201D 

VES016341 
C· 

('; 

\.. ,: 

c 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 24 

April!, 2010 

C-lb(l)(JV){b)Wute Streams not requiring a Pre-Aeceptanc:e Sample Prior to Waste 

. Receipt 

Cutain waste streams will not require a pre-acceptance sample prior to waste approval. Upon 

receipt of the first shipment of the waste at the facility, a sample will be collected and analyz.t:cl for 

bolh pre-ea:eptanc:e BD<i fingapriDI parameters. WPS llpprOVed in accxm!anoe with Ibis section 

diffc:c from waste streams 'approved under section C-1 b(l). Types of wastes considered Ulldcr Ibis 

section are listed below. 

Clb(2)(Iv){b)(l) Third Party Waste 

Third party waste is a lam used to describe waste tbat can be stored at tho facility BD<i may 01: may 

oot be treated by the Permittee. Third party wastes may be stored until fbcre is a sufficient quantity 

to be transported off-site to another facility for storage, treatment, recycling, reclamation, and/or 

disposal. 

Third. party waSte docs not require analysis of a ~ce sample until the waste is received 

at the facility. Once the first shipmCill has been received at the Pe:nnittee's facility, a sample is 

collected and analyzed for both pn>-acceptance and fingerprint parameters. Please see section C 

2a ond Attachments C.2 and C3 for pre-acceptance and fingerprint pln!DCten. 

The Waste Approval Manager or Was!c Approval Olemist will review the completed analytical to 

e:nrure it is representative of the Wa51c as profiled. The profile may be revised as necessaiy in 

accordaoce with section C-lb(2)(v), Revision Proce!lll(eS. In the event the Permittee decides to 

incinerate third party waste, the Permittee will review the WPS and associatrd analytical and will 

reviae the profile u oeeessary in accordance with section C 1 b(2)( v), Revisjon Pmsslprrs. 

Third party wilSie may be stored in any of the permitted waste storage areas in aecordaoce with 

applicable regulation (s) un.til it is shipped to an alternate facility. 

C-40 

APR 1 5 2010 

VES016342 
r\ Heritage· WTI, Inc. 

\.. .! OHD980613541 

C lb(l)(v) Revision Prowbues 

Revision: 24 

April!, 2010 

Any change to the WPS is reconled on a revision form. Revisions may include, but are' DOt limited 

to, changes in waste composition, waste charadcristios (e.g., pH or water contmt), waste gcncmlion 

p10ccss, waste codes, and otb=. Facility pc:ISOnoel oomplete the fonn after interaction with a 

customer. The fonn is submitted tn the waste approval group upon completion. The Waste 

approval group reviews the changes.. Any questions are forwarded tn the customer service . 

pcnonne~ who in tnm COillaCI. the eus10mer for corredions aDd cJarifjodjon. 1f the revision is 

complete, the waste approval group approves the revision. The he:allh and safety IqucseuWive 

must re-evaluate the HMJS and PPB information if new chemicals or properties are i.nboduoed. 

Typically, tbe health and safety representallve rc-evaluates all revision n:quests except for those that 

modify container types and/or waste code. Approval by the health and safety rqm:sentalive is 

designated on the revision foxm after the n>evahullion is complete. 

0 . Waste analysis will need to be repeated if the prooess generating the waste changes or the 

\.,j composition of the waste changes. Revisions will be submitted for approval if significant waste 

lundling or characteristics change (e.g., if it is significantly different in c:ompositioo ·from 

iDformation shown in pre-acceptance papc:rwodc). Spcci:fic examples are: 

C· 

• adding waste codes 0001, 0002, ar 0003; 

• if the changed waste can no longer be processed the same way (ie., if it can oo longer be 

dumped intn lbe bulk solid waste la!lla); 

• if the cbangcd waste can no longer be sampled (a oon-MSW becomes a MSW); 

• an.ypublio-sa!Sitive waste stream changes. 

C41 APR 16 2010 

VES016343 
Heritage- WTI, Inc. 

OBD980613S41 

Revision: 24 

Aprill, 2010 

In addition, an approved waste stream profile for generator's waste may be oopled to a new waste 

stream profile for the same geoeralor onder two specific conditions. This may be done only for the 

foD.owing; 

1. The gcocrator wishes to seod the waste in a. different container type that possibly 

changes the handling procedUI"es, but the waste itsdf docs not change; or 

2. The genera.tor has an approved waste stream profile that the generator would like to 

divide into two or more waste stream profiles for the generators internal ll:aclcing 

JliiiPOSCS only. 

A copy-over of an· approved profile cannot be acalcd on profiles which have been pr<Mously 

OO:..Utionally approved (approved with specitic conditions). Copy over of approved profiles cannot 

be created on profiles for MIHW. Copy-over profiles will be reviewed and approved internally by 

,......., the designated departmenlll. 

'--' 

Ci 

Approved profiles may be woopicd"' bY the Pennia,., using the copy utility in the profile software in 

otdcr to =tc new profiles for different g=entors. These new profiles will be reviewed and 

approved in accordance with section C-lb(2)(tii) of this document. 

C-43 APR 1 5 ZOIO 

VES016344 
() 

C-lb(2)(vl) Waste Prome Copy-Over Proced11res 

Heritage - WTI, Inc. 

OHD980613S41 

Revision: 24 

April I, 2010 

There are specific situations whm: the Permittee may copy-over an approved waste profile sheet 

(WPS) to aeate additional profiles. The eopy-over of the approved waste profiles to other gc:ne:ator 

locations would only be pertixmed if aU four of the following conditions are met: 

I. The waste stream prolilc is a cum:nt!y approved waste stream profile; 

2. The nt:W waste stream profile is for the same genc:rator as the approved waste stream 

profile, just a1 a different site to include customer sites resulting in different US EPA ID 

numbers; 

3. The new l.VSSte stream profile is-identical to the approved waste S1ream profile; and 

4. All additional requiremects of the approved waste stream profile, sucb as condition.• 

andfor special handling instructions, are applied to the ~ waste stream profile. 

C-42 APR 1 6 2010 

VES016345 
0 

Clb{3) Waste Cbancterizalioo Fingerprint Procedures 

Heritage- wn, Inc. 

OHD98061354\ 

Revision: 22 · 

November 10, 2009 

When waste shipment deliveries arrive at the facility, the shipment, iiS manifest(s) nod land 

disposal restriction documents will be reviewed for compliance with the scheduled delivery 

information. This will be ~onned before the initiation of any further activity. If no significant 

dis=pancies are found, bulk solid and bulk liquid dclivaies will be sampled end the "Fingerprint 

Analysis" perfonned and approved before the shipment is directed to an unloading station (c:><cept 

as noted in soction C-1 b(2)(ii), these lllAterials, when appropriate, will be visually inspected). 

The fingerprint sample is analyzed i.o. accordance with SCI(;tion C-2, :Wast• A nai)(Sis Plan, to provide 

specific data used to compare the waste received with the waste described in the WPS and on the 

manifest In addition, the fingezprint analysis and paper review ensures the waste is handled, 

stored, and treated appropriately on site. 

On occasion as desaibe in C I, a pre·acceptSnce sample will not be taken until the shipment of 

waste anives on-site. This sample, takeo upon receipt of the first shi.pmenl, will be used for both 

the ~ce and fingerprinl. analysis. The analysis will be used to compare the waste 

rteeived with the waste desa:ibed i.o. tho WPS and on the manifest for confoiJ'Oity. 

lf the laboratory detcnni.o.es the buUc shipment is acceptable, it will be unloaded, the manifest will 

be signed, end the IJUCk will be released from the site. If the laboratory determines the bulk waste 

is not aoccplable at the facility, the shipment will not be unloaded. The appropriate i.o.fo1JI181ion will 

be recorded as a discrepancy, if applicable, on the manifest. The generator will be contacted to IIy 

to tcSO!ve the discn:pancy. If resolution is not reached, the waste may be rejCI(;!ed from the facility. 

C-44 JAN 1 5 2010 

OHIO EPA NEDO 

VES016346 
c 

c· 

Heritage • \Vfl, Inc.. 

OHD980613541 

Revision: 22 

November I 0, 2009 

CotUi.oer deliveries that mnlrit oo sigJli.ficant disaepancics will be unloaded and cowrted. lf no 

marifcst dlsaepancics are idmtified 8l that time, the manifest will be signed and the tnu:k will be 

released from the site. The containers will be sampled, (sampling JR,quency discussed in seclion C2d), and placed in storage UDtil the analysis is complete. Wasre streams arc not released for 

incineration until the lab analyses are approved. If the laboratory believes the waste is discrepant, 

then the containers are not released. The generator or their agent is contacted ro resolve the 

disaq>a.ncy. Tbe resolution is ~ changes are made when necessary, and lhe containe.s 

are released· for processing. lf it is determined that the waste is not acceptable, the appropriate 

information will be recorded as a discrepancy on the manifest, and the generator will be informed 

that the waste may be ri.,iecled the facility. · 

In addition, a Land Disposal Restriction (LOR) fo= from the generaror or TSD must accompany 

aU waste shipments that are subject t.o or prohibited under the Land Disposal Restrictions of OAC 

Rule 3745-59. This' form must identify the following: (I) all applicable USEPA hazardous waste 

codes associated with the waste; (2) all applicable tteatment standards and land disposal 

prohibitions associaled with the waste; (3) any applicable analytical data; a.od ( 4) the hazardous 

W1Ste manit'est number. WaSte streams that have beeo trea1cd, exempted, gnmted a Vllriance, or 

me'! the appropriate standard or prohibition without treatment, must be certified on the fonn as 

having met the appropriate treatment standard, prohibition, exemption or variance. In addition, any 

awlicable analytical data or reference to such data or documentation must be included in 

~rdance with OAC Rule 3745-270. A one-time notification may also be used io accordance 

will OAC Rule 3745-59. 

Control procedures used to ensure incoming waste streams are the same as pre-approved waste 

stJeams are presented io section C-U(l), which describes this process in greater delll.il. The 

acccplllnce of lab plldc shipments foUow similar procedures, but include a more rigorous routine to 

CXDfirm that incoming wastes meet specific guidclines. Section C-2e(2) describes the procedures 

for acceptance oflab packs. 

C-45 JAN 1 6 2010 

OHIO EPA NEDO 

VES016347 
() 

0 

/\ 

\ .... · 

C l t J!acllity..Specific Chemical & Physical Analyris Requirements 

C·lc:(l) Co11tainerized Waste 

OAC Rules 3745-50-44(C){l}(b)(i), 3745-S5-75(C) 

Heritage· WTI,lnc. 

OHD980613541 

Revision: 22 

No..,embtt 10, 2009 

Not Applicable. At this site, all ~ waste is stored only where seoondary tODtaimnent is 

pzesc:nt; therefore there= cwrently no additional analysis requiremeol3. 

C-1<(2) Waste in Tank Systems 

OAC Rules 3745-5S.91(B){2), 374S.55-92(A){2) 

The facility tanks h~ve been &signed and subsequently assessed to be able to manage the following 

types of waste: 

Otganic liquids 

C>r(pmic sludges 

Organic solids 

Inorgamc liquids 

Inorganic sludges 

· • Inorg;uric solids 

The bazan:l charactA:ristics for these wastes are presented on Attacbment C.l. 

Before placing mste in any of the tank systems, certain hazard cbaracteristics, xeactivity, and 

compatibility tests will be performed by the Permittee laboratory using the test methods described 

in section C2a. Of these tests, tbe results from the pH, ~ctivity screcos, and compatibility tests 

assist in determining dmacteristics that would affect tank storage. The results of these tests will 

assist in detmnining whether waste= compatible with the tank materials, and, if applicable, other 

wastes already stored in the tank. 

C-46 JAN 15 7010 

OHIO EPA NEDO 

VES016348 
0 

('. 

' .· 

Heritage- WTl, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

Tests perfonned on the incoming waste include pH, cyanide screen, su16de screc:n, oxidize.-screen, 

add mix, alkali mix, and water mb. reactivity screen. Two compatibility tests, Waste Mix and 

Differential Scanning Calorimetry (DSC) or equivalent method/test, are perfonned on bulk liquid 

wastes during the fingerprint phase if the waste will be commingled with olhc:r wastes within the 

tank system. These test are completed to identify any waste compatibility issues due to mixing 

waste prior to off-loading 1he incoming waste into the tank system. 

MIHW will not be placed into any tank system at the facility. Treatment residual (slag) from the 

incineration of MlHW that contains waste not combusted to ash or slag, except for metallic, glass, 

and ceramic items, may be placed in the Bulk Solid Waste Tanks for reprocessing. Specilic 

information regarding the management of MIHW can be found in section C-1 a(2XiXe), Miu.d 

Infectious and Hazandaus Waste, and in section C·2e(4), Specific f>mmlnres For Act:qJtanc.e of 

.MixNI Jnfectjous and ijmrdons Waste. 

Fer containerized waste (waste in drums and totes) scheduled for transfer into the taDk syst= 

through ihe pumpout statiims or the e:xtrud..-, an oxidizer reactivity s~ and a waste 

compatibility screen is completed before any waste is traosfcrrod. 

O!ganic solids and inorganic solids may be placed in the Bulk: Solid Waste Storage Tanlcs, which 

do not have secoodary containment Before placcmcnl of the waste into this tank system, a free 

liquid test (Le~ Paint Filter Test- USEP A Method 9095 • SW-846) is performed Waste failing the 

the liquids test, i.e. containing free liquids, will not be placed in the Bulk Solid Waste Tanks. 

C-47 

.JAN 15 2010 

OHIO EPA NEDO 

VES016349 
c 

0 

C-lt(3) Waste in Piles 

OAC Rules 3745-50-44(C)(4)(b) 

Not applicable. The facility does oot manage waste in waste piles. 

Cle(4) Landflllcd Wastes 

OAC Rule 3745-57-14 

Not applicable. The facility does not manage waste in an on-site landfill. 

C l t(S) Wastes blcinentcd an.d W astu Uoed iD PerfoODaDce Tests 

OAC Rules 3745-S0-44(C)(8)(cXI),(ii),(vii), and (vihl 

Heritage- WTI, Inc. 

OHD9806135-41 

Revision: 22 

November I 0, 2009 

Refer to section C-1 of this document fur detailed chemicalllld physical desaiptioos of waste to be 

processod at the facility. Future perfonnancc tests will be conductl:d in accordance with Ohio _EPA 

and US EPA standards and regulations cum:nt at the time o{the test. Perfonnance test plans will be 

sub~tted to the Obio BP A for review and approval prior to the testing event A:rly new analyses 

required by future Trial Bum Plans will be added to this plan as necessary to fulfill applicable 

re<{Uircments. Re(a-to section D-5 of the Part B permit application regarding pet fo1momce tests. · 

C-48 JAN 1 5 2010 

OHIO EPA NEDO 

VES016350 
c 

0 

Clt(6) Wastes to be Land Treated 

OAC Rule 374S-50-44(C)(S)(d) 

Not applicable. The facility does DOt perform any on-site land treatment 

Cle('J) . Waste to ML1ceUaoeous Treatment Units 

OAC Rule 3745-S0-44(C)(9)(d) 

Heritage - WTI. Inc. OHD980613541 

Revision: 22 

November I 0, 2009 

The faQJity is permitted for aiDe m.i.sa:IIIIQI'X)us ooits: two cxtrode:s, a pusher, two filter presses and 

four shredders. 'lbele units paiono a physical, pn:lreall:nent function. All wastes from these units 

are incinerated as a final treatment mc:tbod; th.nfore, a dcmons1ratioo of the effectiveness of the 

treatment required by OA.C Rule 3745-50-44 is not required. See Section D for desaiptioos of 

tbeso miscellaneous units. The facility also has an isocyanate solidification process. The Standard 

Operating Procedure for this process can be found in Attachment C.ll. 

MIHW will not be placed into any miscellaneous uoit (filter press, sbrcddel:, extruder. pusher) at the 

facility. 

C-lt(8) Waste Used In Lieu of Produt~ 

OAC Rule 3745-Sl~l (EXl)(b) 

In specific situations, the Permittee may substitute waste for products to be used at the faci.lity. 

Wastes (hazardous and non-ba2ardous) used in lieu of product are e;u:mpt in accordance with OAC 

Rule 3745-51-02 (EXl)(b). Depending upon the specific situation, the Permittee will set conditions 

and parameten; that must be met before the substitution can occur at the facility. Each situation will 

be evaluated on a case-by-case basis. 

C-49 JAN 1 5 2G10 

OHIO EPA NEDO 

VES016351 
c 

Heritage- WTI, Inc. 

OHD9806l3541 

Revision: 22 

November I 0, 2009 

C-lc{S)(i) Non-Hazardous Wastewater 

The Peanittec may substilll!c non-hazardous wastewater gCDcrated off~tc for lll1lllicipal water in 

designated units and processes at the facility. When oon·bazludous wastewater is received at the 

facility for usc as process water, a preacccptance sample will be taken prior to acceplal:lee. The 

sample will be analyzed to verify the acceptability of the wastewater for utilization as process water 

ud to ensure the existing gcnecal wastewattt treatment system can a-eat the wastewater, if 

rucessary. The Pe:anittee bas established the following limits for the acceptance of non-hawdous 

wastewater to be used in lieu of municipal water: 

Volatile Organic CompoWlds (VOC) 

PH 

Metals 

Total Suspended Solids (TSS) 

Total OrganicCatbon (fOC) 

Mercury 

S.lOOppm 

> 2.0 and < 12.5 

Below RCRA Regulatory Limits 

Established After Testing Is Completed 

Established After Testing Is Completed 

<0.2PPM 

The Peanittee will also conduct preacc:cptmce anal)'l>is for brominated compounds and iodine. 

Although there are no pe:mit limits associated with these cherrucals, The Permittee has discovered 

tllat UDder specific cooditions, these chemicals in the 5a!'bber water will produce a discoloration in 

the stack plume. Consequently, The Pc:mlittee will monitor the presence of brominated 

compounds and iodine and use Ibis information when utilizing non-hazardous wastewater as male~ 

up water in the Four Stage Wet Scrubber. For more information reganling the affects of 

brominated compounds and iodine in the Four Stage Wd Saubber, ;;ce section D-5c(7)(a) PiDk 

Pbtme Suwressinn 5¥'lcm 

C-50 JAN 1 5 2010 

OHIO EPA NEDO 

VES016352 
0 

0 

.Heritage - \VII, Inc. 

OHD9806L3541 

Revision: 22 

November l 0, 2009 

Upon receipt and acceptance, che non-hazardous wastewater is transferred to W-5. The no'?-

hazardous wastewater will be stored in Process Water Holding Tanks W-4 and W-5 (iliesc tanks 

are discussed in section D-9a). Prior to the transfer to W-4, samples will be talcen from W-5 and 

analyzed for VOC, TOC, TSS, and mercury to determine if 1he wastewater requires treatment in 

the general wastewater treatment system. lf ilie Pennittce is unable to obiain and analyze a 

s21Dple from W-5 prior to t.b.e water being transferred to W-4, the Pennittee will obtain and 

analyze • sample for TOC, VOC, TSS, and Mercury from W -4 prior to usc as process water. 

The existing general wastewater treatment system is capllble of treating the wastewater for 

suspended solids and organics lhat may be at values~ than the limits desaibed ahove. 

Please refer to Section D, !>rnrn• Qe;cription, for more infonnation regarding the use of nonhaz:ardous wastewater in lieu of municipal water. Specific sections of the permit application that 

contain information regardi.og the units and processes where non-hazardous wastewater can be 

utilized include, but are not limited to, D-5o(2Xb), D-Sc(7)(a), D-9a, and D-10b(2Xb). 

C l c(9) Third Party Waste 

TIWd party waste is a term used to desc:ribe v.oaste that can be stored at the lilcility and may or may 

not be 11-eated by the Pennittce. Thiid party wastes may be stored until there is a stlflicient quantity 

to be traosported off-site to another facility for storage, treatment, recycling, reclamalion. and/or 

disposal. 

Third party waste does not rcqwre analysis of a pre-acceptance sample until the waste is received 

at the facility. Once the first shipment bas been received at the Pennittee's facility, a sample is 

eol.le<:tcd and analyzed for both pre-acceptance and fingerprint parameters. Please see section C2a and Attachments C.2 and C.3 for pre-acceptance and fingerprint pw-.uneters. 

Third Party waste may be stored in any of ilie permitted waste storage areas in accordance wilh 

applicable regulation (s) unliJ it is shipped to an alternate facility. 

CSL "JAN U 2010 

OHIO EPA NEDO 

VES016353 
r · 

\.. .' 

c 

Heritage- W11, Inc. 

OHD980613541 

Revision: 25 

Apri123, 2010 

The Wasre Approval ~or Waste ApproV11 ~will review the analytical to enswt it is 

.representative of the waste as profiled. The profile may be revised as necessary in accordance with 

the Section C. In the event the Pennittee decides to incinerate third party waste, the Permittee will 

review the WPS and associated analytical and will revise the profile as necessary in 8CCOidance wi1h 

section C-lb(2Xv), RevisionProcec!wes. 

C·2 WASTE ANAI,YSIS PLAN 

OAC Rules 3745-50-44(A)(3), 3745-S4-13(B) a ad (C), aJid 3745-59-07 

The purpose of this Waste Analysis Plan is to documeut the necessary sampling methodologies, 

anlllytical techniques, and overall procedures that are undertaken for three types of wastes: (I) 

wastes that enter the facility for trealmellt, (2) \1.-astes that enter .the facility for transfer to aoother 

facility that will perfurm alternate tzc:a1ment; or (3) wastes which are geaerated by this facility in 

perfonning treatment, such as PPE, incineration residues (slag, ash, and brick), wastewater, oud 

·laboratory wastes. 

The following sections of C-2· will describe the procedures followed by the Pennittee to gather 

infoanati.on necessary to properly store and manage hazardous waste. This information will be 

oblained by the Peani.ttcc aod upd••ed wbeo oecessary. This infotmatioo will be maintained at the 

facility for a period of no Jess than three years. Paper portions of these IeCOrds, older than three 

yeatS old, may be maiotalnrtl at an off-site stonge facility. Heritag<> W11 (WTI) will maintain a list 

of these off-site localioos at its facility. WTI will enswe lbat the portions of the operating record 

maintained at the off-site locations would be available to review at WTI's facility within five 

business days of the Ohio EPA's roquesl 

C-52 MAY 1 7 2010 

VES016354 
c 

0 

Cla Parameten aDd Radonale 

OAC Rule 3745-54-13 (B)(l) 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

"fltis section desaibes Ule parametm for which each waste will be analyzed and the rationale for 

the selection of Ulese parameters. The analytical program developed with tespect to waste 

IDill3gement coosists of four phases. The four basic phases axe as follows: {1) pre-aoocptancc 

analyses analysesflllSpCCtions that occur prior to storage and trealment of a waste; {2) fingerpriot 

analyses analyses/inspections that occur on incoming waste from off-site generators; (3) 

S\JP!llc:mcntal analyses analyses that occur during the pre-acceptance and/or fingerprint phase as 

needed to identify additional charaderistics; and (4) land disposal restriction analyses axe analyses 

tmt occur on treated waste residue to determine if the residue may be laodfilled. This approach to 

waste identification and acceptance enables the Pennittee to structure analyses to adequately 

identify wastes, to determine waste acceptance, to define operational parameters for handling waste, 

and to ensure proper treatment prior to land disposal. 

JAN l 5 Z010 

C-53 OHIO EPA NEDO 

VES016355 
0 

0 

Heritage- Wll, lnc. 

OHD980613S41 

Revision: 22 

November 10,2009 

As introduced in section C-18(4}, wastes received at the facility are grouped into waste categories 

atCOtding to common cba:ractcristics. lbe waste categories are presented in 1he table below; 

Attachment C.l provides a more detailed description of ead! waste categoxy. Desigl:Ullion of the 

waste ca!ego:y, as determined from the WPS, identifies the tests to be conduded except for !bose 

VlaSteS identified as MiscellaDeous Special Wastes (section C-lb(l)(h)). Attacbments C.2, C.3, and 

C.4 present the analytical parameters that will be tested for each waste categoxy during the various 

pb.oses. 

T•ble C-la- C...~ory Defillition Table 

C...tegocy Description 

A Organic Liquids 

B Organic Sludges 

c Organic Solids 

D Inorganic Liquids 

E Inorganic Sludges 

F Inorganic Solids 

G Lab Packs 

H Compressed Gas and Gas Mixtures 

1 Loose Paclcs 

JAN 15 2010 

C-54 

OHIO EPA NEDO 

VES016356 
() 

0 

C-l2(1) 

Heritage- Wr!, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

Pr&-acceptance samples are analyzed during the review phase of the waste stream acceptance 

process. These analyses will be obtained before a waste is, at a miniorum, sto~ at tho facility. 

Exceptions to this p:ocedure have been pmnitted for Third Party Waste and waste that bas been 

cooditionally approved 10 ob1ain a pr&-acccptance sample the first time the waste is received at the 

facility. AI; discussed in previous sections, wastes meeting the definition of a MSW may use 

supporting docummtation including MSDS, product ingredient infurmation, chemical analysis, and 

· olber information used by the generator to characterize tbe waste. In this situation, p:e·acceptance 

analyses will not be conducted. 

MIHW is a MSW category 3a and thctefore will not require pre-acceptance sampling. 

Attachment C.2 presents a table that SllllllllarizeS the p:e-accep1ance analytical testing by waste 

category. This table lists the analyses perfcnmed on tbe waste rtt:eived by the facility. Designation 

of the waste category is determined from the WPS. The parametas and associated rationale for the 

p:&-acceptaooe analyses are as follows: 

Ash Content -Measured 10 evaluate JK>!ential slag production and/or fly ash generation. 

Beaene Cooten.t - Measured 10 evaluate National Emission Standards for Hazatdoas Air 

Pollutanu (NESHAP) mJuircmentl!. 

CompatibUity Ttsts (Acid, Alkali, Water) - Measured to ideotifY wastes which may be 

incompatible with acids, alkalis or water. The results may _indicate the need for 

supplemeotal analyses and processing limitatiODS. 

C-55 JAN J.6 2010 

OHIO EPA NEDO 

VES016357 
0 

• 

• 

• 

• 

Heritage • WTI, Inc. 

OHD98061354l 

Revision: 22 

November 10, 2009 

Flasbpoillt - Measured to assist in detelmining safe handling, management, and storage of 

the waste prior to treatment !goi.tability of the waste will be identified as less than 140"F or 

greater than 140CF to assist in determining DOOI applicability. 

Heat Value (BTU lib) ..,. Measured to provide information to assist in the development of 

feed zates and to establish proper blend characteristics. It also can be used to identify any 

obvious change in a waste's physical proper1ies or to develop appropriate packaging 

requirements. 

Jaorganic Anions (fluoride, chloride, bromide, iodide, sulfur) - Measured to assist in the 

management of feed parameters and permit conditions, as well as to evaluate potential 

impacts on the incinerator and/or poUlllion control equipment 

Metals Omteot (Sb, As, Ba, Be, Cd, Cr, Pb, Hi Ni, Ag, Se, TI) - Measured to manage 

feed parameters and establisb proper bleod characteristic$ and/or packaging properties and 

to ensme confollllaiiCe with permit conditions. 

• Paint Filter Test - Measured to determine if solid wastes can be managed in the bulk solid 

tanks. This test is only performed on solids and other materials with no visible free liquid. 

Liquids are evaluated vistially and recorded as failing tbe paint filter test. 

PCB - Measwed to evaluate pennit restrictions. This test is only applicable to liquid 

wastes with less than 50 percent water. Wastes containing PCBs in concentrations less than 

50 ppm will wammt questions to the generator concerning the source of the PCBs to ensure 

that tbe waste is not regnlated by Toxic Substanoe Control Act (TSCA). The Permittee will 

not accept wastes for treatment containing PCBs greatec than 50 ppm or regnlated by 

TSCA. 

JAN 15 2010 

C-56 

OHIO EPA NEDO 

VES016358 
f\ 

\.. . ...-· 

Heritage - WTI. Inc. 

OHD9806!3541 

Revision: 22 

November I 0, 2009 

pH - Measured to evaluate, the coiTOsive nature of the wastes. The results assist in 

cbaracterization, proper handling, and processing of the waste. Certain wastes will not 

require pH testing, such as organic solvent wastes, non-water-soluble wastes, and solid 

wastes. The test method identified in Attachment C.5 will determine whether the test is 

applicable to particular types of waste. 

Physical Description - Used to determine the general physical properties of the waste. 

This fucilitates subjective comparison of the pr~>oacceptaoce sample description with waste 

to be sent to the facility. It also can be used to identify any obvious change in a waste's 

physical properties. Examples of these parametern are listed below: 

0>/cr 

Layering 

Turbidity 

Physical Slllte -

Visual obser.valion of color for reference 

Docwneutation of observed layering and sediments 

Visual observation of magnitude of tUibidity 

Documentation as to state (i.e., solid, liquid, ?I sludge) 

Radioactivity - Measured to evsluate acceptability of waste streams. Indicates the absence 

of radiation in relation to background levels. 

• Reaetivity Screens (Cyani<)e, Sulfide, Oxidizer) -Measured to identify wastes wlrich may 

contain reactive cyanides, sulfides, or oxidizers. The results may indicate the need for 

supplemental analyses and may be used in the management of waste on-site. 

• Water Content - Measured to assist in the development of feed rates and to establish 

proper blend characteristics. It also can be used to identify any obvious change in a waste's 

physical properties. 

C-57 JAN I 5 2010 

OHIO EPA NEDO 

VES016359 
0 

C-2a(2) Fingerprint Analyses 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

These analyses are conducted to ensure that waste arriving on-site is !he same waste that was 

characterized during pre-acceptance activities. The tests that are conducted during !he fingaprint 

phase are typically a sUbset of !he pre-acceptance tests. Attachment C3 presents a table 

swnmarizing.fingerprint analytical testing by waste category. Th.e typical parameters that may be 

analyzed during fing<qlrint analyaes and any applicable boundaries to be applied to the analyses are 

listed below. As shown in Attachment C.3, the parameters to be analyzed are waste stream specific 

and, as such, will change for different waste streams. 

Fingerprint samples will not be collected from MIHW streams. Sufficient documentation, such as 

product inserts, MSDS, generator certification, and/or data sheets, will be provided to the Permittee 

in lieu of facility sample analysis. Each container ofMIHW will be evaluated for radioactivity. 

Compatibility Tests (Acid, Alkali, Water, Waste Mix, and Differential Scanning 

Calorimetry (DScyor equivalent method/test) - Measured to compare wdS!e properties 

frOm pre-acceptance analysis and information on the WPS to ensure waste is the same as 

that approved in pre-acceptanoe phase. The waste mix and DSC tests are perfonned on 

bulk liquid wastes that will be commingled with oilier wasies wifuin the organic tank farm. 

These tests are completed to identify any waste compatibility issues prior to oflloading the 

incoming waste into the organic tank fann. The Pennitlee may use an equivalent alternate 

method/test for compatibility in lieu of the DSC. 

Flashpolnt - Results indicaling significant changes may be considered atypical, and more 

detailed analyses. or shipment ~ection may be warranted. 

loorganlc Anions (Bromide, Chloride, Fluoride, Iodide, and Sulfur) - Test results will be 

compared to information reported on the WPS. Results outside of the ranges indicated on 

lbe profile will be consideml atypical and a more detailed analysis or shipment rejection 

may be warranted. 

C-58 'JAN 15 2010 

OHIO EPA NEOO 

VES016360 
. !'""\ 

\.. ...... 

Heritage - WTI, Inc. 

OHD98061354l 

Revision: 22 

November 10, 2009 

• Beat Value -Test results will be compared to the information reported on the WPS . . 

Results indicating significant changes may be considered atypical, and more detailed 

analyses or shipment rejection may be warranted. 

Paint FUter - This test will be perfonned on wastes with little free liquid. Solid materials 

to be managed in the bulk solid storage pits niust pass this test. Solid materials failing the 

paint filter test will be considered atypical and may require additional processing or 

rejection may be warranted. 

pH -Boundaries are reported on the WPS. Results outside of these boundaries will be 

considered atypical and a more detailed analysis or shipment rejection may be warranted. 

certain wastes will not require ph testing, such as orgauic solvent wastes, non-water-soluble 

wastes, and solid wastes. 

Physical Description - Observed to determine the physical properties of a waste. 

Parameters are described in section C-2a(l). Pre-acceptance observations are compared to 

fingerprint results. Observations which are different will be considered atypical·and a more 

detailed analysis or shipment rejection may be warranted. 

Radioactivity - Wastes indicating radioactivity greater than background will be considered 

atypical and a more detailed analysis or shipment rejection may be wammted. 

Reactivity Screens (Cyanide, Sulfide, Oxidizer) - Reactivity screens will only be 

performed on wastes that will be processed in tanks or stored on-site. Positive results may 

warrant supplemental analyses or shipment" rejection. 

Water Coo tent - The boundary for this parameter is plus or minus 15 percent of the water 

content reported on the Pemilitee's WPS. Results outside of this range may be considered 

atypical and signify the initial properties of the waste have changed . 

C-59 'JAN 15 2010 

OHIO EPA NEOO 

VES016361 
c 

c· 

C-2a(3) Supplemental ADalyaes 

Heritage- WTI, Inc. 

OHD98061354l 

Revision: 22 

November I 0, 2009 

Supplemental analyses are not always run as part of the pre-.acceptance or fingerprint analyses, but 

mAy be added, as necessary, to assist in determining waste acceptability, processing, and/or waste 

management options. The tests may also be perfonned to provide additional inful"'MMion used in 

tbe operation of the incinerator. These analyses fall into two categories: (1) further analysis as 

iclcnlilied by saeens; and (2) furtba analysis as idaltified in the WPS. These supplemeotal 

analyses are listed below with the specific cireums!ances in wlri<:h they may be used: 

Cy211lde DistiDJition - Positive cyanide saeens for bulk solids will warrant this analysis, as 

well as when =gemcnt decides further testing is needed. Shipment rejection may be 

warranted. 

Freons (dicblorodifluorornethane, tricWorotluoromethane and bromoform)- Thc.~e analyses 

may be conducted to detennine the presence of these organohalides. 

Metals Conteat (Sb, As, Ba, Be, Cd, Cr, Pb, Hg, Ni, Ag, Se, TI) -Analyses for metal 

content are mandatory during pre>acceptance analyses, but wiD only be run during the 

fingespcint analyses wbeo the coooc:ntration on the profile for one or more of the metals is 

above a prede<mnined limit set by facility managcneot. If one OT more of the metals 

exceed the preset limil, analyses for all metals is perfmmed The analyses, and averages of 

these analyses, are nsed in the development of the daily bum plan for the !nc:ineration 

System to fllSUre complim with pc:mit me1a1 feed limits. The rationale of facility data 

used to determine feed rates of metJII bearing waste is described in t:fte following 

paragraphs. 

OHIO EPA NEDO 

· .. 

VES016362 
0 

c 

Heritage- WTl, Inc. 

OHD980613S41 

Revision: 22 

November 10, 2009 

At the completion of the waste approval process, the metal concentration ranges (referred to 

as 'conranges') are obtained from 1he WPS and recorded in the ARTS (Automated Realtime 

Traclcing System or any suca:ssor) database. If the conrange does not exceed the ~ 

limits, then they are used to caltulate metal feed rates. When the preset limits are exceeded, 

metal analyses are completed as supplemental analy= on incoming waste samples. The 

analytical results for the container sampled are now used instead of the conrange for that 

container from the WPS. 

When at least thirty consecutive samples from the nonna1 1 00/o sampling freque"ncy 

(discwsed in seelion C-2d(2)) have bcm analyzed for metals from the same pro£le, the 

Permittee may use a statistical average of these tbirty analyses instead of the conrange. This 

number is referred to as the 'dirty thirty' and is equal to the .average of at least thirty 

analyses plus two stanclaid deviations. The dirty thirty metal numbers an: used for "tracking 

metal 6!ed limits, instead of the conrange, for a period of six months. After six months tbe 

dirty thirty is oot available to use until five new analyses arc incorporated into the dirty 

thirty Statistical average. Tbe five new analyses must be consecutive and the same 

statistical average calc:ulation is applied to the twaJty-five most recent results from the 

original thirty, plus the five newer resuliS. At any time that the dirty thirty calc:ulation 

results in nwnbers outside the acceptable range, the Permittoe may choose to use collJ8Dges 

or keep mOiling metal• a.• supplemcmal analyses. 

PC& - These analyses are mandatory during the pre-accc:ptaDcc phase for certain waste 

categories, but are not mandatory for fingerprint analyses. Random PCB testing ofliquld 

wastes with less 1han 50 percent water will be condllded ooce a week, one bulk liquid 

sample and one drum liquid sample. 

JAN 15 2010 

C-61 OHIO EPA NEDO 

VES016363 
Heritage- WTI, lne. 

OHD980613541 

Revision: 22 

November 10, 2009 

Reactive Sulfide Distillation - Positive sulfide screens for bulk solids will warrant this 

analysis, as well as when management decides further testing is needed. 

SeUable Solids - This test will only be performed as needed by facility management. 

Speclfle Gravity- This test will only be performed as needed by facility management. 

VIscosity- This test will only be pcrfonned as needed by facility management to determine 

pumpability characteristics. 

C-2a(4) Land Disposal Restriction Analyses 

'Land disposal restriction (LOR) analyses art conducted on treatment residuals and other waste 

streams fiom the incinention system to determine if wastes may be Iandfilled, or require additional 

treatment before it may be landfilled. Analytical parameters to be evaluated are based on the waste 

incinernted generating the 'treatment residues: Categories of parameters that will be analyzed may 

indude aoy or all of f!:le following: 

Cyanides 

Metals 

Pesiiddes 

Semi-volatiles 

Volatiles 

Samples will be taken from the wastes for the toxicity characteristic leaching procedure (fCLP). 

Analytical detection limits will be detennined using current luboratocy technology. Analytical 

results in conjunction with evaluation of appropriate treatment or technology standards will be used 

to determine if the wastes comply with current land disposal restrictions. Analytical data will 

accompany representative sample shipments of the residual destined for land disposal. Refer to 

section C-3 for more details about LOR requirements. 

C-62 JAN 1-5 ZOIO 

OHIO EPA NEDO 

VES016364 
., 

'· -' 

C-2b 

C·2b(l) 

Analytical Test Methods 

OAC Rule 3745-54-13(B)(2) 

Description of Analylkal Test Methods 

Heritage - WTI, Inc. 

OHD9806!3S41 

Rcyisioo: 22 

November I 0, 2009 

Tbe Peunittee will use USEP A approved a.odlor current iDdusiiy standard analytical test methods, 

"'"'en they are available, 10 ~ ihe paramettts l'fX!IIired to determine permit compliance and 

opemting requirements. For example, tbc Peanittce will use SW-846 methods 10 test waste foc 

items such as heat value, pR, metals, PCBs, free liquids, total cyanide, total suliide, and 10 test 

incinerator residues for vo!anle !Wd semi-volatile organics: Additional tests needed by tbe 

Pcrntittee, but not available in SW -846, include ASTM tests for physical properties, ash, water 

content, and screening tests for cyanide, sulfide, oxidizers, waste mix compatibility and Differential 

Scanning Calorimetty (DSC) or equivalent method/test. Tests for radioactivity, settable solids, 

tii.Shpoint, and acid, alkali, and water compatibility have been developed by the Permittee IUld are 

described below. 

W-1000: Add, Alkali and Water Stl'fJtDlng ill Waste-The acid saeen portion of this test uses a 

mi= of the waste and I 0'/e hydrochloric acid. Any generation of gliS, heat, bubbling or 

spanering or precipitation causes a positive result A brief description of the obscrvalion is 

recorded. 

The alkali screen portion uses a miltture of the waste and an aqueous solution of 1 00/o ellcali. Any 

~on of gas, heat, bubbling or spllltering or precipitation causes a positive result A brief 

de:scriptinn of the observation is recorded. 

Tho water screen portion uses a mixture of tbe waste and type IT reagent grnde water. Any 

genom~tinn of gas, beat, bubbling or spatte:ring or 'precipitation causes a positive result. Miscibility 

is also.recorded when the waste is a liquid. 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016365 
Heritage- wn, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

'W-1002: Radioa ctivity Test -This test uses a Geiger counter to meaSure the radioactivity of a 

sample of waste. R.adialion above ba.clc:grotmd causes a positive result 

W-1005: Settable Solid Test - This test Scparllles solid/liquid waste mixtures by centrifuge and the 

relative peroentage of each layer is measured. 

W-1008: FbshpoiDt Test - This wes slandard testing procedw:es except instead of a gradient 

evaluation·of the ftashpoint; the instrum~t will be set on 14WF. If the waste flashes at 140"F, than 

less thlm 140"F will be reconlcd as the fiashpoinl If there was no flash at 140"F, then greater than 

140"F will be recorded ~the flashpoinL 

The facility's on-site laboratory will be the primary laboratory used to perform analyses, however, 

some situations may warrant the use of an off-site laboratory. Attachment C.S lists the parameters 

to be tested and the primary and allematc aaalytical me1hods to be used. In most instances where a 

primary method exists, that meiliod will be used. However, the Permittee reserves the right to use 

mcfuods listed as alternates or cum:n1 indiiStry standard methods with equivalent quality 

asSUt8l!Wquality conlrol (QAIQC) measures. 

C-2b(2) Destriptioa of Quallty Control Program 

1b.e quality conlrol pxog,:am at the faeility is managed through Anacbment C.l2 of this document, 

OOed Qlalicy Assrranre and Quality Cnntml Plan (QA!QC Plan) and is based on SW-846, 

Revision m. Good laboratory practices, which encompass sampling, sample handling, 

housekeeping and safety, are maintaiDed. 

JAN 1 5 2010 

C64 

OHIO EPA NEDO 

VES016366 
0 

c 

Heritage · Wfl, Inc. 

OHD98061354! 

Revision: 22 

November I 0, 2009 

Sampling is petfomied at the facility to characterize incoming waste shipments and wastes 

generated on site. When pre-acceptance samples are required, the Pennittee refers waste generators 

to 40 CFR 261, Appendix I and OAC 3745·51-20, Appendix I for sample collection. These 

procedures eosure that a representative sample of the waste is obtained for analysis. 

With respect to the samples collected by the Pennittee, specific sampling procedures are dependent 

on both lbe nature of the material and the type of containers being used for shipping. To eosure the 

integrity and that each sample is representalive, sampling and decontamination procedures based on 

SW-846 or equivalent methods will be employed. Details of the Pennittee's sampling procedures, 

methodologies, and equipment are presented in Attachment C.6 of this plan. These procedures may 

be changed from time to time to reflect advancements in sampling methods and equipment, 

cbanges in regulations, etc. These changes, however, shall be consistent with the governing 

iequirements of the approved Waste Analysis Plan. The remainder of this section presents an 

overvi~ of the facility's recominended sampling protocol for general types of waste materials and 

OODiaiJlers, however Attachment C.6 should be referenced for details. 

C-65 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016367 
· .. 

C-2t(l) Containers and Tanks 

Heritage · WTI, Inc. 

OHD9806l354l 

Revision: 22 

November I 0, 2009 

Sampling of small container.; (e.g., dnuns, pails, and other small units) varies with the nature of the 

waste material. For flowable materials, when appropriate, the sampling device to be used is either a 

Coliwasa or open tube sampler to draw a fUll vertical axis siunple of the flowable material. For 

nco.-flowable wastes, an open tube sampler, scoop, or trier is used to obtain a sample. 

~e containers and tanks for flowable materials and bulk containers for solid materials may be 

eilher stationary or mobile. Liquids are sampled with a Coliwasa or open tobe sampler to obtain a 

vertical section. Light, dry powders and granules are sampled with an opeo tobe sampler to obtain 

a vertical core. Heavier solids are sampled by scoop or trier, or by coring with a open tube sampler. 

In addition, where the tanks do not perl:nit sampling from the top, the tank may be sampled from 

tank sampling ports or taps through tank inlets, outlets or re-circulatiog tines. 

Bo.lk deliveries will normally be sampled from the top of the container. The number of samples 

aud the device ·used are based upon the physical characteristics of the waste, and the access 

di:neosions of the container. Attachment C.6 provides the facility's Basic Procedures and 

Equipment for Waste Sampling. 

Fly ash and slag will be sampled using different procedures. The fly ash will be sampled using a 

scoop or trier, depending upon the consistency. The hatches, ports, or openings in the pneumatic 

trailer, polypropleoe fabric bags, or the dust-tight dry-solids transport box will allow vertical 

compositing. The slag residue from the incinerator will be collected via a steel belt conveyor into a 

roll-otfbox or end dwnp trailer. The number of samples collected for the composite sample wm 

vary depending on the size of the roll-off or end dump trailer. The sampling procedure is addressed 

in the waste sampling procedures in Attachment C.6. The slag will normaJJ.y be collected using a 

sooop or shovet 

C-66 JAN 1 5 2010 

OHIO EPA NEDO 

VES016368 
c 

\. .• 

C2e(2) Spray Dryer Feed System 

Heritage • WTI,lnc. 

OHD98061354l 

Revision: 22 

November l 0, 2009 

A sample will be taken of the spray dryer feed liquid daily. The sample will be drawn at the spray 

dtyer feed pump. Analyses will be made for the following parameters: 

• pH 

• Total Solids 

• Density 

• Metals (Sb, As. Be, Ba, Cd, Cr, Cu, Pb, Hg, Ni, Se, Tl, Zn) 

C2c(3) Storage Tanks 

Waste delivered to the Permittee can be stored in bulk storage tanks. These tanks will be sampled 

in accordance with the most up to date standard operating procedwe (SOP). Section C-l c(2) 

discusses tests conducted to determine: (I) the compatibility of incoming wastes with the tank's 

oollS1niCtion malerial; and (2) the COIDpanbility of fucoming waste with the waste already cootained 

in these tanks. 

C-2d Freqna~cy of Analyses 

C-2d(l) Pre-ac:eeptaoce Analyses 

llefore storage imdlor trea1menl of a new waste stream at the facility, the generator of the waste will 

provide the Pennittee with a completed Waste Profile Sheet (WPS) and, either a rep:esentative 

sample for pre-acoeprance analyses and/or laboratory analysis of a representative sample of the 

waste stream to be received at the filcility. Exceptions to this are listed in the MSW sec1ion, Clb(2)(ii) and in section C-1 b(2)(iv). For wastes meeting the definition of a MSW, only a WPS will 

be required, along with any available analysis, or other documentation, that was used to cbaracterize 

1b.e waste. Tbe generator will be required to 

C-67 JAN 15. 2010 

OHIO EPA NEDO 

VES016369 
0 

Heritage- WT!,l.ac. 

OH.D980613541 

Revision: 22 

November I 0, 2009 

S\.9PIY the Permitt~ with sufficient chemical and physical characteristic information for proper 

management of the waste. The generator-provided IIJlalysis will only be acceptable for replacement 

of the Pennittee pre>-ruxq:>tance IID81yses if all testing is supported by SW-846 quality conlrol 

results and the laboratory QAIQC has been audited by tho Pennittee. All tests discussed in Section 

C·2a(l) of this plan must be completed with either the some test methods used by the Pennittee or 

al~emate test methods approved by facility rtWU~gemcnt. 

Pre-acceptance analysis will be repeated as necessary to ensure it is aocurate and up-to-dille. At a 

minimum, new pre-acceptance analyses will be completed when one of the following oocun: 

·The generator of the waste notifies the Petmittee that the process generating the 

waste has changed and suspects that the properties of the waste have changed; or 

The Pennittee has reason to believe the process generating the waste has changed; 

or 

Inspection of tbe received waste does not match the waste designated on the 

manif~ or sbippiDg papas. 

A review of pre-accep~ance analyses will be pctfonned by a membtt of facility management on an 

3llJlUal basis, as part of IDilUa! recertification requirements. A new sample, and thus new analyses. 

may not be required if tbe fingerprint analyses throughout the year have been consistecl with the 

wa.ste's initial properties. 

C-68 

JAN I 5 2010 

OHIO EPA NEDO 

VE5016370 
0 

C·2d(2) Fmgerprint Analyses 

Heritage -WTI, Inc. 

OHD980613541 

Revision: 22 

Novl2llber 10, 2009 

For container shipments, at last 10 percent of the containers from each waste stream will be 

randomly selected for sampling upon delivery ru:oordi.og to section C-lb{3). A minimwn of one 

cootainer from each waste stream will be sampled. The designation of the containers to be sampled 

will be made by a random number generator function in the computer system that prints the labels 

for the CO!llainc:n. In the eve:nt of a system failw-e, the colll:aim:(s) to be sampled will be 

dcsigJlated by supervisory personnel. 

For bulk solid and bulk liquid deliveries, a sample will be taken from each load. The "Fingerprint 

Analysis" is performed and approved before the shipment is directed to an unloading station. 

As stated in section C-lb(2Xii), Miscellaneous Special Wastes (MSW), and in section C-lb(2)(iv), 

sOille materials may not be sampled upon arrival, but will, at a minimum, be subject to a visual 

iDSpection. For certain waste streams, such as those in Catcgocy 3 - Wastes tba! P"""'"'' elpO•nre 

hazarrls, it is not apptoptiate to visually inspect the contents of the contairun. These waste streams 

(Xesent hazards upon opening the con1ainer. In addition, otr1ain conlainer types, such as a cylinder, 

may prevent a visual inspection to be perfonned. All other waste streams meeting MSW 

definitions will be visually inspected. 

C-69 J~N 15 2010 

OHIO EPA NEDO 

VE$016371 
f\ 

' 

. ~ 

\ . / 

C-2d(3) Supplemental Analyses 

Heritage -WTI, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

This analysis will only be repeated as part of pre-acceptance and fingerprint analyses, when 

applicable as descnbed in section C-2a(3), the parameters and rationale section for supplemeotal 

ana.lyses. 

C-2d(4) L and Disposal Restriction Analyses 

Land Disposal Restriction (LDR) analyses are perfonned on treated waste streams that are being 

sent from the facility to other disposal facilities. This section will discuss the frequency of analysis 

fur these waste stteams. Currently there are four waste streams generated at the facility analyzed 

for LDR: I) Fly Ash Residual, 2) Slag Residual, 3) Savbber Blowdown Water, and ·4) Used Kiln 

Brick. The ash and scrubber blowdown water sampling fi:eqW!:IlCies are similar since they are bo1h 

generated via emission- control systems and consequently should be relatively consistent in their 

composition. Similarly, the slag and brick sampling frequency is similar since they are both 

produced through processes related to the incinerator. The paragraphs below discuss the sample 

frequencies for both of these groups. Analytieal data will accompany representative shipments of 

the wastes destined for disposal. Facility management will investigate treatment options for 

materials that fail LDR to ensure compliance with LDR Standards requirement Any :future waste 

streams generated by the Permittee requiring LDR analysis will be reviewed to detennine the 

appropriate sampling frequency . 

C-70 

JAN 1.5 2010 

OHIO EPA NEDO 

VES016372 
/ ·. 

'.. ' Heritage. wn,Ine. 

OHD980613541 

Revision: 22 

November 10, 2009 

C.2d(4)(i) Ash Residue and Scrubber Blowdo"Ml Water SampliDg Frequency 

These waste streams require metal, organic, 11Dd pesticide analysis. The Permittee will either 

eaalyze the these wastes for metal constituents related to the waste stream on a batch basis or 

require the receiving facility to · provide further treatment (e.g., stabilizatioo or encapsulation) that 

v.ill ensure the waste stream will be 11131laged within the requiia:nents of the c::wrent labd disposal 

nslrictions. The Permittee will 1118lyze the outgoing incinerat« ash residue for organic 

comtituents at least once every 30 days to confirm flu! the ash oomplies with the =t land 

disposal restrictions. The lim ash and water container r=oved from the 6lling station each month 

v.iU be the representative sample for that month. If the Permittee uses a polypropylene fabric bag 

for the lim ash sample of the month, the Permittee will obtain samples from three coosccutive 

fabric bags. 1bree fabric bags arc the approximate equivalent of a SO..yd1 collection box. 

In addition, laboratory test samples are collected from each container filled and are tctained until 

the container's contents have been disposed. In the unlikely event that the analytical performed on 

the monthly sample fiills for associated trace organic compounds, an investigation will be 

aliJducted to determine the cause. Available ash samples retained from prior containers will be 

analyzed until three consecutive passing samples are obtained. Facility management will cletum.ine 

the necessary corrective actions, b&sed on the results of the investigation. Coo:ainers filled 

mbsequent to the failed container will be sampled and analyzed until passing samples from three 

a:msecutive ash containetS are obtained. Analysis will also be performed on any ash oontaine:s 

filled and yet tu be disposed. 

C-71 

JAI-4 15 2010 

QH\0 EPA NEOO 

VES016373 
~ 

\. ... 

/'"', 

\.. . 

C-2d(4)(il) Slac Residue and Used Kiln Brick 

Heritage - WTI, Inc. 

OIID980613541 

Revision: 22 

November 10,2009 

These waste streams also require metal, organic, and ~1icide analyses. The brick waste stream is 

geoerated when the kiln aodlor secondaly combustion chamber are being relined with bricks. At 

tllat time, a couple of boxes may be generated each day. The Permittee will either analyze these 

wa.stes on a batch basis for metal constituents related to the waste stream or require the receiving 

focility to provide further treatment (e.g., stabilization or encapsulation) that will ensure the waste 

stream will be managed witbin the requirements of the cmrent land disposal restrictions. The 

Pennittee collects a random sample of the waste and performs analyti~ for orglmics a minimum of 

oo.ce per day to confum that the waste complieS with cuaent land disposal restrictions. The samples 

me crushed or pulverized, blended, and a labom!ory sample taken fur tbe same analytical chemical 

tests as were applied to the incinerator ash. An evaluation of these test results are made to 

detmnine if the waste meets the land disposal restrictions. In addition, samples collected from all 

ofuer colltainen are retained until the following day's sample is analyzed to coofum it meets land 

disposal restrictions. In the event the daily sample fails fur associalecj ttace organic compounds, an 

investigation is implemented to detecnine and rectify the cause of the problem. The inv~on 

includes analyzing samples in reverse order of collection until a passing sample is obtained, and 

followed by three (3) consecutive passing samples following samples for that calendar day. 

In summary, the fly ash reSidue and scrubber blowdown Wlller will be tested at least every 30 days 

md the slag residue and kiln brick will be tested daily for truce organic and pesticide compounds. 

Metal TCLP analysis will be performed for each bulk container. The cbemicals to be analyzed are 

dlosen based on the wastes incinerated during the associated time period. AIIalyti.cal methods used 

for the land disposal restriction· analysis are presented on Attachment C.5. 

C-72 JAN l5 2010 

OHIO EPA NEOO 

VES016374 
c 

Cle 

C2e(l) 

Additional quirement~ for Wastes Generated Off-Site 

OAC Rule 3745-S4-13(BXS) & (C) 

Hcriljlge • WTI, Inc. 

OHD98061354\ 

Revision:22 

November I 0, 2009 

Gt11enl Procedures for Acceptance ofWmes Geoerated OfJ..Site 

The Pen:niUee has develop«! a four·stql proc= of control .pr\JCOlwes to ensure that incoming 

wastes are the same as pre-approved waste for trealmc:nt. The four st~ are detailed in the sections 

thai follow. 

J. Waste Identification: 

Incoming waste shiprneot identification begins upon arrival of the waste nt the facility. The 

inspection, sampling, and analysis of incoming waste will be perfooned in acconlance with 

the methods described in sections C-2c and C2a(2). Wastes that 111:e designated as MSW 

may not be sampled. . HQwevcr, these materials will, if appropriate, be visually inspected. 

Special requirements for lab packs are presented in section C2e(2). 

In general, the waste idenli1ic:ation step is compost:<! of the following: 

Waste manifest review and LOR review 

lnspec:tioo (may include D.O.T. descriptions/labels) 

Sampling (when app)jcahle) 

Analyticel results review 

Review WPS and any additional documentation supplied by the generator, 

and 

Facility management's judgn1enl Facility management's judgmCilt can 

, assist in the waste identification by determining the commooality between 

reported infoiiD.ali.on and analyticel xesults. 

C-73 JAN 1 5 7010 

OHIO EPA NEDO 

VES016375 
c 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

Bnlk solid and bul,k liquid deliveries are sampled and the required analysis peaormed and approved 

before the shipment ~ directed to an unloading station. Container deliveries that exhibit no 

significant discrepancies are unloaded and counted. If no significant discrepancies are ideolified 

during the unloading process, the manifest IS signed and the truck is released from the site. Details 

of sampling frequency are presented in section C.2d(2) 

There may .be situations which warrant the use of generator-supplied fingerprint analysis. In these 

situations the analytical provided will have. to report those tests required by this section of the 

pm:nit application and use the same test methods, or equiVlllent methods, as approved by the 

ftcility's laboratory management. The requirements for the use of off-site laboratory analytical is 

discussed in C-2b of this plan. 

n. The Need for Additional Supplemental Analyses: 

The facility management decides whether additional analyses are required for a particular 

waste based on tbe following: 

• WPS infunnation 

· Results of finge~print analyses 

Experience and judgment of facility management in determining the oeed 

for more information 

Further testing may be required if the results indicate unexpected infunnation with respect 

to pre-acceptance procedure paperwork and/or analytical results, or if the facility 

management has reason to believe that the waste composition has changed. 

C.74 JAN t 5 2"010 

OHIO EPA NEDO 

VES016376 
c 

0 

c 

Heriaage - wn,lllc. 

OHD980613541 

Revision: 22 

November 10, 2009 

m. Evalnatioo of Waste Conformity: 

The fac.t1ity management will classifY waste as being in •noo-ronfonruwce• if it is 

determined by the Permittee waste acceptance personnel to be significantly diffe.ent in 

composition from tbe information shown in the ~acceptance paperworlc. or in quantity 

from the infonnalion on the manifest, in &CCOrdanc.e with 40 CFR 264.72 and OAC 3745-

54-72. The following majoc criteria are ~ to mive at this decisioo: 

• 

. . 

Far bulk waste, variations greater than 10 percent in weight; 

For batch wastes (e.g., drums, bags, etc.), 81}Y variation in piece c.ollllt (i.e., 

the number of pieces listed in the manifest does not agree with the nutnber 

of pieces on the truck when received); 

If inspection or nnalyais of any wa.~te determines obvious difterences, such 

as waste solvent substituted fur waste acid or toxic constituents, not reported 

00 mamfest; or 

Radioactivity gn:ater tbnn background. 

Manifest discrepancies or oon-conformaoces that do not fall within these criteria arc 

comidercd to be "minor" and are not subject to re-evaluation review. If lhe Permittee has 

reason to believe a "minor" disaepancy is not a one-time deviation and a particular waste 

stream is different _from i1s doc:umentcd values, the geoc:rnlOr will be contacted in on:ler to 

re-characterize the waste. 

C-15 . 

J"N .1 5 1010 

0\-\\0 EP" NE.OO 

VES016377 
0 

\.. . 

() 

. 0 

IV. Resolution of Nonc:onf rmln~: W aste: 

Heritage - WTI, lnc. 

O!ID980613541 

Revision: 22 

November 10,2009 

Wastes found to be in non-confonnancc may be rejected or they may be re-evaluated for 

possible acceptance by the facility despite the variance. The re-evaluation procedure is 

designed to detemline whether a nonconforming waste material, can be baodlcd at the 

facility. ·upon completion of the evaluation, the generatotlcustomer wiU be contacted to 

gain concur:rence with the new dctcnnioation. At ibis point, a decision is made by the 

generator ·and the Permittee regarding the disposition of the waste, i.e. continue with the 

incineration process, reject back to generator, or send to ao altauate facility. This 

procedure is intended to prevent the unnecessary movement of a waste ~terial back and 

forth between the Permittee and the generator, when the material can be readily handled 

by the facility. 

The facility management evaluates the waste in question with regnrd to the following 

criteria: 

Pennit requirements 

Discussions with the generator 

Faality's capability to appropriately manage the material in question 

Results of any fingeqnint analyses 

Results of additional supplem.eotal8IJ3iyses (tf any) 

Facility llJliDII8=CI1I's judgment 

If the above parameters indicate that the waste can be aeeepted and the gcoerator concurs, 

tbe wasre will be accepled at the mcility. If a major disc:rtpancy cannot be resolved within 

IS days of shipm.ent receipt, lhe BP A Regional Administrator and the Ohio EPA will be 

notified, in writing, of the discrepancy aod of attempts to reconcile it, including a copy of 

the involved manifest . 

C-76 JAN l 6 2010 

OHIO EPA NEOO 

VES016378 
(' 

\..· 

0 

0 

...... 

Heritage - W11, Inc.. 

OHD980613541 

Revis!on: 22 

Ne>vember 10, 2009 

The Permittee may reject waste fur any one or any combination of the following reasons: 

• 

C:Zt(2) 

A manifest discrepancy (or non-confonnance) cannot be resolved to the generatot's 

and/or the facility's satisfaction; 

The generator'sltrnnsporte:r's mani f'lSt is not in order; 

The bulk shipment is not compatible (fails the waste compatibility test) with wastes 

already contained in storage, lllld no o1bec 1Jl.811.11gemeot method is available; or 

There are major deviation(s) bttween pre-acceptance and fingctprint analyses. 

The shipment contains waste prohibited in section C-1 a(l ). 

Radioactivity is greater than badcground 

Specific Procedures for Acceptance of Lab Patk Shipments. 

(lnclnded in former permit as Attachment 1 Ill the Waste Analysis Plan) 

1. "Lab paclc'' shall be defined as an outer container unit that oonta:ins inner containers of different 

chemical wastes intended fur treatment or disposal. This shall include such multiple-waste 

containers generated from laboralories, research facilities, and other commercial and industrial 

activities where chemical wastes arc gmera!ed. Lab patk does not include "Loose pack" a.~ 

defined by Ohio Eo~tal Protection Agency ("Ohio EPA"). 

C-77 JAN 1.5 2010 

OHIO EPA NEDO 

VES016379 
( \ 

\. _ ..... 

Heritage • WTI, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

2. "!Aose packs" as defined by Ohio EPA (see Jetter dated 6/10/98, and any subsequent 

correspondence on this issue) are not required to meet these lab pack requirements. 

3. All Jab packs received at the facility shall contain materials that are coropatJ'ble, acceptable, and 

well-<iefined. . Matmals thai are not readily identified at the point of generation must be 

characterized by the generator. The characterization protocol must include, at a minimum, the 

following tests: 

a) Physical description of material (ASTM-04979~9) 

b) Radioactivitytest(wn-23) 

c) Flammability test (Method 1010) 

d) Corrosivity test (Method 90458) 

e) Peroxidt"ioxidiztl: test (AS1M·D4981·89) 

f) Water reactivity/solubility test 

g) Cyanide test (ASTM-05049-90) 

f) Sulfide test (AS1M-D4978-89) 

Test methods used may vary fi:om those listed above if deemed by the facility's Laboratory 

Manager to be equivalent fur the purposes of charnclerization of the waste materials. 

C-78 JAN 15 2010 

OHIO EPA NEDO 

VES016380 
c 

0 

Heritage - WTI, Inc. 

OHD980613S41 

Revision: 22 

November 10,2009 

4. No lab paclc(s) of the following materials shall be received or stored at the facility. 

a) Shock«D.Sitive materials with NFP A 704 Reactivity Hazan!. !Wing of 4 such as, 

crystallized picric acid, crysta.llized peroxides in elhyl ether, cby nitroguaoidine, or 

trinitroetbanol; 

b) Stockpile or DOD-Stockpile chemical muni1ions con!rollecl by the Department of 

Defmse, or IeSidue derived from ihc tr ... -, stomge, or disposal of sud! 

cbemical munitions; 

c) Explosives in quantity greater ilian two (2) pounds per out« conlainer; 

d) Primazy explosives (DOT cla.o;silication code 1.1 A, including mercury fulminate 

(Chemical Abslract NWDber (CAS#) 628-86-4), lead styplmate (CAS# 63918-97-8), 

mannitol beXllllitrate (CASII1582S· 70-4), or dinitro~l (CAS#2S550.58-7)); 

e) The followiog ~s due to existing site/permit restrictions: 

I) InfectioUil Waste Nitrogen Muswds Dioxins 

PCB's great~ than SO ppm Sulfur Mustards Radiooctivc Waste 

Chemical Wadarc Ageots Compressed Oases (with the exception of a 

compressed ps used as a propellaot in aerosol cans) · 

2) MIHW (unless a specific miSte !X'Ofilc shed is prepared in ~with 

section C-lh(2)(ili) of this document) 

3) NFPA Class lA Flammables unless managed in c:ompli•nce with the 

provisions of the Pcnnittce's cummpe:mlit; 

4) Wastes prohibited due to LOR restrictions sud! as high mcrc:uty LOR 

category, inorganic subcategocy, of 0009. However, the Pennittee may 

accept the low mercury subcategocy (less than 260 ppm) and tho high 

mercury, organic subcategory ofD009. 

5) PCB waste rcgulatcd by TSCA, regardless of PCB concentration. 

r'-. JAN 1 5 2010 

'-../ 

C-79 OHIO EPA NEDO 

VES016381 
c 

Heritage - WTI, Inc. 

OHD980613S41 

Revision: 22 

November 1 0, 2009 

S. Lab packs shall be~ in accordanc:e with the Pemrittee's Lab Pllclc Guidelines dsled 

Oe1obez 23, 2007, or later update. The Pemnttee shall modify the guidelines wben necessary 

BOd furnish the Ohio EPA witb a copy of any significant revisions within thirty days of tbe 

change(s). 

a) The Pemrittee may recave lab packs C001aining asbestos. Hov.-ever, these lab paclcs may 

cot be treated on-site and must be tnmsfemd to an altt:mate destination facility. 

6. The Pemrittee shall receive and review the packing inventory sheet for ooceplability of each lab 

pack prior to shipment of that lab pack. 

7. Auditing oftbe colrtCIIIsoflab packs: 

a) Auditing definition- Auditing shall include at a minimum, for each lab peclc: 

1) Opening of tbe outer container, 

2) DepacJcing the outer contaiDer; and 

3) Verifying tbc information on tbe imlez container labels against tbe pac!ring 

i.nventozy sbeet. 

b) Auditing frequeDcy -

1) For lab packs paclc!gcd bY or under the direct supervisipo of a WTI Field 

Chemist, one drum from each load will be audited. Tbls drum will be chosen by 

aulhorized facility persoDDel. 

2) Fa.- lab packs packaged bY any Pemrittee trained geoaalor, 40 percent of each 

load shall be opened and audited except for any lab pack specifically exempted 

bY tbe Ohio EPA from auditing. The containers to be audited will be chosen by 

authorized facility PQ'80ililcl. 

JAN l5 2010 

C-80 

OHIO EPA NEDO 

VES016382 
c) Auditing docwnenfa!iooHeritage· WTI, lnc. 

OHD980613541 

Revision; 22 

November I 0, 2009 

The Permittee shall develop and utilize a 1Iaclcing system designed to record and 

access information on the nwnber of lab packs received and audited. In addition, 

the number, description, and resolution of major discrepancies identified, as defined 

in paragraph I 0, below will also be tracked. 

8. The addition or relocation of any lab pack processing area(s) shall be considered a Class Ia 

peanit modificalion under AppaldiJ< B.3 of OAC Rule 3745-50 if the following aiteria are 

comparable to any already existing lab pack processing m:ea: 1) vapor recovery; 2) aisle space;. 

3) currently peanitted hazardous waste area; 4) fire suppression and deleclion systems; 5) spill 

containment; 6) isolation; and7) a=sibility. 

0 9. For each Lab pack shipmart, the generntor shall certiiY as follows: 

"To the best of my knowledge, all labels on the inner and outer containers, and all 

infurmation recorded on the paclcing inventory sheet for each Lab Paclc, correctly 

identifies lhe conlained" chemicals. Where testing has beat necessary to c:han!cterize 

material in the lab pack, I have used test methods equivalent to those specified in the 

Pemrittce's current operating permit Lab PBclr Procedure." 

JAN I 5 lllln 

C-81 

OHIO EPA NEDO 

VESD16383 
c 

c 

Heritage- WTI, Inc . 

. OHD98061354f 

Revision: 22 

November 10,2009 

10. Using the system described in paragraph 7.C~ above, the Pen:nittee shall track the following 

disc:repi.ncies noted under the lab pack audit program, and other discrepancies deemed by the 

Permittee to be major: 

a) Major discrepancies include: 

I) Extra or unknown material in the lab pack and not on the inventory sheet that if 

wtdiscovered would have result in an activation of the contingency plan, a permit 

violation, or a serious safety hazard. 

2) Incompallble material packed together in the same outer container. 

3) Sharps that were not packed in a rigid container. 

4) Free liquids in an outer container. 

5) Lab pack(s) not pre-approved before anivaJ (inventory sheet and/or manifest not 

received by the W:ility prior to receipt oflab pack 

b) Minor discrepancies include: 

I) Extra or unknown material in a lab pack and not on the inventory sheet that is 

acceptable at the fucility and would not result in issues described in IO.a).l) of this 

section. 

2) More than one inner container broken in transit. 

3) Grossly insufficient quantity of absorbent in the lab pack; and 

~ Other disaepapcy (IES) not specifically listed. 

C-82 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016384 
0 

c 

Heritage - WIT, Inc. 

OHD980613S41 

Revision: .22 

November,IO, 2009 · 

c) If a geo.eratorfcustomer should at any time exceed a ten perocot (Hl"lo) major 

discrepancy rate per load, that getJerator/customer will be retrained and 100% of the 

disctepant load will be audill:d. All future loads received from that 

generator/customer would also be audited at 100% until their discrepancy rate falls 

below S%. 

d) If a major discrepan.cy is found in a Jab pack packaged by a WI1 Ficld Cb.cmist, I 00% 

of that load will be audi.tcd and the Field Chemist retrained. 

II. The Paurittcc sball designate in their injury Jog any injuries associated wi1h lab pack depacking 

operations. The Permittee sba1l notify the Ohio EPA of any releases from a lab pack(s) lha1 

results in the acli"lllinn of the facility's response team. 

12. The OEP A shall have the right to cause the Paurittee to temporarily restrict or disallow receipt 

of lab packs from any specific customer who demonstrates a contimling history of significant 

packing disaqJancies or a history of shipping lab packs which result in injury or release. 

13 . Lab pecks may be stored 81 the facility for up to a year. However, the Permittee may store ljlb 

poclcs beyond a ye~S provided such storage is soldy for the puqlOSC of accumulation of soch 

quantities of ba2mdctJS waste as are necessary to facilitate prop« recovery, lrea!ment, or 

disposal. 

C-83 JAN 1 5 2010 

OHIO EPA NEDO 

VES016385 
0 

0 

\.._ , 

Heritage-.wn. Inc. 

OHD980613541 

Revisioti: 22 

November I 0, 2009 

14. Lab Packs shall be stored, audited, and otherwise handled under an appropriate foam or similar 

(balon, etc.) fire protection system at all times . . 

15. Lab Packs may only be received from generators/packers who have successfully completed the 

Permittee's lab pack training program, or from generators where the facility's field Chemists 

have packed or directly supervised the packaging of the lab Pack(s). Records shall be 

maintained of generators who have successfully completed such training. 

16. Each lab pack shall contain only mutually compatible material as defined in the Pennittee's 

waste analysis plan and shall meet all applicable DOT requirements. All inner containers must 

be labeled in such a way that the container can be matched to the corresponding packing 

inventory sheet All outer containers must bear all app)jcable U.S. EPA labels, plus a HMIS 

label and profile number or other unique container identification number. 

17. Each lab pack shall contain a sufficient quantity of compatible absorbent to absorb all liquid 

(wcluding all liquid held within all inner containers) in the lab pack. All inner containers must 

be non-leaking at the time of packing, or overpacked to prevent leakage of contents. For waste 

materials which must be kept under liquid to prevent increased reactiviiy, the inner container 

must either be made of polymeric (or other suitable) material which resists breakage, or 

overpacked in a larger inner container of such .suitable break-resistant material. 

18. Each lab pack shall be limited to no more than 55 gallons total volume. This requirement does 

not prohibit protective overpacking of 55-gallon containers within larger containers. 

JAN 15 7010 

OHIO EPA NEOO 

VES016386 
C' 

Heritage- WTI. Inc. 

OHD98061354l 

Revision:· 22 

November I 0, 2Q09 

19. The Permittee shall not intentionally teed lab pack(s) to the incinerator that results in a waste 

feed cut-off due to over-pressurization of the Incineration System. The Permittee sball have 

measures in place to evaluate tbe beat content and release rate of lab paclcs waste in order to 

avoid feeding problematic lab packs to the kiln. Complian<:e of feed/metal limi1s for Jab paclc 

materials will follow the currently approved waste handling methods. 

20. The Ohio EPA reserves the right to temporarily suspend approval ofa lab pack w'PS if the lab 

pack causes an accident at the facility and the Ohio EPA detc:nnines the suspension is 

appropriate based on the MIUre and/or severity of the accident 

C-85 

JAN 1 5 201ij 

OHIO EPA NEDO 

VES016387 
_ ...... ___________ _ 

0 

0 

VES016388 
("" ' . Heritage- Wll, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

C2e(3) Specl& Procedures for Acceptance of Loose Pack Shipments 

The loose pack program bas been developed to provide a management method to describe and 

document the procedures for waste shipped to the facility as loose packs 

1. "Loose. pack'' shall be defined as an outer container unit that contains inDer containers of 

commercial products or consumer materials contained in packages of five gallons or less. 

Loose pac.ks will not be acapted from laboralories. Multiple-waste COill8iners gcnented 

from laboratories will be processed as lab packs. All material must Call uoder at least one 

of the categories described below ill order to be acceptable for management under 1his 

program. 

The categories ofloose paclcs are defined as follows: 

a. Drum consolidation of industrial process materials that arc to be discarded in the 

original packaging or poured together into a larger container. The original 

containers may n:qulre disposal and are not present to provide secondary 

contaimnenl Examples include solvents, some acids, some bases, paint , cleaners, 

oils, ere. An inventory sheet is not required bccanse the Was~~:; Profile Sheet (WPS) 

provides a complete desaiption of the properties, constitneats, and ranges that are 

acccplable, although an invc:zuory sheet may be included. These loose paclcs are 

managed as 'L' profiles. 

b. Consolidated consumer packaged materials in the original packaging, which are 

readily available in cotnm.crc:c for hou.~ld use, aJldlor which may be individually 

purchased and discarded by the general public. Examples include materials 

gathered during household hazardous 'l'aste collection events and consumer 

commodities that have been returned to the generator. These loose packs are 

managed as 'L' pro6.1es. 

JAN 15 7011J 

C-86 OHIO EPA NEDO 

VES016389 
Heritage - WIT, Inc. 

OHD980613S41 

Revision: 24 

April !, 2010 

e. Drum c:oosolidatlon of ooosumer materials that pos~s unique bazatds that are best 

addressed througll restrictive packaging. For these loose paclcs, inner containers 

and/or special stongc may be used by the facility to be protective or to meet 

operational oonstnints of the facility. The p•clrnging and perhaps the actual hazards 

of the material may preclude fingerprint analysis or other stipulatiollS os discussed 

later in this plan. Examples include those types of waste listed in Section C-la(2) of 

this tloconm:nt, which discusses restricted wastes. These loose packs are managed as 

'X' profiles. 

2. Loose pack waste profile templates have been created for the most common COIIliru:n:ia1 

prochu:ls and c.onsamer materials acor:ptable in. this program. Customers se.lcc:t the templates 

that are applicable to their waste 8lld sign a catification fur the "lief' of templates selected. 

The only unique information is the geocrator and cu.<;tomer information and their selection 

/'. of templates. Revisions to any individual loose pack profile will be done in accordaocc to \ I 

.._ .; section C-lb(2)(v) 

In addition to the current waste profile numbctiog systttn, the Jetter suffixes of 'L' and 'X' 

are used exclusively to identify the categories of loose packs (as clesctibed ~vc). The 

Jetter 'L' as a suffix signifies a profile with potcntiaDy intact inner containcta which require 

a visual inspection and auditing. The letter 'X' as a suffix signifies a profile which should 

not be sampled or opeoed because of the poteotiaUy high level of risk to the s.lmpler and/or 

laboratory penoDDd. Wbeo cll:cmed nee - ry by the Material Processing Mmaget, 'X' 

profiles may be opeoed for visual inspection. 

C-87 

APR 1 5 201Q 

VES016390 
c 

c 

Heritage- WTI, Inc. 

OHD980613S41 

Revision: 22 

November I 0, 2009 

3. All loose packs received shall contain materials that ilfe compatible, acceptable, and welldefined. Only compatible chemicals from a similar chemical family will be permitted on 

the constituent list of any given profile. Loose pack profiles may contaio debris, including 

the original small contaioer that held the consumer-paclcaged material. These small 

containers may or may not be intact. 

4. The loose pack. program is intended for wastes that are in the original container with 

original labels. If cootaiocrs of unlcnowns, waste not in the original container and/or 

containers that are not labeled, are discovered dwing inspection, audit, or inventory 

activities, those containt:rs shall be removed from the loose psclc. The conlaioa oontcnls 

will be analyud for acceptability, plared in a facility lab pack, and either incinerated, 

rejected back to the geoerntor, or transferred to 81lother facility for tn:ao:nent. 

Wastes prohib;ted from the "loose pack program can be found in section C-Ia of the 

facility's Part B pamit application, Section C- Waste Chaiacleristics and Waste Analysis 

Plan. 

S. Loose packs shall be packed in accordance with the most recently updated Loose Pack 

Program Information and Guidelines. The Penuittee shall modify this standard operating 

procedure (SOP). with Ohio EPA co11CUlralCe, when necessary and fumi.sh the Ohio EPA 

with a copy within thirty days of such chaoges. 

6. The Permittee will open and perform a visual inspection of every L-suffixed loose pack 

container to ensure genc:ni! compliance with a1e waste profile sheet. This visual inspection 

should not be confustd ·with container audits, di.salssed m item 7 below. The visual 

fnspectioo will be done to determine: 

a. The oontamer contents are of a physical state that matc.hes the profile; 

b. The outer container is acceptable for storage pursuant to OAC 3745-55·71; and 

c. All visible inner containers have labels from original packaging. 

C-88 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016391 
c 

0 

c 

Heritage - WIT, Inc. 

OHD980613541 . 

Revision: ' 22 

November I 0, 2009 

7. Ten (10) percent ofloose pack containers per each manifested line item will be' audited to 

determine whether the containers were packed according to the guidelines and whether the 

contents of the containers match the specific constituents listed on the waste profile sheet. 

a. Auditing shall be defined as: 

I) Opening lhe outer container, 

. 2) Recording lhe size, quantity, and main chemical of the inner containers, 

4) Verification of lhe information on the . inner container labels against the 

constituent list in the WPS; 

5) VeriJying all inner containers are labeled OR somehow identified; and 

6) Removing any oontainers as necessary for further evaluation. 

When multiple kinds of commercial products or consumer materials are packed 

· inside the outer container, an accunte representation will be recorded. lfth~ is not . 

a chemical listed on the illDer container, the trade name and type of product will be 

recorded (e.g. waxes, epoxy, adhesives, and paints). When an inventory sbeet is 

attached to the outer container, the Permittee will verify that the inventory matches 

the container's contents, and record the profile and drum number on the inventory 

sheet 

b. Auditing frequency shall be conducted as described above. The designation of the 

loose pack containers to be andited will be randomly selected by the computer 

system. In the event of a compullr system failure, the loose pack containers to be 

sampled will be designated by supervisory personnel. The computer system will 

designate ten (I 0) percent for each manifested line item of each manifested 'L'-

suflix container to be audited prior to releasing the waste for processing. Loose 

packs with an 'X' suffix will not be audited. For shipments where discrepancies are 

discov~ during inspection, audit, and inventory activities, the number of 

containers audited from that shipment wiU be increased. For shipments where 

discrepancies are discovered, the auditing percentage will be increased from ten (I 0) 

percent to a minimum of twenty-Jive (25) perceot per each manifested line item. 

C-89 

JAN 1.5 ?flll) 

OHIO EPA NEDO 

VES016392 
c 

c 

c 

Heritage - WTI, Inc. 

OliD98061354! 

Revision: . 22 

November 10, 2009 

c. Auditing documentation shall be maintained by the Pennittee. The Pernrittee shall 

develop and utilize a tracking system designed to record and access infunnation on 

the number of loose packs received, and the number, description and resolution of 

discrepancies, as defined below. 

8. Discrepancies found in loose pack containers may include any of !be following examples: 

a. Loose pack containers that have an unlabeled inner container, unless other 

identification is )liOVided that sufficiendy describes the waste. . 

b. Loose paclc containers that have inner COiltainers that are not in the original 

paclcaging, unless original label is included, but are labeled. 

c. Loose pack sbipmeots in which inner containers exceed 5 gallons in volume. 

d. Loose paclc containers that, wheo audited, do ~t confonn to paclcaging 

specifications given in the facility's loose Pack Program Information and Guidelines 

and cannot be safely repackaged to meet the loose paclc program infonnation and 

guidelines . 

. e. Loose pack containers that, when audited, have constituent~ not listed on the WPS 

and are either compatible, incompalible, or prolubited. 

f. Loose pack containers whose processing results in the activation of the fuctlily's 

Contingency Plan. 

When a discrepancy is discovered, the Permittee may take one or more of the following 

actions: 

a. Reject the loose pack baclc to the generntor or to an alternate facility; 

b. Revise the waste stream profile to reflect the discrepancy, if appropriBte; 

c. Re-train the generator/customer on the facility's Loose Pack Progxam Infonnation 

and Guidelines; and/or 

d. Repackage the loose pacl.c to meet the facility's loose pack criteria. 

C-90 

JAN 1 5 2010 

OHIO EPA NEDO 

VE$016393 
c 

0 

0 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

9. The LQose Pack Program is only available to specific customer locations that ship waste to 

the facility. The program is designed for full-service cuslotners who perform waste 

consolidaiion and manifesting for generators, either trom treatment, storage, AND disposal 

facilities (TSDF) or trom waste genexating sites. Under this prog,:am, the Permittee will 

provide the customer with a set of existing loose pack templates and a copy of the LOose 

Pack Progl'31D Information and Guidelines. A customer interested in the program will 

initiate the service by requesting participation and submitting a signed copy of the desired 

profiles. 

A detmnination will be made whether a THE customer meets the Permittee's standards for 

preparing loose pack containers. This detenninatiou will be based upou information such as 

the customer's shipment discrepancy record, technical abilities, site cleanliness, and 

environmental compliance. Facility petsonnel will visit the customer's facility at least once 

prior to their acceptance into the progJ:am, and the Pennittee ~ continue to review the 

customer's qualifications during any additional routine site visits. Facility personnel will 

also conduct a formal review of a customer's loose pack records on an annual basis. 

I 0. Loose pack containers may only be received trom customers who have successfully 

completed the Permittee's loose paclc training program, or trom customers where fuciljty 

personnel have packed or directly supervised the packaging of the loose pack collfainers. 

Records shall be maintained of customers who have successfully conipleted the initial 

training and refresher training (records to include at a minimum, d8te of training, attendees, 

training content). Facility personnel will provide specific training to assist customers with 

the following services pertaining to loose pack profiles: 

a Training on the intent and use of!oose pack profiles; 

b. Evaluation of chemicals for inclusion under the appropriate teinplate; 

c. Determination of proper packaging criteria for each loose pack profile; 

C-91 JAN 1.5 2010 

OHIO EPA NEDO 

VES016394 
0 

c 

Heritage - WTI, Inc. 

OHD980613541 

Revision: 22 

November I 0, 2009 

d. Training on load preparation (proper packaging) of these materials; and 

e. Refresher training as necessary, based on the numb« of discrepancies and whether 

non-conformance to the program is high. At a minimwn. refresher training will be 

provided if greater than SO% audited containers have discrepancies within a 

calendar year. 

I I. The Ohio EPA may require the Permittee 10 temporarily restrict or disallow receipt of loose 

pack containers from any specific customer who demonstrates a continuing history of 

significant pacDog discrepancies or a history of shipping loose pack containers which result 

in injwy or release. 

The Ohio EPA may also require the Permittee to increase the auditing percentage of loose 

packs if there has been a significant increase of loose pack containers manifested per each 

tnallifest line itan. 

12. The Pemtit:tee wiU manage feed paramei.O{s fur loose pack containers using the same 

procedwes as all other containers processed at the facility. All aspects of the facility's feed 

limit scheduling procedure will be followed. Because loose pack materials are a category of 

miscellaneous speciat wastes, a representative sample cannot be taken. Therefore, 

analytical results of these containers cannot be used to calculate metal feed rates. For this 

reason, the high end metal range of a given profile will be used to calculate metals feed 

rates. These i:anges may be modified on a case-by-case basis for specific OODiainer:s based 

on generator inforrnationlk.nowl.edge of the exact content of the constitoents in the waste. 

This is the most conservative approach used in the cwrem feed limit scheduling hierarchy. 

C-92 JAN l 5 2010 

OHIO EPA NEDO 

VES016395 
c 

0 

C..2e(4) 

Heritage- WTI, Inc. 

OHD980613541 

Revision: 22 

November 10,2009 

Specific l'roc:eduns for Acceptance of Mixed Infectious and Hazardous Waste 

1. Mixed infectious and hazardous waste (MIHW) is defined as infectious waste that is also 

hazardous waste as specified in Ohio Administrative Code Rule 3745-51-03, and thus 

requires the application of ooe or more hazardous waste codes in order to be managed as 

hazardous waste. 

a) InfeCtious waste must also be hazardous waste to be managed as MIHW. 

b) 

Infectious waste cannot be managed at the facility. The tenn "managed" includes 

acceptance, processing, staging, storage, and/or treatment by incineration. 

Examples of MIHW include vaccines, pharmaceutical waste, material resulting 

from decontamination proc:edures in triage, clean up from natural disasters, or waste 

from testing and/or research fucilities 

c) Io accordance with ba:zardous waste regulations, all MIBW is to be shipped on a 

bazllrdous waste manifest. 

d) MIHW will only be llllll;8ged 81 the facility in accordance with the requirementS 

and time limitations stated in the fllcility>s Part B permit application and Ohio 

Hazardous Waste Facility Installation and Operation Permit (Permit). 

C-93 

JAN 1 5 2010 

OHIO EPA NEDO 

VES016396 
• Heritage- WTI, Inc. 

OHD980613541 

Revision: 22 

November 10, 2009 

e) MIHW will only be processed at the facility through certain feed mechaniSms 

(queuing lanes of the feed conyeyor, bucket hoist, direct drum pump-out stations,· 

direct tanker bays) and will arrive at the facility packaged as "kiln-ready" waste. 

f) MlHW will be managed as "high priority" waste. The Permittee will make all 

attempts to incinerate "high priority" MJHW within 48 hours of receipt (manifest 

is signed) at the facility. 

g). MIHW will be processed, staged, and/or stored in accordance with time 

limitations stated in the Part B permit application. lf MIHW cannot be 

incinerated within 48 boms of receipt (signing of the manifest), an update will be 

• . provided to Ohio EPA as soon as possible. 

• 

b) On occasioi:t, and with sufficient justification, Ohio EPA may allow additional 

time for managing this waste . 

C-94 JAN 15 2010 

OHIO EPA NEDO 

VES016397 
c 

c 

0 

Heritage - W11, Inc. 

OHD980613S41 

Revision: 22 

November I 0, 2009 

i) The Petmittee will follow sUu!dJud operating procedures (SOPs) for the 

management of MlHW, including applicable notification requirements. All SOPs 

will be made available to Ohio EPA upon request for review and inclusion of 

· comments. If significant changes are made to SOPs regardi.og the management of 

MmW, the Penni nee wl11 submit those SOPs to Ohio EPA for review and 

i.oclusion of oommc:ots. 

2. The Pennittee will provide generatonlc:ustomers with written guidance and/or training so 

that shipments of MIHW anive at the facility as ''kiln-ready" in the appropriate 

packaging, concentration, size,,quantity, type, and as scheduled by the facility, to ensure 

safe handling and incineration ot the facility. 

a) The Permittee shall tDOdify any written guidelioes as necessary and furnish Ohio 

BP A with a copy of the modified guidelines as soon as possible after the cl!anges 

have been made. 

b) The Permittee will audit a generator/customer's records prior to scbeduli.og the 

first shipment of waste from that generator/customer. The audit will include a 

review of waste . generating processes and process areas, waste handling and 

segregation practices, training lll8ierials, and incident reports. If possible, facility 

personnel will visit a generator/customer's facility prior to acceptance of any 

MIHW. 

JAN 1.5 2010 

C-95 

OHIO EPA NEDO 

VES016398