Table of Contents                                                                                                                                                                        i

April 2015

http://www.epa.gov

‐ Final
DISCLAIMER

This manual represents EPA’s current thinking on this topic. It does not create or confer 

any rights for or on any person or operate to bind the public. You can use an alternative 

approach if the approach satisfies the requirements of the applicable statutes and 

regulations. If you want to discuss an alternative approach (you are not required to do so), 

you may contact the EPA staff responsible for implementing this manual. In addition, 

please note that state hazardous waste programs may be more stringent and/or broader in 

scope than the federal program. If you cannot identify the appropriate EPA staff, call the 

number listed in the Acknowledgment. 

ACKNOWLEDGMENT

This guidance manual was developed by the U.S. Environmental Protection Agency’s Office 

of Resource Conservation and Recovery and was funded under EPA Contract No. EP-W-10-

056. For questions about the document, please contact the Work Group Chair: Gail Hansen, 

703-308-0463, hansen.gail@epa.gov.

EPA wishes to acknowledge and thank the following EPA and state representatives for 

providing input into the manual: Mary Andrews (OGC), Jim Aycock (EPA Region 7), Emily 

Chow (OECA), Jace Cuje (ORD), Laura Dahlgren (Georgia), Darleen Groner (Missouri), 

Vishnu Katari (OECA), Christopher Lambesis (EPA Region 5), Sharon Leitch (EPA Region 1), 

Beth Lohman (Virginia), Maliha Nash (ORD), Liz McCarthy (EPA Region 1), Todd Ramaly 

(EPA Region 5), Wray R. Rohrman (EPA Region 7), Tracy Sheppard (OGC), Jan Simmons 

(Georgia), Steve Simoes (Vermont), Don J. Smith (NEIC), Amy Walden (Wisconsin), and 

Stephen Yee (EPA Region 1).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

Table of Contents i

Table of Contents

Acronym List..........................................................................................................iv

Introduction .......................................................................................................... 1

PART ONE: RCRA Waste Analysis – An Overview............................................... 1-1

1.0 What Waste Analysis Requirements Must You Meet? ................................................. 1-1

1.1 Generator and TSDF Waste Analysis Requirements............................................. 1-3

1.1.1 Generator Waste Analysis Requirements ................................................ 1-3

1.1.2 TSDF Waste Analysis Requirements....................................................... 1-10

1.1.3 Transmitting Waste Analysis Information .............................................. 1-13

1.2 How Can You Meet The Waste Analysis Requirements For Your Facility?.......... 1-15

1.2.1 Sampling and Analysis for TSDFs............................................................ 1-17

1.2.2 Acceptable Knowledge and TSDFs ......................................................... 1-19

1.2.3 Waste Analysis for Generators .............................................................. 1-24

PART TWO: Documenting and Conducting Waste Analysis ................... 2-1

2.0 Developing a WAP and Conducting Waste Analysis ..................................................... 2-1

2.1 Content and Organization of the WAP ................................................................ 2-1

2.2 Facility Description.............................................................................................. 2-6

2.2.1 Description of Facility Processes and Activities........................................ 2-6

2.2.2 Identification/Classification of Hazardous Wastes Generated or 

Managed at Your Treatment, Storage and Disposal Facility ..................... 2-7

2.2.3 Description of Hazardous Waste Management Units............................... 2-8

2.3 Systematic Planning .......................................................................................... 2-10

2.4 Selecting Waste Analysis Parameters................................................................ 2-15

2.4.1 Criteria for Parameter Selection ............................................................ 2-16

2.4.2 Parameter Selection Process................................................................. 2-20

2.4.3 Rationale for Parameter Selection......................................................... 2-20

2.4.4 Special Parameter Selection Requirements ........................................... 2-22

2.5 Selecting Sampling Procedures ......................................................................... 2-27

2.5.1 Sampling Strategies and Sampling Frequencies ..................................... 2-28

2.5.2 Selecting Sample Equipment ................................................................. 2-39

2.5.3 Maintaining and Decontaminating Field Equipment.............................. 2-44

2.5.4 Sample Preservation and Storage.......................................................... 2-44

2.5.5 Establishing Quality Assurance/Quality Control Procedures .................. 2-45

2.5.6 Establishing Health and Safety Protocols............................................... 2-50
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

Table of Contents ii

2.6 Selecting a Laboratory and Laboratory Analytical Methods............................... 2-50

2.6.1 Selecting a Laboratory ........................................................................... 2-50

2.6.2 Selecting Laboratory Analytical Methods............................................... 2-54

2.7 Quantifying Data Uncertainty ........................................................................... 2-58

2.8 Determining Re-Evaluation Frequencies ........................................................... 2-61

2.9 Special Procedural Requirements...................................................................... 2-64

2.9.1 Procedures for Receiving Wastes Generated Off-Site ............................ 2-64

2.9.2 Procedures for Combustion Facilities .................................................... 2-67

2.9.3 Procedures for Ignitable, Reactive, and Incompatible Waste ................. 2-71

2.9.4 Procedures for Complying with LDR Requirements................................ 2-71

2.10 Discrepancy Policy ............................................................................................ 2-74

2.10.1 Manifest Discrepancies ......................................................................... 2-74

2.10.2 Discrepancies Between Incoming Waste and Profile.............................. 2-75

2.11 Rejection Policy................................................................................................. 2-76

2.12 Recordkeeping.................................................................................................. 2-76

2.13 Corrective and Preventative Action Measures .................................................. 2-79

PART THREE: Checklist....................................................................................... 3-1

PART FOUR: Sample WAPs................................................................................. 4-1

Example WAP 1: Waste Analysis Plan for ACE Chemical Services............................................. 4-2

Example WAP 2: Waste Analysis Plan of Container Management Incorporated (CMI)........... 4-33

APPENDICES

Appendix A: Hazardous Waste Identification........................................................................... A-1

Appendix B: Regulatory Summary .......................................................................................... B-1

Appendix C: Regulatory Citations for Conducting Waste Analysis ........................................... C-1

Appendix D: Overview of Major Hazardous Waste Management Units ..................................D-1

Appendix E: Glossary of Key Terms.......................................................................................... E-1

Appendix F: Key Considerations and Tips .................................................................................F-1

Appendix G: References..........................................................................................................G-1
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

Table of Contents iii

List of Tables

TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs............ 2-4

TABLE 2-2: Description of Listed Wastes.................................................................................. 2-7

TABLE 2-3: Description of Characteristic Waste....................................................................... 2-8

TABLE 2-4: Sampling Approach Overview.............................................................................. 2-31

TABLE 2-5: Major Sample Types ............................................................................................ 2-33

TABLE 2-6: Applicability of Sampling Equipment to Wastestreams........................................ 2-43

TABLE 2-7: Important QA Elements....................................................................................... 2-52

TABLE 2-8: Laboratory QC Techniques................................................................................... 2-53

TABLE 2-9: Re-Evaluation Frequencies................................................................................... 2-63

List of Figures

FIGURE 1-1: Summary of Generator Testing, Analytical & Documentation Requirements ....... 1-5

FIGURE 1-2: Analytical Requirements for LQGs Determining Applicability of Standards 

under Subparts AA, BB, and CC of 40 CFR Part 265.................................................................. 1-6

FIGURE 1-3: Summary of TSDF Analytical Requirements........................................................ 1-12

FIGURE 1-4: Waste Analysis Data Flow .................................................................................. 1-14

FIGURE 1-5: Waste Analysis Quality – Conceptual Model ...................................................... 1-16

FIGURE 2-1: The Seven Steps of the DQO Process ................................................................ 2-11

FIGURE 2-2: Waste Analysis Parameter Selection Process ..................................................... 2-21

FIGURE 2-3: Illustration of Simple Random, Stratified Random and 

Systematic Random Sampling ............................................................................................... 2-32

FIGURE 2-4: Samplers for Liquid Wastestreams..................................................................... 2-41

FIGURE 2-5: Samplers for Solid Wastestreams....................................................................... 2-42

FIGURE 2-6: Precision Versus Bias ......................................................................................... 2-47

FIGURE 2-7: Example Chain-of-Custody Record ..................................................................... 2-49

FIGURE 2-8: Analytical Methods Selection Flowchart ............................................................ 2-57

FIGURE 2-9: Shipment Screening........................................................................................... 2-66

FIGURE 2-10: Example Waste Profile Sheet ........................................................................... 2-80
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

Acronym List iv

Acronym List

AA Atomic Absorption

AES Atomic Emission Spectroscopy

AK Acceptable Knowledge

ASTM American Society for Testing 

and Materials

BIF Boiler and Industrial Furnace

Btu British Thermal Units

CAA Clean Air Act

CESQG Conditionally Exempt Small 

Quantity Generators

CFR Code of Federal Regulations

CWA Clean Water Act

DOT Department of Transportation

DQO Data Quality Objectives

EPA Environmental Protection Agency

FAP Feedstream Analysis Plan

FR Federal Register

GC Gas Chromatography

HCl Hydrochloric Acid

H&S Health and Safety

HW Hazardous Waste

HWC Hazardous Waste Combustor

ICP Inductively Coupled Plasma

LDR Land Disposal Restrictions

LQG Large Quantity Generator

LQM Laboratory Quality Manual

LWAK Light Weight Aggregate Kiln

MACT Maximum Achievable Control 

Technology

MDP Method-Defined Parameter

mg/L milligrams per liter

MIR Methods Innovation Rule

MS Mass Spectrometer

NELAP National Environmental 

Laboratory Accreditation 

Program

NIOSH National Institute for 

Occupational Safety and Health

NTIS National Technical Information 

Service

NSCEP National Service Center for 

Environmental Publications

NWW Non-Wastewater

OSHA Occupational Safety and Health 

Administration

PCB Polychlorinated Biphenyls

POHC Principle Organic Hazardous 

Constituent

ppm parts per million

QA Quality Assurance

QC Quality Control

RCRA Resource Conservation and 

Recovery Act

SDS Safety Data Sheet

SOP Standard Operating Procedure

SQG Small Quantity Generator

TC Toxicity Characteristic

TCLP Toxicity Characteristic Leaching 

Procedure

TSDF Treatment, Storage, or Disposal 

Facility

UHC Underlying Hazardous 

Constituent

WAP Waste Analysis Plan

WPS Waste Profile Sheet

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

Introduction 1

Introduction

The purpose of this guidance manual is to discuss how a person can perform waste 

analyses and develop waste analysis plans (WAPs) in accordance with the federal 

hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA), as 

amended. The federal hazardous waste regulations are codified at 40 CFR Parts 260 

through 279. The primary audiences for this manual are hazardous waste generators and 

owner/operators of treatment, storage, and disposal facilities (TSDFs). This manual can 

also provide guidance in the development of used oil processor or re-refiner analysis 

plans under Part 279. In addition, the manual can be helpful to federal and state permit 

writers in evaluating WAPs and inspectors/enforcement personnel in determining 

whether a facility is in compliance with its WAP requirements. Note: In discussing the 

WAP, this manual presents federal hazardous waste requirements. Because state 

hazardous waste programs may be more stringent and/or broader in scope than 

the federal program, consult your state’s regulations to learn the requirements that 

apply to you.

This manual has the following objectives:

Part One

 Explains the general requirements in the federal hazardous waste regulations for 

developing a WAP and/or conducting waste analysis.

Part Two

 Presents general and facility-specific guidance on the procedures for developing a 

useful WAP and conducting waste analysis.

Part Three

 Provides a checklist to assist you in conducting waste analysis and preparing a WAP.

Part Four

 Offers facility-specific WAP examples.

The previous edition of this manual was issued in 1994.1EPA has updated the manual to 

reflect experience that the Agency and states have gained since then. Some of the new 

recommendations in this current edition (e.g., for greater use of testing) reflect this 

experience. In addition, this current edition includes important updates and a greater focus 

on issues of particular importance to waste analyses. For example, it includes an expanded 

discussion in Part Two on how to integrate Data Quality Objectives into sampling/analysis 

activities. It also includes new WAP examples in Part Four. These examples are meant to give 

 

1

The 1994 edition can be found at: http://www.epa.gov/epawaste/hazard/tsd/ldr/wap330.pdf.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

Introduction 2

permit applicants and permit writers ideas to consider when preparing or approving a WAP.

This edition also includes information on some changes to the federal RCRA program 

concerning waste analysis requirements that were promulgated since the last edition (e.g., 

new regulations). The following is a list of these program changes:

 Definition of solid waste final rules.

 Alternative requirements for laboratories owned by eligible academic entities.

 Conditional exemptions for military munitions.

 Conditional exemptions for low-level mixed waste storage, treatment, transportation, 

and disposal.

 Organic air emission standards for tanks, containers and surface impoundments [Parts

264 and 265, Subpart CC] 

 Amendments to the Land Disposal Restrictions (LDR) regulations, including the Phase II 

- IV rules

 Revisions and updates to the Test Methods for Evaluating Solid Waste, Physical/ Chemical 

Methods (SW-846) and issuance of the Methods Innovation Rule (MIR).

The above referenced program changes are summarized in Appendix B of this manual. 

Refer to Appendix E for a glossary of terms.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-1

1.

PART ONE:

RCRA Waste Analysis – An Overview

1.0 What Waste Analysis Requirements Must You Meet?

The cornerstone of the RCRA hazardous waste program is the requirement of generators and 

owner/operators of treatment, storage and disposal facilities (TSDFs) to properly identify 

and characterize, through waste testing and/or acceptable knowledge, all hazardous wastes 

that are generated, treated, stored, or disposed of at their site or facility.2 Waste testing 

involves identifying and verifying the chemical and physical characteristics and composition 

of a waste by performing a detailed chemical and physical analysis of a representative 

sample of the waste. A facility may also apply 

acceptable knowledge of the waste in lieu of 

testing the waste, as specified. Proper waste 

analysis3is needed to: 

 Determine whether your waste is a RCRA 

hazardous waste under applicable federal and 

state requirements (which can be more 

stringent and/or broader in scope than the 

federal program).

 Classify the waste according to RCRA.

 Ensure that the waste is managed properly and 

avoid commingling incompatibles.

 Ensure you are complying with permitted 

feedrate (e.g., metal feedrates) and other 

numerical limitations as applicable. 

Waste analysis, therefore, is the pivotal activity for 

properly ensuring that your facility (and any 

subsequent handlers) complies with the applicable 

regulations for proper waste treatment, storage, 

or disposal. 

The majority of RCRA’s waste analysis 

requirements apply to hazardous waste generators 

 

2

This manual presents federal hazardous waste requirements. Because state hazardous waste programs may be 

more stringent and/or broader in scope than the federal program, you should consult your state’s regulations to 

learn the requirements that apply to you.

3

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

General References on the RCRA Program

 EPA Regulations (Title 40) 

http://www.gpo.gov/fdsys/

 RCRA Orientation Manual

http://www.epa.gov/epawaste/inforeso

urces/pubs/orientat/

 RCRA Online (database) 

http://www.epa.gov/epawaste/inforeso

urces/pubs/orientat/

 RCRA Training Modules 

http://www.epa.gov/epawaste/inforeso

urces/pubs/rmods.htm

 Envirofacts (database) 

http://www.epa.gov/enviro/index.html

 RCRAInfo (database) 

http://www.epa.gov/enviro/facts/rcrainf

o/index.html

 TSDF Tool

http://www.epa.gov/epawaste/hazard/t

sd/permit/tsd-regs/tsdf-ref-doc.pdf

 EPA Hazardous Waste Regulations

http://www.epa.gov/waste/lawsregs/regs-haz.htm

 EPA Test Methods for Hazardous Waste

http://www.epa.gov/epawaste/hazard/t

estmethods/index.htm
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-2

and TSDFs. The RCRA generator standards primarily apply to large quantity generators 

(LQGs) and small quantity generators (SQGs).4Briefly, LQGs and SQGs are required to: 

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

 Determine if the hazardous waste is “prohibited” from land disposal under the Land 

Disposal Restrictions (LDR) program (see Part 268). A prohibited waste is a waste that 

does not meet its applicable LDR treatment standards at its point of generation and 

cannot be land disposed until it meets those standards.5If they have a prohibited waste, 

they must either treat it on-site to meet the standards or send it to an off-site treater or 

recycler along with the required paperwork. A waste analysis plan (WAP) is required 

for generator on-site treatment which describes the procedures they will carry out to 

comply with the LDR treatment standards (§268.7).6

 Manage the hazardous wastes in accordance with the applicable Part 262 and 268 

requirements (e.g., accumulate the hazardous wastes only in tanks, containers, or 

containment buildings that meet specified standards, perform periodic inspections).

 Comply with Parts 262 and 268 recordkeeping and reporting requirements (e.g., retain 

waste analysis data).

The requirements for permitted and interim status TSDFs can be found primarily in Parts 

264 through 268 and 270. Concerning the waste analysis requirements, §§264/265.13 

require a TSDF to: 

 Properly characterize hazardous wastes before managing them and repeat these 

analyses as specified (pre-acceptance).

 Inspect incoming shipments that are received at TSDFs from off-site sources for 

hazardous waste management.

 Test their treated waste according to the frequency specified in their waste analysis 

plan to assure that they meet the applicable treatment standards.

 Prepare and follow a WAP that adequately describes the methods, procedures and 

equipment that will be used to perform these analytical requirements. 

 

4

Conditionally exempt small quantity generators (CESQGs) are subject to the regulations at 40 CFR 261.5, including 

the need to make hazardous waste determinations.

5

Land disposal as defined in §268.2 means placement in or on the land, except in a corrective action management 

unit or staging pile, and includes, but is not limited to, placement in a landfill, surface impoundment, waste pile, 

injection well, land treatment facility, salt dome formation, salt bed formation, underground mine or cave, or 

placement in a concrete vault or bunker intended for disposal purposes. The RCRA statute draws no distinction in 

the duration of disposal. “Temporary” placement in a land disposal unit is “land disposal” just as much as is 

permanent disposal.

6

Enforcement of the LDR requirements is based on the treatment standard, not the facility’s waste analysis plan, 

so that enforcement officials would normally take a single grab sample and analyze for all constituents regulated 

by the applicable treatment standards. (See Federal Register 54:120 (23 June 1989). p. 26606.)
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-3

In addition, the TSDF may be subject to analytical requirements elsewhere in the 

regulations, depending on the waste management activities that it performs (e.g., LDR 

treatment, storage of organic waste in containers, feedstream analysis for hazardous waste 

combustors and thermal treatment units). The WAP must specify the methods that will be 

used to meet these other analytical requirements (e.g., see §§264/265.13(b)(6)).

For additional information on these topics, see the references identified in this section. In 

addition, Envirofacts and RCRAInfo can be used to learn about the RCRA-regulated 

universe (e.g., generators and TSDFs) and the types and quantities of hazardous wastes 

generated and managed by them.

1.1 Generator and TSDF Waste Analysis Requirements

Following is a summary of some of the analytical and related requirements that apply to 

generators and TSDFs. See Appendix C of this manual for more detailed information, 

including the regulatory references, of many of the RCRA waste analysis requirements to 

which generators and TSDFs are subject.

1.1.1 Generator Waste Analysis Requirements

Persons who generate a solid waste are obligated under 40 CFR 262.11 to determine if 

their wastes are hazardous. If a hazardous waste generator intends to send the hazardous 

waste to a TSDF, he may be required to provide waste-related information to the TSDF, 

such as a waste profile (see Section 1.1.2 on pre-acceptance) or information that 

accompanies an LDR notice with a shipment (see the “Generator Paperwork Requirements 

Table” at §268.7(a)(4)). A generator is not required to prepare a WAP unless he is 

managing and treating waste or contaminated soil in tanks, containers, or 

containment buildings regulated under §262.34 to meet applicable LDR treatment 

standards. Figures 1-1 and 1-2 provide an overview of the RCRA waste analysis and WAP 

requirements that apply to generators. 

As a generator, you must determine if the waste generated is a RCRA hazardous waste, as 

required by §262.11, by: 

 First determining if your waste is excluded from 

regulation (see the solid and hazardous waste 

exclusions at §261.4(a) and (b));

 Then determining if it is listed as a hazardous waste in 

Subpart D of Part 261; and

 For purposes of compliance with the LDR Program in 

Part 268, or if the waste is not listed in Subpart D of Part 

261, determining whether the waste exhibits any of the 

hazardous characteristics in Subpart C of Part 261. You 

may test the waste or use acceptable knowledge to 

Applicability of WAPs to 

Generators

A generator is not required to 

prepare a WAP except when 

managing and treating waste or 

contaminated soil in qualified 

units to meet applicable LDR 

treatment standards found at 

§268.40. See §268.7(a)(5) for this 

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

PART ONE: RCRA Waste Analysis – An Overview 1-4

make the determination. (See Section 1.2.2 of this manual for a discussion of some of the 

types of information that EPA would consider “acceptable” knowledge.) See Appendix A 

for additional information on hazardous waste identification procedures.

If you have generated a hazardous waste or acute hazardous waste, you must determine 

the amount of hazardous waste that you generated during that calendar month, as 

required by §261.5. You then must determine whether you are a small quantity generator 

(SQG), large quantity generator (LQG), or conditionally exempt small quantity generator 

(CESQG):7

 SQGs (generators of > 100 kg/month and < 1,000 kg/month of hazardous waste) are 

subject to regulation under Part 262 and other applicable parts (e.g., Part 268). 

 LQGs (generators of ≥ 1,000 kg/month of hazardous waste) are subject to regulation 

under Part 262 and other applicable parts (e.g., Part 268). 

 CESQGs (generators of ≤ 100 kg/month of hazardous waste) are subject to limited 

requirements as specified in §261.5 (e.g., hazardous waste determinations, monthly 

counting). They are not subject to the waste analysis requirements other than hazardous 

waste determinations at §261.5(g)(1).

If you are a LQG or SQG, you must determine if your hazardous waste must be treated to 

meet the LDR treatment standards before being land disposed, as required in §262.11 and 

Part 268. You must determine each EPA hazardous waste code that applies to your 

hazardous waste, which allows you to identify all applicable treatment standards under the 

LDR program. You must refer to the treatment standards in §§268.40, 268.45, and/or 

268.49 to determine if your waste “as generated” must be treated. This determination can be 

made concurrently with the hazardous waste determination described above. You can either 

test the waste or use acceptable knowledge of the waste. Alternatively, you can send the 

waste to a hazardous waste treatment facility subject to a RCRA permit, where the facility 

can make the LDR determinations in accordance with §§264/265.13 and 268.7(b).

If the hazardous waste does not meet the treatment standards, as generated, it must be

treated before being land disposed. Some wastes must be treated by a particular treatment 

method before land disposal while other wastes are subject to concentration-based 

treatment standards. 

In addition, if you are a LQG, you must comply with the organic air emission standards in 

Subparts AA, BB, and CC of Part 265, including a requirement to test the waste or use 

acceptable knowledge of the waste to determine if the air emission requirements apply to 

your units.

 

7

The quantities shown only apply to hazardous waste. For acute hazardous waste quantities, see 40 CFR 261.5(e). 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-5

FIGURE 1-1: Summary of Generator Testing, Analytical & Documentation Requirements a

If you treat on-site in tanks, containers, 

or containment buildings to meet LDR 

standards, prepare and follow a WAP 

(268.7(a)(5)) to test waste and comply 

with other applicable LDR requirements

Ship wastes meeting treatment 

standards to disposer with required LDR 

notice/certification (268.7), or if a 

characteristic waste is rendered nonhazardous, prepare/file the 

notice/certification (268.9)
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-6

FIGURE 1-2: Analytical Requirements for LQGs Determining Applicability of Standards under 

Subparts AA, BB, and CC of 40 CFR Part 265 a
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-7

LDRs: Underlying Hazardous Constituents

If you determine that your waste exhibits a 

hazardous waste characteristic, you must also 

determine whether the hazardous waste contains 

underlying hazardous constituents (UHCs) (there 

are no UHCs for listed waste), as required by 

§268.9(a). A UHC is any constituent listed in 

§268.48, Table UTS—Universal Treatment 

Standards, except fluoride, selenium, sulfides, 

vanadium, and zinc, which can reasonably be 

expected to be present at the point of generation of 

the hazardous waste at a concentration above the 

constituent-specific UTS (§268.2). To determine 

whether you need to be concerned about UHCs in 

your waste, go to the Table -- Treatment Standards 

for Hazardous Wastes in §268.40. The table shows, 

for example, that a D001 non-wastewater 

exhibiting the ignitability characteristic, except for 

the High TOC subcategory, has a treatment 

standard expressed as “DEACT and meet §268.48 

standards; or RORGs; or CMBST.” This means that, if 

you choose to treat it using deactivation, you (or the 

treater receiving your hazardous waste) must 

determine what the UHCs are in your hazardous 

waste. Then, you can go to Table UTS in §268.48, 

which lists the regulated constituents (i.e., UHCs) 

and their respective treatment standards expressed as concentrations. The waste must be 

treated to both eliminate the characteristic(s) and meet the UTS treatment standards for the

UHCs, as indicated in the table. Compliance with the treatment standards is based on grab 

sampling, unless otherwise noted in the table. Compliance with the wastewater treatment 

standards is based on the maximum for any one day, except for D004 through D011 wastes 

for which the previously promulgated treatment standards based on grab samples remain in 

effect. (See §268.40(b).)8 

 

8

Compliance with LDR treatment standards for nonwastewaters is based on grab sampling (i.e., a one-time sample 

taken from any part of the treated waste), rather than composite samples (i.e., a combination of samples collected 

at various locations for a given waste, or samples collected over time from that waste). The Agency believes that 

grab samples generally reflect maximum process variability and thus would reasonably characterize the range of 

treatment system performance. (See Federal Register 54:120 (23 June 1989). p. 26605 and Federal Register 

55:106 (1 June 1990). p. 22539.) The grab sample also meets the ultimate objective of the LDR program that all of 

the hazardous waste to be land disposed be treated in a way that minimizes threats that land disposal could pose, 

not just the average portion of the waste to be so treated (a possible result of using composite sampling). In 

addition, since grab sampling is based on an individual sampling event, it facilitates the collection of data to 

evaluate compliance. This is discussed further in Section 2.5.1 of this manual. 

Applicability of UHCs to 

Treatment Residuals

Generators of characteristic hazardous 

wastes are required to identify any 

underlying hazardous constituents 

reasonably expected to be present above 

their concentration-based levels (see Table 

UTS in §268.48) at the point of generation. 

This means that, for metal constituents that 

did not qualify as UHCs in the original waste 

but are concentrated to above UTS levels 

during treatment, treaters are not expressly 

required to further treat the residuals such 

that those metal constituents meet UTS 

levels. If, however, the residual exhibits a 

characteristic due to a new property (e.g., 

concentrated metals now exceed one or 

more of the constituent-specific Toxicity 

Characteristic thresholds), residuals exiting 

the treatment unit would be considered a 

new point of generation, the treater would 

be considered to be the generator, and the 

full suite of UHCs must be reconsidered and 

identified, as appropriate. See Federal 

Register 64:90 (11 May 1999) p. 25411 for 

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

PART ONE: RCRA Waste Analysis – An Overview 1-8

Rules for characteristic wastes under §268.9 require generators to identify all the listed 

and characteristic waste codes that could apply to their waste. If a listed waste also 

exhibits a characteristic, the treatment standard for the listed waste may operate instead of 

the characteristic treatment standard, provided that the treatment standard for the listed 

waste includes a treatment standard for the constituent that caused the waste to exhibit 

the characteristic. In these cases, there would be no need to meet the treatment 

standards for UHCs. However, where the treatment standard for the listed waste does not 

include a treatment standard for the constituent that caused the waste to exhibit a 

Examples of the Applicability of UHCs to Treatment Residuals

Following is a discussion of the applicability of UHCs to treatment residuals. Two scenarios are described and 

analyzed.

Background

Scenario 1: A D007 chromium waste is incinerated. Trace quantities of lead are present in the original waste, 

but at levels below the UTS (thus, lead is not a UHC under §268.2(i)). The resulting ash is no longer 

characteristic for chromium, but lead is now present at levels above the UTS. 

Scenario 2: A D008 lead wastewater contains no underlying hazardous constituents as generated, but is treated 

with dithiocarbamate, a metal precipitating agent. Dithiocarbamate is also a hazardous constituent that 

appears on the list of potential UHCs in §268.48. The dithiocarbamate assists the stabilization of the lead but, 

after treatment, is present at levels above the UTS in the treatment residuals.

Analysis

In both scenarios, the treatment residuals (ash and sludge) demonstrate that the original waste is 

decharacterized. Under §268.2(i), the only UHCs that must be treated and that must meet the Universal 

Treatment Standards (UTS) are those determined to be present above UTS levels in the original waste, i.e., at 

the point of generation--either via testing or generator knowledge. Because the treatment process results in 

non-hazardous residuals, the treatment facility is not responsible for additional testing to determine if any 

different underlying hazardous constituents are added or created during the treatment process itself. 

Furthermore, only the original UHCs must meet the UTS.

However, if in either case the treatment residual is also characteristic by having constituents that are not only 

above the UTS level but also above the TC level, then the residual is a newly-generated hazardous waste for 

LDR purposes. This result is consistent with the definition of generator at §260.10. The result is also consistent 

with the key LDR principle that hazardous wastes must meet LDR treatment standards to minimize threats 

before the wastes are land disposed. For these reasons, the Agency regards generation of a new characteristic 

treatment residual as being a new point of generation for LDR purposes. 

This newly-formed hazardous waste would have to be treated to below the characteristic and any underlying 

hazardous constituents would have to be treated to below their UTS levels.

Thus, in the first scenario above regarding a decharacterized waste with lead in the ash, if the lead is present in 

the ash at or above TC levels (i.e., a new D008 waste has been generated), the lead must be treated to UTS 

levels. Furthermore, the treater has generated the new hazardous waste for LDR purposes and is responsible 

for a new determination of UHCs that are present and that require treatment to UTS levels. The same is true in 

the second example if the dithiocarbamate treatment sludge is characteristic.

See Federal Register 64:90 (11 May 1999) p. 25411 for additional clarification.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-9

characteristic, the waste must meet the treatment standards for all applicable listed and 

characteristic waste codes.

LDRs: Generator WAP Requirement

If you are a generator managing and treating prohibited waste or contaminated soil in 

tanks, containers, or containment buildings regulated under §262.34 to meet applicable 

LDR treatment standards, you must prepare and follow a WAP [§268.7(a)(5)]. The WAP 

must describe all the procedures you will carry out to comply with the treatment 

standards. (Generators treating hazardous debris under the alternative treatment 

standards of Table 1, §268.45, however, are not subject to these waste analysis 

requirements.) The plan must be kept on site in your records for review by inspectors, and 

the following requirements must be met:

 The WAP must be based on a detailed chemical and physical analysis of a 

representative sample of the prohibited waste(s) being treated, and contain all 

Determining Applicability of UHCs During and After Waste Treatment

In determining whether a treatment process has generated a new hazardous waste for LDR purposes and 

therefore is subject to the requirement for UHCs, the Agency looks to the entire treatment process, not to each 

component part. In general, the determination of whether a new hazardous waste is generated--i.e., whether a 

new point of generation for LDR purposes is created--is made at the completion of the treatment process.

 For residuals that are the end product of a one-step treatment process or the end product of a treatment

train, the treater has the obligation to ensure only that the original UHCs meet UTS standards and that the 

treatment residuals are not themselves characteristic. If a treatment residual in this scenario does not 

meet the treatment standards for the original characteristic (i.e., when treatment is ineffective or 

incomplete) and requires further treatment, EPA does not consider the treatment residue to be newly 

generated for LDR purposes. Such a treatment residue, however, cannot be land disposed until it meets 

the treatment standard applicable to the original waste. This situation would normally involve re-treating 

the waste residuals on-site. Any UHCs added or created by the treatment process are not required to be 

treated because there is no new point of generation for LDR purposes. However, if the treatment residuals 

are themselves characteristic due to a new property (e.g., a formerly characteristic chromium D007 waste 

is now characteristic only for D008 lead), then the treater must make a new determination of the UHCs 

present--either through knowledge or additional testing. This is the same obligation that attaches to any 

generator of a hazardous waste.

 For treatment residuals that appear only at intermediate steps of a treatment train, there is no obligation 

to determine UHCs or to determine whether the residual is itself characteristic. Intermediate-step 

treatment residuals are not newly generated hazardous wastes for LDR purposes. Thus, even when an 

intermediate treatment residual is sent off-site for further treatment (such as incinerator ash going off-site

for stabilization and landfilling), §268.7(b)(5) requires only that the UHCs identified at the LDR point of 

generation be identified. There is no such requirement for any new UHCs that may be added or created 

during the preceding steps of the treatment process.

See Federal Register 64:90 (11 May 1999) p. 25411 for additional clarification.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-10

information necessary to treat the waste(s) in accordance with the requirements of Part 

268, including the minimum selected testing frequency. 9

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

1.1.2 TSDF Waste Analysis Requirements

As a TSDF, you must comply with the applicable §§264/265.13 requirements for waste 

analysis and WAPs. Part 264 covers the requirements for permitted facilities/units, 

whereas Part 265 covers interim status facilities/units. Figure 1-3 provides an overview of 

these analytical requirements. The figure identifies the requirement for a WAP at 

§§264/265.13, as well as the analytical requirements found elsewhere in the RCRA 

regulations that must be addressed in the WAP (e.g., the Part 268 requirements for treaters 

and disposers to test treated waste for LDR compliance).10

A TSDF receiving waste from off-site may use generator-supplied information to aid in its 

understanding of the waste it receives and manages. However, the TSDF is ultimately 

responsible for understanding the wastes to ensure compliance with its permit/regulations 

and manage the wastes in a protective manner. If the TSDF relies on generator-supplied 

information, it is important for the TSDF to review and verify this information to 

ensure its adequacy (e.g., by performing fingerprint analyses to determine if a 

shipment matches the manifest).

TSDF Analytical Responsibilities

Sections 264/265.13(a) establish two broad analytical responsibilities that you as a TSDF 

must perform at a minimum:

 Pre-acceptance.

11 Before you can treat, store, or dispose of candidate hazardous 

waste, you must obtain a detailed chemical and physical analysis of a representative 

sample of the waste. At a minimum, the analysis must contain all the information 

which must be known to properly treat, store, or dispose of the waste in accordance 

with Part 264 or 265 and the LDR program. The analysis may include information 

developed under Part 261, and existing published or documented data on the 

hazardous waste or on hazardous waste generated from similar processes. For 

example, studies conducted on hazardous waste generated from similar processes as 

the waste to be managed at the facility may be included in the analysis, as specified. 

The owner or operator of an off-site facility may arrange for the generator of the 

hazardous waste to supply part of the information required, except as otherwise 

specified in §268.7(b) and (c). If the generator does not supply the information or 

 

9

The WAP must also contain procedures for re-treating the waste if it is determined that the waste, after testing, 

does not meet the applicable UTS. It is also important to note that these procedures must be in compliance with 

all Part 268 requirements including, for example, the LDR storage prohibition. 

10 The figure does not address all analytical requirements that may potentially apply to a TSDF.

11 Other terms may be used such as “pre-qualification.”
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-11

supplies incomplete or inadequate information and the owner or operator 

chooses to accept a hazardous waste, the owner or operator is responsible for 

obtaining the information required for compliance.

The analysis must be repeated as necessary to ensure that it is accurate and up to date. 

As with the initial analysis, the owner or operator of an off-site TSDF may arrange for 

the generator of the hazardous waste to supply part of the information required. At a 

minimum, the analysis must be repeated:

– When the owner or operator is notified, or has reason to believe, that the process or 

operation generating the hazardous wastes, or non-hazardous wastes if applicable 

under §§264/265.113(d), has changed; and

– For off-site facilities, when the inspection of incoming shipments, described below, 

indicates that the waste received at the facility does not match the waste designated 

on the accompanying manifest or shipping paper.

 Waste acceptance. If you are the owner or operator of an off-site facility, you must 

inspect and, if necessary, analyze each hazardous waste shipment received at the 

facility to determine whether it matches the identity of the waste specified on the 

accompanying manifest or shipping paper. 

Contents of WAP

Sections 264/265.13(b) and (c) spell out the information that must be included in your 

WAP in order to perform the analyses described in the text above, as well as other analyses 

that may be needed at your facility: 

 The parameters for which each hazardous waste, or non-hazardous waste if applicable 

under §§264/265.113(d), will be analyzed and the rationale for the selection of these 

parameters (i.e., how analysis of these parameters will provide sufficient information of 

the waste’s properties as specified).

 The test methods that will be used to test/analyze these parameters.

 The sampling method that will be used to obtain a representative sample of the waste 

to be analyzed. A representative sample may be obtained using either:

– Appropriate sampling method in Appendix I of Part 261 for the waste; or

– An equivalent sampling method.

 The minimum frequency with which the initial analysis of the waste will be reviewed or 

repeated to ensure that the analysis is accurate, up to date, and representative of the 

waste over time.

 For off-site facilities, the waste analyses that hazardous waste generators have agreed 

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

PART ONE: RCRA Waste Analysis – An Overview 1-12

FIGURE 1-3: Summary of TSDF Analytical Requirements a

tests to determine if sorbent used to treat free liquids is non-biodegradable (264.314 and 

265.314)c

For treaters and disposers under LDR program, tests to assure that treated waste meets 

applicable treatment standards (268.7) and that other applicable LDR requirements are met
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-13

 For permitted TSDFs, where applicable: the methods that will be used to meet the 

additional waste analysis requirements for specific waste management methods as 

specified in §§264.17, 264.314, 264.341, 264.1034(d), 264.1063(d), 264.1083, and 

268.7. (See Figure 1-3.)

 For interim status TSDFs, where applicable: the methods that will be used to meet the 

additional waste analysis requirements for specific waste management methods as 

specified in §§265.200, 265.225, 265.252, 265.273, 265.314, 265.341, 265.375, 265.402, 

265.1034(d), 265.1063(d), 265.1084, and 268.7. (See Figure 1-3.)

 For surface impoundments exempted from the land disposal restrictions under 

§268.4(a), the procedures and schedules described in §§264/265.13(b)(7).

 For owners and operators seeking an exemption to the air emission standards of 

Subpart CC in accordance with §§264.1082 or 265.1083, the information specified in 

§§264/265.13(b)(8).

 For off-site facilities, the procedures that will be used to inspect and, if necessary, 

analyze each movement of hazardous waste received at the facility to ensure that it 

matches the identity of the waste designated on the accompanying manifest or shipping 

paper. At a minimum, the plan must describe:

– The procedures that will be used to determine the identity of each waste managed 

at the facility; and

– The sampling method that will be used to obtain a representative sample of the 

waste to be identified, if the identification method includes sampling.

 The procedures that the owner or operator of an off-site landfill receiving containerized 

hazardous waste will use to determine whether a hazardous waste generator or treater 

has added a biodegradable sorbent to the waste container. Sorbents used must be nonbiodegradable (§§ 264/265.314).

1.1.3 Transmitting Waste Analysis Information

In addition to conducting waste analyses, generators and 

owner/operators of TSDFs that ship waste off-site are 

required to transmit waste-related information to the 

destination facility under the manifest and LDR programs. 

A helpful summary of information-sharing requirements 

under the LDR program can be found in the “Generator 

Paperwork Requirements Table” [§268.7(a)] and 

“Treatment Facility Paperwork Requirements Table” 

[§268.7(b)]. For example, if you are:

 A generator or TSDF that ships waste to an off-site 

(i.e., “designated”) TSDF, you normally will be asked to 

provide waste profile data (e.g., analytical data, 

Adding Waste Codes to an LDR 

Notification (§268.7(a))

An Example

A wastestream, K062, is listed due to 

corrosivity, hexavalent chromium and 

lead. The LDR treatment standard for 

K062 only includes treatment for 

metals. If the K062 wastestream is 

actually corrosive (D002), the LDR 

notification form will need to include 

the waste codes K062 and D002 so 

the treatment facility knows to treat 

the waste for corrosivity also. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-14

Generator

Treatment Facility

Storage Facility

Transfer Facility

Disposal Facility

description of the waste generating process) to the designated facility prior to the initial 

shipment. As discussed earlier, the designated TSDF will review the data as part of its preacceptance process to ensure, among other things, that the waste can be accepted 

according to its permit [§§264/265.13(a)]. If the designated TSDF gives you approval to 

ship, you must transmit the hazardous waste manifest (EPA forms 8700-22 and 22A)

describing the shipment (e.g., RCRA waste codes, DOT shipping description) [Part 262, 

Subpart B] as well as LDR paperwork (e.g., notice laying out RCRA waste codes, etc.) and 

available waste analysis data, as specified [§268.7(a) or (b)]. 

 An owner/operator of a treatment facility, you 

must comply with LDR paperwork transmittal 

requirements specific to treaters as applicable 

[§268.7(b)(3)-(6)]. This includes transmitting a 

notice and certification to the designated facility, as 

specified. It also is important to provide waste 

analysis information when available (including 

any information supplied by the generator, as 

well as waste analysis data developed by your 

facility before and after treatment) to ensure that 

the waste is managed in compliance with LDR 

requirements and the permit.

In addition to generators and TSDFs, hazardous waste transporters and transfer facilities 

also have hazardous waste-related responsibilities, as specified in Part 263. These facilities 

are generally not required to conduct waste analyses. However, to ensure protective

handling, transporters and transfer facility owner/operators need to know the identity of the 

wastes they are handling. They generally rely on the information provided by the generator 

or the TSDF offering the waste for transport as presented on the hazardous waste manifest. 

Therefore, the accuracy and 

completeness of the waste analysis 

performed by the generators and 

TSDFs is important to them and to the 

many individuals (e.g., subsequent 

transporters, emergency response 

personnel) who may encounter these 

materials while they are in transit.

Figure 1-4 depicts the transfer of 

waste analysis information that needs 

to occur among facilities that are 

shipping and receiving hazardous 

waste. It is advantageous for all 

facilities involved to provide detailed 

waste analysis information with each 

shipment of a wastestream, and for 

the receiving facility to verify, through 

FIGURE 1-4: Waste Analysis Data Flow

Information-Sharing under Manifest 

and LDR Programs

Manifest Program

 For generators, refer to Subpart B 

of 40 CFR Part 262.

 For designated TSDFs, refer to 

Subpart E of 40 CFR Part 264 or 265.

LDR Program

 For generators, treaters, and 

disposers, refer to 40 CFR 268.7.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-15

waste analysis, the information that the generator or sender of the waste provided. Doing this 

should increase the likelihood that the waste will be treated, stored, or disposed of properly, 

and reduce the chance of accidents, releases, and mismanagement (e.g., mixing of 

incompatibles).

1.2 How Can You Meet The Waste Analysis Requirements For 

Your Facility?

You can meet the general and specific waste analysis requirements using several 

approaches or combinations of methods. Meeting waste analysis requirements by 

performing waste sampling and laboratory testing typically is more accurate and 

defensible than other options. (The procedures and equipment for both obtaining and 

analyzing samples are discussed in Part Two of this manual. In addition, see Appendix I of 

40 CFR Part 261 for sampling methods.) Section 1.2.1 addresses sampling and analysis. 

Waste analysis information can be acquired by either collecting samples and conducting 

laboratory testing or using published data and generator knowledge of the waste and the 

process that generated it (known as acceptable knowledge, generator knowledge or 

process knowledge). Acceptable knowledge can include, but is not limited to:12

 Process knowledge, whereby detailed information on the wastes is obtained from 

existing published or documented waste analysis data or studies conducted on 

hazardous wastes generated by processes similar to that which generated the waste 

(process knowledge is supported with technical data).

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

 Data on waste composition or properties from analysis or relevant testing performed 

by the generator.

 Information on the properties of waste constituents or, in cases of newly listed wastes, 

data from recent waste analyses performed prior to the effective date of the listings. 

Section 1.2.2 addresses acceptable knowledge.

Generators may use any of the above or other information demonstrated to be relevant in 

making hazardous waste determinations. TSDFs may have process-related permit 

requirements that exceed generator determination requirements. The regulations establish 

more robust waste analysis requirements for TSDFs. At all times, the owner/operator of a 

TSDF is responsible for obtaining sufficient information required for compliance, 

regardless of the completeness or quality of any information received from the generator 

or other parties. Although it may not meet all TSDF analysis requirements, acceptable 

 

12 For additional discussion of acceptable knowledge, see Federal Register 58:176 (14 September 1993) p. 48111, 

Federal Register 59:233 (6 December 1994) p. 62916, Federal Register 62:224 (20 November 1997) p. 62081, and 

Federal Register 68:202 (20 October 2003) p. 59939.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-16

knowledge, as discussed above, may be sufficient for documenting compliance in 

certain circumstances and is required to be used where the Agency has determined 

that no acceptable test method exists (e.g., D003). If the regulatory agency determines 

that a TSDF’s use of acceptable knowledge is deficient, the agency can require the TSDF to 

take additional steps to address such deficiencies.

Many factors influence the determination of WAP requirements. Some permit conditions 

require compliance with precise numerical values. Other permit conditions can be met with 

less sophisticated testing or simple direct visual inspection. Wastes and their matrices can 

be highly variable even within a single shipment. Other waste shipments may be more 

homogenous, but may have higher variability over time, perhaps reflecting seasonal or 

market-based variations in the process generating the waste. All of these factors should be 

evaluated for each waste in developing an appropriate waste analysis plan. In addition, it is 

important for the WAP to address the range of operating conditions, not just when the 

facility is operating at normal conditions, but during planned and unplanned events (e.g., 

consider wastes generated during start-up, shut down, etc.). Figure 1-5 illustrates the 

relationship between waste variability (e.g., the extent to which a waste varies within a 

shipment (heterogeneity) or across repeated shipments) and the need for high quality and 

frequent waste analysis.

FIGURE 1-5: Waste Analysis Quality – Conceptual Model

For example, facilities with constituent feedrate limits may need relatively accurate and 

precise analytic results to verify that concentrations fall within an acceptable range to 

document compliance (such as heavy metal feedrates in support of a risk-based permit 

limit for a hazardous waste combustor or for compliance with the Maximum Achievable 

Control Technology (MACT) standards of the Clean Air Act where the WAP includes 

elements of the MACT-Feedstream Analysis Plan). In addition, variable wastestreams or

wastestreams close to a numerical limit may require frequent analysis to document 

compliance, whereas wastestreams shown to be consistent over time may only require 

Variability of Wastestream

Less More

Less More 

Level of Accuracy and Precision Needed to Document Compliance

Frequent 

High Quality 

Sampling & Analysis

Sampling & Analysis 

or 

Acceptable Knowledge

Frequent 

Sampling & Analysis

High Quality 

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

PART ONE: RCRA Waste Analysis – An Overview 1-17

Considerations for TSDF Pre-Acceptance Procedures

 Specifying circumstances in which generic profiles can/cannot be used so they are not inappropriately used, 

if applicable. For purposes of this manual, a generic profile (also called a “standard profile”) is defined as a 

profile that could be used for multiple wastestreams that are similar in physical and chemical properties.

Generic profiles may not be acceptable in a number of situations, e.g., if the TSDF’s treatment/disposal 

processes must meet numerical limits.

 Sampling of wastes during pre-acceptance under certain circumstances, e.g., if the TSDF’s 

treatment/disposal processes must meet numerical limits.

 Establishing a recurring process for re-evaluating waste profiles or sending waste profiles to generators 

periodically or as required by state regulation for their review, update, and recertification to ensure that 

profiles are up to date. 

 Carefully examining documentation from the generator supporting its waste profile sheet (e.g., see the 

suggested factors in Section 1.2.2 for evaluating acceptable knowledge).

Considerations for TSDF Pre-Acceptance Procedures

 Generic profiles should be used in limited situations so they are not abused. A generic profile is a profile 

that may be used for multiple waste streams that are similar in physical and chemical characteristics

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

waste determinations.

1.2.1 Sampling and Analysis for TSDFs

Sampling and analysis can be used to meet all waste analysis requirements for a TSDF. 

Frequent and higher quality sampling and analysis, such as analyzing the waste for a broader 

list of hazardous constituents with laboratory instrumentation, may be necessary when:

 A generator begins a new process or changes an existing process.

 Wastes are received by a facility for the first time.

 A generator has not provided appropriate laboratory information to the TSDF.

 The TSDF has reason to believe that the wastes shipped were not accurately identified 

by the generator.

 EPA changes RCRA waste identification/classification rules.

Sampling and analysis can be used to document compliance for pre-acceptance, waste 

acceptance, and other on-site waste management activities. These are described below.

Pre-Acceptance Sampling and Analysis

A TSDF receiving waste from off-site may need to confirm various characteristics of a waste 

at the time of pre-acceptance (profiling) to avoid accepting a generator’s waste that it is not 

permitted to handle. Sampling and analysis may be essential for certain types of wastes 

and/or operations conducted at the facility (e.g., if the TSDF’s treatment/disposal 

processes must meet numerical limits). 

The generator normally submits analytical data along with a “waste profile sheet” (WPS) or 

“waste characterization report” (WCR) and other supporting data to the TSDF to describe 

the generator’s waste. An example of a waste profile sheet is provided in Figure 2-10 of this 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-18

manual. Waste profiles and submitted data are normally used by the TSDF, pursuant to 

§§264/265.13(a), to (1) determine and document with adequate specificity what waste it 

will be managing and (2) assure that it can manage such waste effectively, protectively, and

in accordance with the conditions of its permit and/or governing regulations. 

Waste Acceptance (Fingerprint Analysis)

Waste acceptance sampling and analysis can include rigorous laboratory instrumental 

analysis, testing with field test kits and screening instruments, or by making qualitative 

observations such as visual identification of color, number of phases, etc. The specific 

information needed for waste acceptance may depend on the variability of the waste, the 

accuracy and precision needed to comply with permit requirements, and the stated 

objectives of waste acceptance. 

Two key objectives of all waste acceptance sampling and analysis are to 1) ensure that the 

parameters being tested (e.g., pH) meet permit requirements and fall within acceptable 

limits for effective treatment and management and 2) verify that the incoming shipment 

matches the manifest and is the same waste that was approved during pre-acceptance. In 

regard to this second objective, if a facility’s waste acceptance criteria are too broad (e.g., 

wide pH range), they are an ineffective screen for verifying that the incoming shipment 

matches the originally approved waste. As a result, a TSDF might accept a new or changed 

wastestream that falls within the broad criteria for acceptance but that has vastly different 

properties than the originally approved waste. 

Visual identification of color and number of phases are examples of fingerprint analysis 

that can be used to help verify that the waste generated (or received by an off-site TSDF) 

meets the acceptance criteria and matches the expected characteristics for that waste. 

Other examples of this type of screening include specific gravity, flash point, Btu/lb, pH, 

halogen content, cyanide content, and percent water. For certain types of wastes, verifying 

the packaging form and packaging content of the waste would also be an important waste 

acceptance activity. 

Fingerprint analysis parameters specified in a WAP to verify that each waste arriving at the 

gate of the TSDF is the actual waste expected are often quick screening tests or 

observations since the detailed chemical and physical properties of the waste are usually 

obtained under pre-acceptance sampling and analysis, subsequent sampling and analysis at 

the TSDF, or from acceptable knowledge. Fingerprint parameters and the criteria for 

acceptance/rejection of the waste will be discussed in Part Two of this manual. 

As another example, fingerprint analyses may be done to track metal concentrations in a 

highly variable wastestream to document compliance with permitted feedrates. This type of 

acceptance sampling could require sophisticated analysis using laboratory methods. 

Although key parameters can be used to obtain a representation of waste composition 

quickly, owner/operators should be aware that EPA will generally measure compliance 

with the hazardous waste regulations based on a detailed chemical and physical analysis of 

a representative sample of the waste(s) in question. As a result, it is important for the 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-19

selection of key parameters to be based on sufficient waste profile knowledge and data 

testing frequency to ensure accurate waste representation on an on-going basis.

Other Information Needed for TSDF On-site Management

In addition to the analytical results from pre-acceptance and acceptance, other analytical 

information may be needed to document a TSDF’s compliance with permit conditions. An 

example is verifying whether LDR treatment standards have been met as a result of on-site

waste treatment. Note that sampling and analysis may be particularly important to verify 

the achievement of numerical limits (e.g., feed rates for combustors, organic constituent 

levels for wastes subject to the organic air emission standards in Subparts AA through CC 

of Parts 264 and 265). 

1.2.2 Acceptable Knowledge and TSDFs

While waste generators are responsible for making accurate hazardous waste 

determinations under §262.11, TSDFs are not relieved of their responsibility to obtain 

accurate waste analysis data despite the submission of information provided to the TSDF 

by generators. Acceptable knowledge can be used to provide information for preacceptance (profiling) needs, as well as information needed to comply with permit 

requirements. However, acceptable knowledge may not be an appropriate substitute for 

fingerprint or spot check procedures except in unique cases such as when the TSDF is 

accepting properly manifested waste from another site owned by the same company using 

the same processes. 

Considerations for TSDF Acceptance Procedures

 Fingerprinting ≥ 10% of the containers of each wastestream shipped from each generator.

 Using a tiered approach for analyzing incoming shipments, whereby all shipments are 

inspected/fingerprinted and non-conformances between shipment and waste profile sheet (WPS) trigger a 

mandatory evaluation to resolve it and update the WPS (or create a new one) if needed.

 Documenting tolerance limits for at least one fingerprint parameter based on the operating requirements of 

the facility’s management systems, such as a +/- 2 pH unit difference between the shipment and that of the 

pH in the profile. If the pH of an incoming shipment falls outside this range, the value would be considered a 

non-conformance that should be evaluated and may be subsequently rejected or requalified as appropriate.

 Visually inspecting lab packs as a potentially acceptable alternative to fingerprinting them when protective to 

do so (e.g., open the containers and verify their contents and packing materials) and reviewing their 

inventories (e.g., identify compatibility/potential incompatibility of materials).

 Ensuring that a detailed analysis for the regulated hazardous constituents under the LDRs is completed at 

least annually by the generator or treater (e.g., to verify that treated wastes do, in fact, meet applicable LDR 

treatment standards). See EPA interpretive guidance, Waste Analysis Requirements in Incoming Waste 

Shipments –LDR, which is available at RCRA Online (Number 12943).

 Using a random sampling approach for incoming shipments, whereby the TSDF takes a representative 

sample from a small percentage of incoming waste shipments and performs a comprehensive chemical 

analysis to verify LDR compliance.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-20

On the other hand, there may be situations where it may be sufficient to apply acceptable 

knowledge, such as the following:

 Hazardous constituents in wastes from specific processes are well documented, such as 

with K-listed wastes, presuming that the wastes are not highly variable and accurate and 

precise concentrations are not necessary for documenting compliance.

 Wastes are discarded unused commercial chemical products, reagents or chemicals of 

known physical and chemical constituents, presuming that the wastes are not highly 

variable and accurate and precise concentrations are not necessary for documenting 

compliance. See the P- and U-listed waste categories in §261.33.

 The Agency has determined that no acceptable test method exists to satisfy an 

analytical requirement (e.g., hazardous waste determinations under §261.23 for D003 

reactivity).

 Health and safety risks to personnel would not justify sampling and analysis (e.g., if 

opening a container exposes technician to radionuclides from radioactive mixed waste).

 Physical nature of the waste makes it technically impracticable to obtain a laboratory 

sample. For example, to conduct waste analysis of surface-contaminated construction 

debris, such as steel girders, piping, and linoleum, it may be necessary to use a combination 

of laboratory analysis and acceptable knowledge. The acceptable knowledge would be 

applied to identifying the composition of the base construction materials (e.g., steel). One 

could then collect surface “wipe” samples or, if coated, remove a chip of paint or other 

coating and conduct laboratory analysis to determine the representative concentrations of 

any contaminants present. If the base materials are porous, such as gypsum, the 

contamination could be determined by conducting analysis on the extracts obtained from a 

solvent wash.

When acceptable knowledge is used, documentation is important for presenting the 

information used as the basis for the owner’s or operator’s classification of the hazardous 

waste. Examples of information that may be used as part of the basis for acceptable 

knowledge include: material balances for the source or process generating the hazardous 

waste; constituent-specific chemical test data for the hazardous waste from previous 

testing that are still applicable to the current waste; previous test data for other locations 

managing the same type of waste; or other knowledge based on information included in 

manifests, shipping papers, waste certification notices, and Safety Data Sheets (SDSs, 

formerly known as MSDSs).13

 

13 The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical 

manufacturer, distributor, or importer provide to downstream users Safety Data Sheets (SDSs) (formerly MSDSs) for 

potential hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are 

required to be presented in a consistent 16-section format. Refer to the OSHA Web site for additional information 

(http://www.osha.gov).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-21

Concerns When Using Acceptable 

Knowledge

It is important to consider 

relevant concerns when using 

acceptable knowledge for waste 

analysis purposes. First, if you 

own or operate an off-site TSDF 

and rely on information supplied 

by a generator, it is important to 

understand, to the extent possible, 

the process that generated the 

waste and ensure the integrity of 

the information. Second, it is 

important to scrutinize whether 

there are any differences between 

the waste generation process and 

the process described in the 

published information/data being 

utilized and whether it is current.

Generators and off-site TSDFs may 

use the factors discussed in this 

section, among others, as a starting 

point to make hazardous waste 

determinations based on acceptable

knowledge. Periodic re-evaluation 

of these determinations may be 

necessary because EPA periodically 

revises the criteria that qualify a 

waste as a hazardous waste, or the 

waste properties may change over 

time due to shifting industry 

practices and/or process inputs. 

Therefore, if you use acceptable 

knowledge, you may need to 

review your waste analysis or waste characterization information periodically to verify that 

the hazardous waste determinations you have made are still accurate. In addition, you may 

need to determine if your existing information is sufficient to identify any new constituent 

concentration limitations (i.e., demonstrate compliance with LDR requirements). 

SDSs (aka MSDSs) for chemicals used in the process that generated the waste can be useful 

in identifying the properties of hazardous constituents in the waste; however, it is not 

recommended that they be relied on to exclude possible contaminants. Contaminants may 

be introduced as a result of the production or use of the product and would not be 

identified on the SDS. SDSs typically list constituents present at a minimum of 1% by mass 

Suggested Factors for Evaluating Waste Determinations Using 

Acceptable Knowledge (AK)

 Is published data as current as practicable (e.g., SDSs greater 

than five years old may be obsolete due to changes in RCRA 

program, improvements in testing protocols, etc.)?

 Do material balances, if used, include the following (among 

other things):

 Raw ingredient descriptions and physical and chemical 

properties?

 Physical and chemical processes involved prior to and 

during generation?

 Intermediate products?

 Materials added and removed during the process?

 Is the testing capable of illustrating the properties of the 

waste that are related to the hazardous characteristics?

 Does the generator review its original AK determination 

annually, randomly, and whenever the generating 

process/waste changes or the TSDF finds a 

nonconformance?

 Does the generator understand the potential for changes in 

the waste and its classification due to environmental factors or 

spontaneous changes (e.g., separation of organic solvents 

from a water phase over time, pH changes in contact with 

ambient air, etc.)?

 Are records kept demonstrating that periodic reviews are 

being conducted (e.g., a log or certification by facility 

personnel that is signed annually)?

 Are analytical results of published studies based on 

currently acceptable sample/test methods?

 Are there significant differences between the published studies 

and the site’s generation processes/wastes (e.g., raw materials 

used in the generation process) to warrant concerns about 

relevancy?

 Has the TSDF visited the generator’s site to confirm 

determination?

 Has the TSDF obtained samples of generator’s waste to verify 

the accuracy of the generator’s determination? 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-22

(10,000 mg/kg).Hazardous constituent concentrations much lower than this routinely 

impact hazardous waste management and waste analysis requirements. 

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

 A paint manufacturer used knowledge to identify the hazardous constituents of six 

paint colors. During an EPA inspection, the company produced the documents used to 

make the hazardous waste determinations that had been generated years earlier and 

periodically re-evaluated. EPA noted that the company now manufactured eight colors. 

Through testing, EPA discovered that one of the new paints required barium as a 

coloring agent. Barium is a metal that can cause a waste to exhibit the hazardous waste 

characteristic of toxicity if found in concentrations equal to or exceeding the regulatory 

level for barium at §261.24. However, the company had failed to obtain and review 

information specific to its manufacturing process for the new paint colors and instead 

relied on manufacturing documentation about its earlier colors, which did not involve 

barium. The company was found to be out of compliance because the level of barium in 

the extracts of the new paint color was analyzed and found to exceed the toxicity 

characteristic threshold for barium. This illustrates a potential concern that the 

analytical information underlying a knowledge determination may not be sufficiently 

comparable or applicable to the actual generation processes being analyzed.

 Some of RCRA’s requirements mandate the use of specific test methods. For example, if 

a generator tests his waste for the toxicity characteristic (TC) instead of using 

acceptable knowledge, he must use the Toxicity Characteristic Leaching Procedure 

(TCLP), as required by §261.24. This requirement to use the TCLP has implications for 

persons using acceptable knowledge to make a TC determination. If a generator uses 

knowledge under §261.24, it would be unacceptable for him to conclude that his waste 

does not exhibit the TC based solely on the results of a leaching procedure that is not

the TCLP (e.g., a proprietary leaching procedure that EPA is unaware of). This 

illustrates a potential concern that the analytical information underlying a knowledge 

determination may not satisfactorily address the applicable test requirement. Where 

published studies are used as part of acceptable knowledge, it is important to ensure that 

the information is based on valid and relevant/applicable analytical techniques. This 

includes testing for waste characteristics as well as hazardous constituent 

concentrations. The ability of analytical equipment to detect low concentrations of 

contaminants has improved over the years and hazardous constituents that once were 

determined to be “non-detectable” may, in fact, be detectable using sophisticated 

equipment available today.

Although EPA recognizes that sampling and analysis are not as economical or convenient as 

using acceptable knowledge, they do usually provide advantages. Because accurate waste 

identification is such an important factor for demonstrating compliance with RCRA, 

mis-identification can present a safety hazard and may subject your facility to 

enforcement actions for violations of permit conditions, LDR requirements, annual 

reporting, and other RCRA requirements. In addition, accurate waste testing may be 

critical for meeting some of the requirements of other regulatory programs such as effluent 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-23

discharges under the Clean Water Act and transportation requirements regulated by the 

Department of Transportation.

It is recommended that you keep abreast of regulatory developments in the RCRA program

(e.g., by reviewing the Web sites listed in Section 1.0 of this manual) to identify new 

requirements or test methods that may affect the classification of your waste and to reevaluate them as needed using current analytical methods and/or acceptable knowledge, 

particularly for rules affecting waste identification/classification. 

Tips on Using a Safety Data Sheet (formerly Material Safety Data Sheet) 

to Support Hazardous Waste Determinations

 Some wastes have their own corresponding safety data sheets (SDSs). More often, SDSs are used to support 

hazardous waste classifications by identifying ingredients used in the process generating the waste. In this 

instance, SDSs might not represent waste characteristics but are useful in identifying possible hazardous 

constituents and their properties.

 The two essential steps when using an SDS:

 Confirm that you have selected the correct SDS for your waste or process ingredients (this is a common 

mistake; check chemical synonyms and chemical abstract service (CAS) numbers carefully); and

 Check the date to confirm it is recent (e.g., more than five years old may be obsolete due to regulatory 

changes, improvements in analytical methods, etc.).

 Scan the SDS and look for mention of RCRA. The SDS may indicate if the material is a RCRA hazardous waste 

when discarded. Note, however, that an SDS statement would not by itself support a RCRA determination; 

information corroborating this conclusion would be needed to make a well-supported determination.

 Review the SDS for any hazard classifications using non-RCRA criteria that may be relevant (e.g., DOT 

Hazmat regulations, NFPA ratings, etc).

 If it does not mention RCRA, find the CAS number. Check to see if the CAS number is identified in the lists in 

Subpart D of Part 261. If so, it may be a listed waste when discarded (assuming it is a solid waste and no 

other exemptions/exclusions apply).

 If it is not listed, it may still exhibit a RCRA characteristic. Refer to relevant information on chemical and 

physical properties for each characteristic, e.g.:

 For ignitability, refer to flashpoint, fire point, etc. Also, look at the NFPA fire rating (a rating of 0 

indicates not ignitable, whereas a rating of 1 to 4 may be indicative of ignitability).

 For corrosivity, refer to pH.

 For reactivity, refer to the section on reactivity.

 For toxicity, refer to the constituents in the material, if shown. If none of them appear under 261.24 

Table 1 and the purity is high, then this may indicate it does not exhibit toxicity characteristic.

However, this requires thorough knowledge of the chemicals in a mixture.

 SDSs can be useful in identifying constituents in the waste; however, they should not be relied on to 

exclude possible contaminants. SDSs typically list constituents present at least 1% by mass (10,000 mg/kg).

Concentrations much lower than this may impact hazardous waste management and waste analysis 

requirements.

 Should not use a SDS in the following circumstances:

 If the material has been treated, mixed with, or derived from other chemicals (e.g., acids with bases) or 

otherwise chemically altered (except as indicators of possible constituents).

 If the SDS is more than five years old, unless you confirm that relevant data are still accurate.

 As a substitute for laboratory analysis of constituent concentrations when required.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART ONE: RCRA Waste Analysis – An Overview 1-24

1.2.3 Waste Analysis for Generators

Generators may use either sampling and analysis or acceptable knowledge in satisfying 

their waste classification obligations. While hazardous waste determinations might not 

include collecting the more detailed information that a TSDF may need, generators should 

consider the same concepts and limitations regarding relevance, accuracy, precision, 

representativeness, protectiveness, and data quality discussed above for TSDFs when 

choosing an approach to waste analysis.

Tips for Generators Unfamiliar with RCRA’s Hazardous Waste Determination Requirements

 Learn your legal responsibilities under RCRA and your state’s hazardous waste program by reviewing your 

state’s generator standards and guidance. Refer to relevant Federal Register notices and supporting 

documents to get a more detailed explanation of the regulations, the intent of the requirements, and how 

they are expected to be implemented by the regulated community. The basic obligations of generators 

regarding waste classification can be found at §262.11.

 Speak with the personnel at your site and compile paperwork to develop a collective knowledge of your 

generating processes, potential wastes, regulatory requirements, and opportunities for waste minimization.

 Contact your state agency, or the agency in the TSDF’s state, if you have questions (e.g., should the analyses 

be performed by certified laboratory?). If the state agency is not authorized to administer the RCRA 

program, you should contact the U.S. EPA Regional Office in which that state resides. 

 Speak with a qualified consultant, your transporter or the designated TSDF for assistance in identifying, 

collecting and characterizing your waste.

 Join a trade association and/or subscribe to a trade newsletter to stay abreast of regulatory changes. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-1

2.

PART TWO: 

Documenting and Conducting Waste Analysis

2.0 Developing a WAP and Conducting Waste Analysis

In Part One, you learned about your waste analysis and waste analysis plan (WAP) 

responsibilities and reviewed the methods by which you can meet these responsibilities (i.e., 

sampling and laboratory testing, and acceptable knowledge). In Part Two, you will learn:

14

 What may be included in a WAP and how the WAP may be organized (Sections 2.1 and 

2.2).

 How to use a systematic planning process to define 

the objectives of your sampling and analysis 

program (Section 2.3).

 How to conduct waste testing, including selecting 

sampling parameters, strategies, and test methods to 

meet your objectives, as well as identifying special 

waste management conditions that may apply to 

your facility (Sections 2.4-2.9).

 How to document your waste discrepancy and 

rejection policies (Sections 2.10 and 2.11).

 What recordkeeping requirements you may need to 

fulfill (Section 2.12).

 How to address corrective and preventative action 

measures (Section 2.13).

2.1 Content and Organization of the WAP

To facilitate conducting waste testing and developing a 

WAP, Table 2-1 provides a list of key questions 

arranged by facility type, that when analyzed 

sequentially, provide an overview for your facility to 

consider when planning, documenting, and conducting

waste testing. Answers to the questions posed in Table 

2-1 will be based on facility-specific considerations. 

 

14 This manual presents federal hazardous waste requirements. Because state hazardous waste programs may be 

more stringent and/or broader in scope than the federal program, you need to consult your state’s regulations to 

learn the requirements that apply to you.

Key Initial Considerations 

for the Facility

 It is important for WAPs to be 

tailored to the circumstances and 

business practices of the facility; a 

WAP that is appropriate for a 

commercial treatment/ 

storage/disposal facility may not be 

appropriate for non-commercial 

treatment/disposal facilities, or 

even captive storage facilities.

 Do not repeat information that 

exists elsewhere in the permit 

(e.g., basic facility description, 

process descriptions); however, 

brief summaries may sometimes 

be appropriate, with a reference to 

where a fuller discussion can be 

found in the permit.

 Prepare procedures for subjecting 

wastes to an appropriate level of 

testing. For example, an incoming 

hazardous waste shipment may be 

incorrectly evaluated or reported 

by the shipper as non-hazardous. 

The receiving TSDF should have 

measures in the WAP to detect and 

properly evaluate such shipments.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-2

Relevant facility-specific factors include:

 The type of facility (e.g., generator, 

storer or disposer) and its operating 

activities (e.g., whether it accepts waste 

from off-site sources for management 

on-site).

 The characteristics and quantities of 

wastes generated.

 The types of units that are used to 

manage wastes on-site.

The text box on the next page, “Content 

and Organization of WAP,” recommends a 

format for facility WAPs that the Agency 

has found to be effective. While there is 

no required format for a WAP, addressing 

the ten elements in the text box will assist 

you in WAP development. Of course, there 

are other acceptable formats and facilities 

are encouraged to work with the permitting agency to determine the most desirable 

format based on their specific facility. In addition, note that a number of the elements in 

the text box are not specified for inclusion in the WAP by regulation; rather, EPA is 

recommending them based on its experience. For purposes of clarity, the text box 

identifies elements that are recommended and those that are mandatory. Only those that 

are mandatory are required to be included in the WAP.

Additionally, it may be helpful to include documents such as sampling manuals and standard 

operating procedures as appendices to the WAP to increase the usefulness of the document. 

Refer to Appendix F of this manual for key 

considerations and tips for both preparing 

and reviewing WAPs and for inspecting 

facilities for compliance with their WAPs.

When the permitting agency reviews your 

proposed WAP and other parts of the permit 

application, it will likely contact you with 

questions, comments, and suggestions. You 

may want to request a meeting and/or phone 

call(s) with the agency prior to and/or after 

submitting the application to learn more 

about their expectations and requirements. 

You may also want to consider having the 

permitting agency visit your facility to learn 

more about your operations.

Generator WAP Requirements

Generators are not required to have or follow a 

WAP, except if managing and treating prohibited 

waste or contaminated soil in tanks, containers, or 

containment buildings regulated under §262.34 to 

meet applicable LDR treatment standards found at 

§268.40 (§268.7(a)(5)). The plan must:

 Be written, kept on site in the generator’s files, 

and made available to inspectors.

 Describe the procedures the generator will carry 

out to comply with the treatment standards.

 Be based on a detailed chemical and physical 

analysis of a representative sample of the 

prohibited waste(s) being treated.

 Contain all information necessary to treat the 

waste(s) in accordance with the requirements of 

Part 268, including the selected testing 

frequency.

Generators subject to §268.7(a)(5) should refer to 

Table 2-1 for guidance on developing their WAPs in 

accordance with applicable requirements.

Key Considerations for the 

Permitting Agency and Inspectors

 Become familiar with the facility; schedule a visit.

 Use clear, enforceable language when preparing 

permit conditions and require the same from the 

facility in its permit application (e.g., use “must” 

and “shall” as opposed to “may” or “should”).

 Consider including a permit condition that requires 

notification of any changes to the WAP or anything 

outside of the flexibility of the test method. 

 Maintain a generic permit template that includes 

all federal/state conditions. Keep it up to date.

 During inspections or compliance evaluations, 

consider inviting someone on-staff (Agency or 

contractor personnel) with a chemistry or 

laboratory background to evaluate WAP 

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

PART TWO: Documenting and Conducting Waste Analysis 2-3

Content & Organization of the WAP

1. Purpose 

A. Identify requirements/permit conditions for preparing and implementing a WAP at your facility.

B. Provide a brief outline or overview of the WAP.

2. Facility Description (see Section 2.2)

A. Identify each hazardous waste type at your facility to include on-site managed wastes, on-site 

generated wastes, acceptable wastes (i.e., waste codes your facility accepts), and restricted wastes 

(i.e., wastes your facility cannot accept).

B. Identify each process generating these wastes.

C. Provide the rationale for identifying each waste as hazardous.

D. Provide appropriate waste classifications (e.g., wastewater or non-wastewater).

3. Waste Pre-Acceptance and Acceptance Processes (see Sections 1.2.1, 2.7, 2.8, 2.9.1) 

A. Describe the rationale, information needs, and criteria for pre-acceptance of off-site wastestreams.

B. Describe the processes, policies, and procedures for evaluating incoming waste shipments for 

acceptance and appropriate on-site management. 

4. Rejection Policy (see Section 2.11) 

Describe the policies and procedures that your facility will use for the rejection of waste received by your 

facility.

5. Discrepancy Policy (see Section 2.10) 

Describe the policies and procedures that your facility will use when there is a discrepancy between the 

waste designated on the manifest or profile and the waste received at your facility, including how the 

discrepancies will be resolved.

6. Sampling Strategies and Frequency (see Sections 2.5, 2.8) 

Describe how your facility selects the appropriate sampling procedure for effective waste characterization and 

describe the process for determining both initial sampling frequency and subsequent waste re-evaluation.

7. Analytical Parameters and Test Methods (see Sections 2.4, 2.6) 

Describe how your facility selects the appropriate parameters and test methods. 

8. Quality Assurance/Quality Control and Data Reporting (see Sections 2.5.5, 2.6.1) 

A. Describe your facility’s quality assurance program and quality control procedure that ensure 

laboratory data are scientifically valid, defensible, and of known precision and accuracy (except for 

test strips and visual observations).

B. Describe the data records your facility maintains and how long, where, and in what format each 

record type will be maintained.

9. Recordkeeping (see Section 2.12) 

Describe the records your facility maintains and how long, where, and in what format each record type will 

be maintained.

10. Corrective and Preventative Action (see Section 2.13) 

Describe your facility’s QA/QC corrective and preventative action program for your waste analyses, 

including the process for identifying deficiencies early and procedures for rectifying any deficiencies.

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

PART TWO: Documenting and Conducting Waste Analysis 2-4

TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs*

Generators Treatment Facilities

Generator Only** Generators That Treat Waste in 

Certain Types of Units***

On-Site Only Off-Site Only

1. What is the description of the facility 

where wastes are generated and/or 

managed? (2.2)

2. What processes result in hazardous 

waste generation? (2.2)

3. What is the description of the 

hazardous wastes that are generated? 

What are the waste classifications, EPA 

waste codes, and treatability groups, 

of the hazardous wastes generated? 

(2.2)

4. What waste parameters will be 

identified for testing and/or 

monitoring and what is the rationale 

for selecting these parameters? (2.4)

5. What sampling procedures (collection 

strategies, equipment, sample 

preservation methods and QA/QC 

procedures) will be used? (2.5)

6. How will a laboratory be selected? 

(2.6.1)

7. What testing and analytical methods 

will be used? (2.6.2, 2.7)

8. What frequency for re- evaluating the 

waste will be established? (2.7, 2.8)

9. Will information be prepared on 

waste’s compliance with LDRs, which 

can be shared with treaters and 

disposers? (1.1.3)

10. Are additional provisions for meeting 

LDR regulations required? (1.1.1, 

2.9.4)

Address all Generator Only 

information from items 1- 10 in 

column one. In addition, 

address the Treatment Facilities 

(On-Site Only column) 

information from items 11-19 as 

applicable.

Address all Generator Only information 

from items 1- 10 in column one. And also, 

answer the following:

Before Treatment

11. What are the treatment or process 

design limitations for optimal protect 

tive use of equipment and materials? 

(2.2, 2.4) 

12. What are the other operational 

acceptance limits applicable to permit 

and technological considerations (2.2, 

2.4) 

13. What are the applicable treatment 

standards with respect to the LDR 

regulations? (1.1.1, 2.9.4)

After Treatment

14. Did the treatment achieve LDR 

standards or is additional sampling and 

analysis necessary to make this 

determination? (1.1.1, 2.2, 2.4, 2.5, 2.6, 

2.8, 2.9)

15. What new wastes, waste codes, and 

treatability groups were generated? 

(1.1.1, 2.2)

16. Are there any additional applicable 

treatment standards with respect to 

LDR regulations? (1.1.1, 2.2, 2.9)

17. What additional parameters of the 

treated materials (residues) will need to 

be monitored and why? (1.1.1, 2.4)

18. How will the treated wastes be 

sampled? (2.5)

19. What testing/analytical methods will be 

used to analyze the waste (2.6.2)

Address all Generator Only information from items 1-

10 in column one. And also, answer the following:

Before Acceptance

11. How will identification of wastes from off-site be 

verified? (2.4, 2.8, 2.9)

12. Will corroborative testing be conducted using fullscale analysis, fingerprinting, or other process such 

as acceptable knowledge? (2.4, 2.6, 2.8, 2.9)

13. How will wastes be screened for contaminants 

that are incompatible with the treatment process? 

(2.4, 2.6)

Before Treatment

14. What are the treatment process design limitations

for optimum protective use of equipment and 

materials? (2.2, 2.4)

15. What are the other operational acceptance limits 

applicable to permit and technological 

considerations? (2.2, 2.4)

16. What are the applicable treatment standards for 

LDR regulations? (1.1.1, 2.9)

After Treatment

17. Did the treatment achieve the LDR standards or is 

additional sampling and analysis necessary to 

make this determination? (1.1.1, 2.2, 2.4, 2.5, 2.8, 

2.9)

18. What new waste/waste codes & treatability 

groups were generated? (1.1.1, 2.2)

19. Are there additional applicable treatment 

standards with respect to LDR regulations (1.1.1, 

2.2, 2.9)

20. What additional parameters of the treated 

materials (residues) will need to be monitored? 

(1.1.1, 2.4)

21. How will the treated waste be sampled? (2.5)

22. What testing/analytical methods will be used to 

analyze the waste? (2.6.2)
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-5

TABLE 2-1: Reference Guide to Key Issues for Consideration When Developing WAPs (Continued)

Storage Facilities Disposal Facilities

On-Site Only Off-Site Only On-Site Only Off-Site Only

Address all Generator Only information 

from items 1- 10. And also, answer the 

following:

11. Will managing wastes (e.g. mixed bulk 

chemicals) change the chemical 

properties, such that issues 12-15 

below must be addressed? (2.2)

12. How will the initial waste 

characterization change? (2.4, 2.7) 

13. What additional sampling and analysis 

are required at the storage facility? 

(1.1.2, 2.4, 2.5)

14. Will a new waste identification be 

required and how will it be verified? 

(2.7, 2.8)

15. What are the applicable treatment 

standards with respect to LDR 

regulations as a result of any blending 

or mixing that may have occurred? 

(1.1.1, 2.2, 2.8, 2.9) 

Address all Generator Only information 

from items 1- 10. And also, answer the 

following:

Before Acceptance

11. How will identification of wastes from 

off-site be verified? (2.4, 2.8, 2.9)

12. Will corroborative testing be conducted 

using full-scale analysis, fingerprinting 

or other process such as acceptable 

knowledge? (2.4, 2.6, 2.8, 2.9)

13. How will wastes be screened for 

contaminants that are incompatible 

with the storage process? (2.4, 2.6)

After Acceptance

14. Will managing wastes (e.g., mixed bulk 

chemicals) change the chemical 

properties, such that issues 15-17 

below must be addressed? (2.2)

15. How will the initial waste 

characterization change? (2.4, 2.7)

16. What additional sampling and analysis 

is required at the storage facility? 

(1.1.2, 2.4, 2.5)

17. Will new waste identification be 

required and how will it be verified? 

(2.7, 2.8)

Address all Generator Only information 

from items 1- 10. And also, answer the 

following:

11. Have all wastes designated for land 

disposal met applicable LDR treatment 

standards? ( 2.2, 2.9)

12. Is it necessary to conduct additional 

(corroborative) testing? (2.8 , 2.9) 

13. Have applicable tests been conducted 

to ensure no free liquids will be placed 

into landfills? (2.4)

Address all Generator Only information 

from items 1- 10. And also, answer the 

following:

Before Acceptance

11. How will the identification of wastes 

from off-site be verified? (2.4, 2.8, 2.9)

12. How will wastes be screened for 

contaminants that are incompatible 

with the disposal process? (2.4, 2.6)

After Acceptance

13. What type corroborative testing will be 

conducted, such as full-scale testing 

and analysis, fingerprinting, or other 

process such as acceptable 

knowledge? (2.4, 2.6, 2.8, 2.9)

14. Have all wastes received on site for 

disposal met applicable LDR treatment 

standards? (1.1.1, 2.2, 2.9)

15. Are additional procedural 

requirements applicable for wastes 

from off-site? (2.9)

16. Have applicable tests been conducted 

to ensure no free liquids will be placed 

into landfills? (2.4)

*This table is intended for illustrative purposes only and should not be used as the sole basis for compliance. Numbers in parentheses indicate the pertinent section numbers of this manual for 

further reference.

** A generator is not required to prepare a WAP unless he is managing and treating waste or contaminated soil in tanks, containers, or containment buildings regulated under 40 CFR 262.34 to meet 

applicable LDR treatment standards. The information in this column is for generators who do not treat but who opt to prepare a WAP to more effectively evaluate their wastestreams under RCRA’s 

analytical requirements.

***Treatment in tanks, containers, or containment buildings. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-6

2.2 Facility Description

The facility description is an important element of an 

effective waste management program. The facility 

description should provide sufficient, yet succinct, 

information so that implementing federal and state 

regulators and WAP users can clearly understand the:

 Processes and activities that generate or are used 

to manage the wastes.

 Hazardous wastes generated or managed.

 Hazardous waste management units.

If your facility has an existing RCRA permit or is in the process of developing a permit 

application, the majority of facility description information should be available from other 

sections of the permit or permit application. However, it is also useful to include a 

summary of this information in the WAP. It may be helpful for the WAP to reference 

where in the permit (or permit application) this information may be obtained.

2.2.1 Description of Facility Processes and Activities

As a hands-on tool for ensuring compliance with applicable regulatory requirements and/or 

permit conditions, the WAP may need to provide a description of all on-site facility processes 

and activities that are used to generate or manage hazardous wastes (or reference applicable 

sections of the permit or permit application) that require sampling and waste testing. This 

information could include facility diagrams, narrative process descriptions, and other data 

relevant to the wastestreams subject to waste testing. Since many TSDFs, especially facilities 

that received waste from off-site sources, use the WAP as an operating manual, it is advisable 

to incorporate process descriptions directly into the document.

In addition to describing on-site processes and activities if you receive waste from off-site, 

you should also consider including in the WAP how process description(s) for each 

generator’s wastestreams will be obtained, updated, and kept on file as part of the off-site 

TSDF operating record (which is reviewed by EPA/state inspectors). If you own or operate a 

TSDF, this data should enhance your knowledge of off-site generation processes and, 

therefore, should improve your ability to determine the accuracy of generator waste 

classification.

40 CFR 264/265.13 do not require WAPs

to provide a facility description. 

However, this manual recommends that 

a brief facility description (e.g., wastes 

and waste generating processes) be 

addressed in the WAP in order to aid in 

the efficient review of the WAP.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-7

2.2.2 Identification/Classification of Hazardous Wastes Generated or 

Managed at Your Treatment, Storage and Disposal Facility

In addition to describing the processes and activities at your facility, you should also 

consider including in the WAP:

 Rationale for identifying each waste as hazardous.

 Procedures and protocols for evaluating

wastes received from off-site sources.

 Each hazardous waste type managed at your 

facility including:

– On-site generated wastes.

– Off-site generated wastes.

 Waste codes your facility accepts.

 Wastes your facility does not accept.

 Each process handling these wastes and 

generating treatment residues.

 Appropriate EPA waste classifications (e.g., LDR classification as wastewater or nonwastewater).

If you generate or manage a RCRA listed waste, you could include tables to present 

relevant information. For example, Table 2-2 provides one possible format that you 

may use to present relevant information about off-site (received) waste.

TABLE 2-2: Description of Listed Wastes

Facility Wastestream 

Name

Process 

Generating this 

Waste

Rationale for 

Hazardous Waste 

Designation

EPA 

Waste 

Code

LDR

WW/NWW

FACILITY A

SemiConductor

Manufacture

Spent Degreasing 

Solvents 

(Trichloroethene)

Machinery 

Degreasing 

Operations in 

Bldg. 12

Contains 25% 

trichloroethene, 

cutting oils, and other 

non-hazardous 

degreasing solvents

F001 NWW

FACILITY B

Wood 

Preserving 

Facility

Bottom Sediment 

Sludge

Treatment of 

Wastewater from 

Wood Preserving 

Operations

Process used 

pentachlorophenol K001 NWW

NWW = Non-Wastewater WW = Wastewater

Pre-Acceptance of Off-site Wastes

If the facility will receive off-site waste 

shipments, it is important for the WAP to

include processes and procedures for prequalifying these wastes before the first 

shipment. This includes describing, for 

example, the types of information these offsite sources should provide and the facility’s 

decision-making criteria.

Refer to Sections 1.2.1 and 2.9.1 of this manual 

for additional information on pre-acceptance

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

PART TWO: Documenting and Conducting Waste Analysis 2-8

In addition to identifying all listed wastes managed (i.e., all wastes generated on-site or 

received from off-site), you may need to conduct testing and/or analysis to determine 

whether you also manage any RCRA characteristic wastes (e.g., for purposes of complying 

with LDR requirements). Sampling and analysis methods that may be appropriate to 

identify characteristics are provided in Sections 2.5 and 2.6 of this manual. If you identify 

wastes as characteristic, you may choose to present relevant information as illustrated in 

Table 2-3, Description of Characteristic Waste.

TABLE 2-3: Description of Characteristic Waste

Facility Characteristic 

Exhibited

Process 

Generating 

this Waste

Rationale for 

Hazardous Waste 

Designation

EPA 

Waste 

Code(s)

LDR

UHC(s) WW/NWW

FACILITY A

Pharmaceutical 

Manufacturer

Toxicity

Analgesic 

cream

(see Process 

A-106)

Benzene > 0.5 ppm D018 None WW

FACILITY B

Hazardous 

Waste 

Treatment 

Facility

Toxicity Fuel 

Combustion

Cadmium > 1.0 ppm 

in Waste Residues D006 None NWW

NWW = Non-Wastewater

WW = Wastewater

ppm = parts per million UHC = Underlying Hazardous Constituent

For TSDFs that handle many wastes, the information in Tables 2-2 and 2-3 could be 

simplified into broader wastestream categories (e.g., spent non-halogenated solvents) 

based on how each wastestream will be handled for treatment and disposal rather than by 

the generator or by highly specific wastestream names.

As a supplement to the above information, this portion of the WAP may also provide a 

listing of any wastes or waste properties that the facility is not permitted to accept (i.e., 

unauthorized wastes). Collectively, the identification of appropriate and unauthorized 

waste types should enhance the facility’s ability to develop effective sampling and 

analytical procedures for the overall waste analysis program.

2.2.3 Description of Hazardous Waste Management Units

The final component of the facility description may need to include a description of each 

hazardous waste management unit at the facility that provides more detailed information 

regarding the specific operating conditions and process constraints for each unit.

A hazardous waste management unit is defined in the RCRA regulations as a contiguous 

area of land on or in which hazardous waste is placed, or the largest area in which there is 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-9

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

Examples include:

 Container storage areas. Note: A container alone does not constitute a unit; the unit 

includes containers and the land or pad upon which they are placed [§260.10].

 Tanks and associated piping and underlying containment systems.

 Surface impoundments.

 Landfills.

 Waste piles.

 Containment buildings.

 Land treatment units.

 Incinerators.

 Boilers and industrial furnaces.

 Miscellaneous units. 

The description of the hazardous waste management units at your facility may be provided 

in narrative and schematic form or a reference to the section of the permit or permit 

application that contains this information may be included. The narrative description could 

include the following:

 A physical description of each management unit with dimensions, construction 

materials, and components.

 A description of each waste type managed in each unit.

 A description of the methods for how each hazardous waste, any treatment residues, or 

any re-treated wastes will be handled or managed in the unit, for example:

– If hazardous and non-hazardous wastes will be mixed or blended, the methods for 

how these activities will be conducted should be described. In certain 

circumstances, the hazardous waste may be subject to the “mixture” or “derivedfrom” rules [§261.3(a)(2)(iv) and §261.3(c)(2)(i)].

– If a surface impoundment will be used for neutralization of corrosive wastes, the 

mechanism for achieving neutralization.

 Process/design considerations necessary to ensure that waste management units are 

meeting applicable permit-established performance standards and complying with the 

regulatory provisions of RCRA (e.g., Part 268). This information may need to define 

specific physical and chemical operating constraints to ensure process integrity. For 

example, flow injection incineration facilities typically require wastes to have certain 

minimum and maximum levels of viscosity, heat content, and particulates for effective 

treatment.

 Prohibitions that apply to the facility (e.g., PCBs in the incinerator feed, storage of 

corrosive waste, unpermitted RCRA hazardous waste codes such as listed dioxin waste).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-10

2.3 Systematic Planning

The process of waste analysis is one that involves the 

collection and evaluation of data to accurately 

characterize the waste. To this end, it may be helpful to 

define clearly the objectives of the program. One way to 

do this is to consider what questions you need to answer 

about a waste to characterize it adequately. Adequate 

characterization not only complies with regulatory 

hazardous waste management requirements, but 

also satisfies company goals such as cost effective waste management, reducing legal 

liability, and improving workplace safety.

The waste analytical process involves a number of steps including:

 Selecting the right parameters for testing;

 Collecting representative samples;

 Choosing a qualified laboratory;

 Selecting appropriate test methods;

 Quantifying data uncertainty; and

 Making decisions.

At each step in the process, the waste handler needs to make a number of choices (e.g., 

sampling method, number of samples, test methods, etc.). Small errors made during this 

process can result in inaccurate or inappropriate data that may result in making a wrong 

decision or violating the rules, including the conditions of the permit. Systematic planning 

processes methodically identify the considerations and approach to data collection prior to 

waste sampling. Systematic planning that considers the data needs best ensure (1) that your 

data will support your decisions; and (2) compliance with permit and regulatory 

requirements. 

Many systematic planning process tools are available to guide planning efforts although the 

Data Quality Objectives (DQO) process is the most commonly used systematic planning 

application in the general environmental community. The DQO process may be 

implemented when data are being used to select between two opposing conditions, such as 

determining compliance with a standard.

The DQO process includes a seven step planning process as shown in Figure 2-1 and offers 

a structured approach to “beginning with the end in mind.” It is a framework for asking the 

right questions and using the answers to develop and implement a plan for data collection. 

The DQO process will enable you to get useful information in a cost-effective manner. The 

process is iterative and adaptive, as your knowledge about the decision needs to change 

with time. If you cannot definitively answer a question in the process, sometimes the best 

option is to make your best estimate and loop back to improve your plan once you have 

40 CFR 264/265.13 do not specify the 

WAP development process described 

in Section 2.3. However, using the 

process described in this section or an 

alternate process of similar rigor is 

recommended to ensure that quality 

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

PART TWO: Documenting and Conducting Waste Analysis 2-11

more information. The following is a brief discussion of 

each of the seven steps in the process. Further 

discussion of implementing the DQO process in your 

waste analytical program is included in Sections 2.4 

through 2.8 of this manual.

FIGURE 2-1: The Seven Ste ps 

of the D QO Process

DQO Step 1 - State the Problem: In Step 1 of the DQO 

process, you define the problem or question you want to 

answer. In waste characterization, your problem may be 

defined by the regulations. For example, you may need to 

determine if a waste is hazardous or if you have met a 

treatment standard. Non-regulatory factors such as your 

company’s standards may also add additional factors 

that affect your decision. During Step 1, you also identify 

who the key individual(s) will be in making decisions 

and determine how you will gather information. For 

larger projects, you may want to organize a planning 

team with a central leader and decision maker that is 

composed of personnel representing all phases of work 

(i.e., the waste generator, a chemist, the sampler, etc.). For smaller projects, you can

streamline the planning effort to reduce costs and meet deadlines. One way you can do this 

is by assigning a single individual to lead the project. The project leader, however, should 

have the authority to make decisions and have access to the individuals with the necessary 

information to make the decision. 

DQO Step 2 – Identify the Decision: In Step 2, you define the specific decisions that you 

want to make and identify the actions you may take based on the results. For example, you 

may not only need to make a decision to determine if a solid waste is hazardous but also 

how to proceed in handling the waste once it is deemed hazardous or non-hazardous. Your 

goal in Step 2 is to formulate a decision statement that includes both of these components. 

Depending on the question you are attempting to resolve, you may need to use a tiered 

approach of several smaller decisions (for example, (1) determine if the material is not 

consistent with the profile, then (2) conduct necessary testing to determine if reactive,

flammable, corrosive or toxic). If several separate decisions are involved, you might list the 

decisions in the order in which they will be resolved. Below is a simple example of possible 

outputs for Step 1 and 2 for a new waste that your facility has just received that may be 

subject to regulation due to lead.

DQO Step 1 – State the Problem

Do you need to treat the new waste to land disposal restriction (LDR) limits before disposal due to elevated

levels of lead?

DQO Step 2 – Identify the Decision

Does the new waste contain lead at a concentration that exceeds the regulatory standard allowing it to be 

disposed at a landfill?

FIGURE 2-1: The Seven Steps 

of the DQO Process
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PART TWO: Documenting and Conducting Waste Analysis 2-12

DQO Step 3 – Identify Inputs to the Decision: In Step 3, you identify the type and source 

of the information to answer the question from Step 2. For RCRA-related programs, you 

typically need to collect samples, measure parameters, and integrate generator acceptable 

knowledge. This should include identifying possible sample and analytical methods; but 

keep in mind that these methods may need to be revised as more information is gathered. 

The potential source(s) of this information (e.g., laboratories) are also identified. 

Discussions specific to selecting waste parameters, sampling methods, testing methods, 

and identifying laboratories qualified to perform those methods are discussed in detail in 

Sections 2.4 through 2.6 of this manual. The output of Step 3 for the lead waste example is 

outlined below. 

DQO Step 4 – Define Study Boundaries: In Step 4, you will define both the spatial and 

temporal boundaries of the waste unit and determine any additional constraints on data 

collection. The spatial and temporal boundaries help to determine the waste to which your 

decision criteria apply. 

 Spatial boundaries define the physical area to which the data applies and the locations 

where samples are taken. 

 Temporal boundaries describe the time frame the data represent and when the 

samples are taken.

When waste is limited to a single container, the spatial boundaries are defined by the 

physical boundaries created by the container. In other cases, the spatial boundaries may be 

less clear. For example, it may be an area (e.g., an accumulation area). Even within a single 

container, however, there may be other aspects to consider when defining the spatial 

boundaries like how evenly (homogeneous) or unevenly (heterogeneous) the hazardous 

constituent(s) are distributed. For example, you may need to sample a heterogeneous 

waste much differently than a homogeneous waste to obtain a representative sample. 

The heterogeneous waste may in many cases warrant collection of additional samples. Two 

examples of heterogeneous wastes include liquid wastes with multiple layers and a solid 

waste that contains “hot spots.” For a discussion of sampling strategies for both homo- and 

heterogeneous wastes, see Section 2.5 of this manual.

DQO Step 3 – Identify Inputs to the Decision

Identify the type of information/sources needed to resolve the decision:

 Measurement of the concentration of lead using the SW-846 TCLP Method 1311.

 Use of existing data from the generator to determine waste variability.

Identify the appropriate sample and analytical methods:

 Sampling of the waste for lead per Part 261 Appendix I.

 Use of the SW-846 TCLP Method 1311 to produce the extraction.

 Use of the SW-846 Methods 3010 and 6010 to prepare and analyze the sample.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-13

DQO Step 4 – Define the Study Boundaries

Spatial & Temporal Boundaries:

 The container boundaries of the 10-cubic yard roll off box define the spatial boundaries.

 The waste seems to be homogeneous based on existing data from the generator. 

 This is a new waste. The decision will apply to this load only. 

Additional Constraints:

 The LDR treatment standard (action level) is 0.75 mg/L TCLP for lead in non-wastewater. 

Temporal boundaries help determine the timeframe to which the decision applies. It may 

be defined operationally (e.g., a “batch” of waste) or by a permit or regulation (e.g., waste 

generated per day). In addition to spatial and temporal boundaries, your project decision 

may also be bound by a threshold value, or “action level” that you can use to answer your 

question. Specifically, the action level is a value that causes a decision maker to choose 

between two actions. Your action level may be a regulatory threshold expressed as a 

concentration for a regulated hazardous constituent (e.g., an LDR numeric treatment 

standard) or it may be defined by a property of the waste as defined in RCRA (e.g., 

corrosivity). You may also be bound by practical constraints that can include having limited 

physical access to the waste being sampled or worker health and safety concerns. You 

should identify all boundaries and practical constraints in DQO Step 4. The boundaries and 

constraints for the lead waste example are defined below. 

DQO Step 5 – Develop a Decision Rule: In Step 5, you take the output from the previous 

steps and develop a decision rule. The decision rule is a single statement in which you 

describe how to use the data to make a decision. In the decision statement, you should also 

specify how to compare sample results to the action level. That is, you could compare each 

individual sample result to the action level or use another method like comparing the mean 

of the results to the action level. In the lead waste example scenario, as RCRA typically only 

requires a single exceedance of the LDR treatment standard to make the waste ineligible 

for landfill disposal under Part 268, you may need to compare the action level to each 

sample individually. The decision rule for the lead waste example is outlined below.

DQO Step 6 – Specify Limits on Decision Error: In Step 6, you identify the certainty or 

level of confidence that you need in your data, since you rarely have complete confidence 

that your decisions are correct due to the non-homogeneity of most wastes and slight 

differences in how you handle, sample, and analyze the waste. The appropriate degree of 

certainty for each decision unit is unique and can be determined by considering the 

consequences of making a wrong decision. If you consider a waste hazardous when it is not, 

DQO Step 5 – Develop a Decision Rule

If any individual sample result is greater than the LDR treatment standard (action level) of 0.75 mg/L TCLP for 

lead in the non-wastewater, then the waste does not meet the LDR treatment standard and is not eligible for 

land disposal under Part 268. Otherwise, the waste will be considered suitable for landfill disposal for lead

under Part 268.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-14

DQO Step 6 – Specify Limits on Decision Error

If any individual sample result in the non-wastewater is greater than 0.75 mg/L TCLP for lead or greater than 

the 90% upper confidence limit, then the waste does not meet the LDR treatment standard and is not eligible 

for land disposal under Part 268. Otherwise, the waste will be considered suitable for landfill disposal for lead 

under Part 268.

the consequences would be the increased cost of unnecessarily treating the waste before 

disposal. If, however, you consider a waste non-hazardous when it is in fact hazardous, the 

consequences may include potential future legal or financial liability problems for the 

owner that are much more consequential and costly. 

For these reasons you should evaluate your data to ensure that not only are sample results 

below the action level but that you have an appropriate degree of certainty that any 

subsequent sample collected from the decision unit would also be below the action level. 

One way that you can express the degree of certainty in your data is by establishing a 

confidence level. A confidence level indicates the degree of certainty of your data in terms 

of a percent (i.e., 90% single tailed confidence level as specified in SW-846, Chapter Nine). 

For example, a 90% confidence level means that you are 90% certain (10% uncertain) that 

any additional sample will also be below the action level. To apply a specific confidence 

level to your data, you determine the confidence limits statistically. Confidence limits are 

the upper and lower limits that your data need to fall within to meet a specific confidence 

level. Most action levels will be based on regulatory standards that are not to be exceeded 

(or equaled), so normally the upper confidence limit is used.

In the lead waste example, the action level is based on the LDR regulatory limit for lead in 

non-wastewater, which is 0.75 mg/L TCLP. As the potential negative consequence for 

making a wrong decision is high in this instance (regulatory penalties for noncompliance, 

etc.), a high level of confidence (90% certainty) in the data is appropriate. Applying a 90% 

confidence level will reduce the chances of the facility being noncompliant with the 

regulations. For more detail on how to calculate the upper bound of a confidence limit, 

please see the example in Section 2.7, Quantifying Data Uncertainty.

The output of Step 6 is a more detailed decision statement that expresses the decisions 

with the confidence limit, which is sometimes referred to as the DQO Statement. 

DQO Step 7 – Optimize the Design: Step 7 is the final step in the DQO process. In Step 7, 

you review the outputs from the previous six steps and determine if you have all of the 

appropriate information that you need or if there are still data gaps. For example, you 

may need to revisit the analytical method you chose in Step 3 if you determine it is not 

sensitive enough to meet your action level. After you have eliminated any remaining data 

gaps, you can identify an optimal design for collecting your data in a cost-effective 

manner to meet your DQO Statement. This will likely include finalizing the selection of 

sampling and analytical methods and determining the appropriate number of samples to 

collect. You should also document your decision and take the appropriate actions to 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-15

40 CFR 264/265.13(b)(1) require that WAPs specify 

parameters for which each hazardous waste, or nonhazardous waste if applicable, will be analyzed and 

the rationale for the selection of these parameters.

ensure that all staff involved in sample collection and testing understand and properly 

implement the sample design. 

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

following sources:

 Guidance of Systematic Planning Using the Data Quality Objectives Process, EPA240-B06-001, U.S. Environmental Protection Agency, Washington, D.C., February 2006. 

 RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation and 

Assessment, EPA 530-D-02-002, U.S. Environmental Protection Agency, Washington, 

D.C., August 2002.

– For a more detailed discussion of the DQO Process - See Chapter Four entitled, 

“Planning Your Project Using the DQO Process.”

– For more examples of applying the DQO Process to waste analysis – See Appendix I 

entitled, “Examples of Planning, Implementation, and Assessment for RCRA Waste 

Sampling.” 

2.4 Selecting Waste Analysis Parameters

An accurate representation of a waste’s 

physical and chemical properties is critical 

in determining effective and compliant

waste management options. Accordingly, the 

facility’s WAP must specify waste 

parameters that provide sufficient information to ensure: 

 Compliance with applicable federal regulatory requirements (e.g., LDR regulations, 

including underlying hazardous constituents, newly identified or listed hazardous 

wastes).

 Compliance with applicable state regulatory requirements for those states that are 

authorized to implement the RCRA hazardous waste program.

 Conformance with permit conditions (i.e., ensure that wastes accepted for management 

fall within the scope of the facility permit and that process performance standards can 

be met).

 Effective and appropriate waste management operations (i.e., ensure that no wastes are 

accepted that are incompatible or inappropriate given the type of management 

practices used by the facility).

Attention to the above factors when developing a WAP should orient you toward the major 

considerations for selecting waste analysis parameters. Your facility should keep in mind 

that parameter selection can be an iterative process and that you may want to select 

final parameters with regulators. The following discussion provides more definitive 

guidance to help you determine the specific parameters to be incorporated into your WAP.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-16

2.4.1 Criteria for Parameter Selection 

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

and effective waste management. Due to the diversity of hazardous waste operations and the 

myriad of operating variables, the identification of the most suitable parameters to be 

sampled and analyzed can be complex, especially for large TSDFs. To this point, relevant 

waste analysis parameter selection criteria can be developed and reviewed systematically to 

efficiently identify parameters of interest. Generally, these selection criteria may be 

organized into the following categories:

 Waste identification.

 Identification of incompatible/unauthorized wastes.

 Process and design considerations.

Each major category where selection criteria are to be applied is described below.

Waste Identification

A prerequisite step in proper waste management is the identification of hazardous wastes in 

accordance with regulatory and permit requirements. Generators and TSDFs must evaluate 

(through testing or applying acceptable knowledge) solid wastes to determine if the wastes 

are hazardous in accordance with state regulations and the RCRA characteristics and listings 

set forth in Part 261, Subparts C and D. In addition, pursuant to the LDR regulations, they 

must determine whether hazardous wastes are restricted from land disposal according to 

Part 268. If the generator determines that his waste is subject to the LDR requirements, he 

must comply with the LDR notification and certification requirements at §268.7. 

Accordingly, an effective waste analysis plan 

not only specifies the parameters that may be 

necessary to ensure that wastes accepted by 

the TSDF are accurately identified and fall 

within the scope of the facility permit (where 

applicable), but also may need to include 

provisions to ensure that applicable LDR 

requirements are fulfilled. Waste analysis 

requirements for generators and TSDFs, 

including the LDR provisions for underlying 

hazardous constituents (UHCs), are presented 

in Section 1.1.1 of this manual.

TSDFs are responsible for meeting the LDR 

treatment standards prior to land disposal 

for all regulated hazardous constituents 

and/or UHCs subject to the LDR 

requirements, regardless of the constituents

Characteristic Waste and

Underlying Hazardous Constituents (UHCs)

Characteristic hazardous waste (per §§261.21-.24) 

must comply with the special requirements set 

forth in §268.9. This includes addressing UHCs.

When determining the LDR treatment standard for 

the characteristic waste, you must consult the 

table of standards in §268.40 to determine 

whether you are responsible for meeting “§268.48 

standards” and, if so, you must identify any 

constituents that are reasonably expected to 

qualify as UHCs at the point of generation.

If UHCs are identified, the waste cannot be 

disposed in a landfill until the waste:

 No longer exhibits the characteristic; and

 Meets the concentration-based universal 

treatment standard (s) in §268.48 for each 

regulated constituent (i.e., UHC) in the waste. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-17

identified by the generator.15 TSDFs may consult a variety of reference materials pertaining 

to the types of wastes to be managed when specifying parameters to corroborate waste 

identification under RCRA, including: 

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

hazardous constituents, respectively).

 Applicable state hazardous waste regulations.

 Industry and trade association hazardous waste profile studies.

 EPA Background Documents for RCRA listed and characteristic hazardous wastes.

Another consideration in selecting waste analysis parameters, especially if you are the 

owner/operator of a TSDF that accepts waste from off-site facilities, is determining when 

you may need to conduct a full waste characterization versus fingerprint analyses. A full 

waste characterization may be appropriate when:

 A generator begins a new process or changes an existing process.

 Wastes are received by a facility for the first time.

 A generator has not provided appropriate waste profiles or laboratory information to 

an off-site TSDF.

 A facility may want to verify that generator supplied waste information (routine) is 

accurate.

 An off-site TSDF has reason to suspect that the wastes received were not accurately 

identified by the generator (non-routine).

 EPA changes RCRA waste identification/classification rules.

Fingerprint analysis is conducted generally for parameters (e.g., specific gravity, color, flash 

point, presence of more than one phase, pH, halogen content, cyanide content, percent 

water) that will give information that can be used to help verify that the waste generated, 

or received by an off-site TSDF, matches the expected characteristics for that waste. For 

example, at an off-site TSDF, abbreviated analysis can be used to verify that the waste 

received matches the description on the manifest, and that the waste matches the waste 

type that the facility has agreed to accept. Where the owner/operator of a TSDF already 

knows the detailed chemical and physical properties of a waste, appropriate target or spot 

check parameters can be selected to verify that each waste arriving at the gate of the TSDF 

matches its profile. 

 

15 As previously noted, Part 268 defines land disposal as the placement in or on the land, except in a corrective 

action management unit or staging pile, and includes, but is not limited to, placement in a landfill, surface 

impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, 

underground mine or cave, or placement in a concrete vault, or bunker intended for disposal purposes. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-18

Sampling frequencies and waste re-evaluation frequencies are discussed in detail in 

Sections 2.5.1 and 2.8, respectively.

Identification of Incompatible/Unauthorized Wastes

Regulatory requirements and good management practices dictate that incompatible (e.g., 

acids and bases) or unauthorized wastes be identified prior to waste management

[§§264/265.17]. If combined, incompatible wastes are capable of spontaneous combustion, 

toxic gas generation, or explosions. Compatibility testing may include determining water 

reactivity (e.g., foaming, heat generating, explosiveness), oxidation-reduction potential, 

spot tests for cyanide and sulfide, among others, with the objective to:

 Ensure compatibility of waste with the hazardous waste management unit into which it 

will be placed (e.g., the material that a container is made of).

 Determine compatibility of separate wastestreams prior to commingling.

 Avoid accumulating incompatible wastes in the same storage location.

 Ensure that tanks/containers that were used to store a different wastestream have 

been adequately cleaned.

In addition, accepting wastestreams not authorized for your facility operations may violate 

permit conditions. Examples of unauthorized wastes may include PCBs and listed dioxin 

wastes. The selection of waste parameters therefore must include measures to screen for 

and identify these types of waste prior to acceptance.

Suitable parameters for identifying incompatible and unauthorized wastes will vary 

according to facility-specific operating and permit conditions. To determine if particular 

wastes or wastes and storage units are compatible, the RCRA regulations list some common 

potentially incompatible wastes [Part 264/265, Appendix V]. For compatibility of wastes 

not listed in the regulations, the facility may need to test the waste and the unit for 

compatibility. Parameters and analytical methods for ignitable and corrosive waste are 

contained in chapters seven and eight of SW-846, respectively. The EPA document, A 

Method for Determining the Compatibility of Hazardous Wastes (EPA-600/2-80-076),

contains guidance on qualitatively evaluating the compatibility of various types of wastes. 

Process and Design Considerations

The effectiveness of a facility’s waste handling operations and associated management 

units are subject to process and equipment design limitations. These operating constraints 

determine the range of wastes and waste properties (e.g., hazardous constituent 

concentrations, pH, etc.) that may be protectively managed in a given process while 

maintaining regulatory and permit compliance. Thus, the facility WAP should consider 

including such provisions to ensure that physical and chemical analyses provide the 

information needed to identify any waste properties that may exceed technical/equipment 

design limitations, as well as regulatory and permit limitations (e.g., inorganic feed rates, 

Btu values, chlorine/metal content). Potential risks to facility personnel and structures, 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-19

compliance status, and possible impacts to off-site human health and the environment that 

may result from exceeding facility operational limitations emphasize the need to identify 

relevant parameters affecting treatment, storage, and disposal prior to acceptance for 

management. Similarly, because waste composition may change while being managed at an 

on-site facility, processes and designs should be reviewed for all phases of waste 

management (i.e., pre-process, in-process, and post-process) when selecting waste analysis 

parameters. For example, where multiple treatment processes are used, waste composition 

changes resulting from a pretreatment process may preclude its subsequent management 

by certain other hazardous waste units at the facility.

Technical/equipment design operating constraints may determine the range of physical 

and chemical properties that are acceptable for a given waste management operation. 

Waste analysis parameters may need to be selected to provide both a qualitative and 

quantitative measure of these conditions. Typically, these waste analysis parameters are 

used to determine if (1) the waste composition is atypical of that normally handled by the 

facility; and/or, (2) acceptance or further management (without pretreatment) of the 

waste may compromise the performance goals of the waste management process.

In addition to selecting these waste analysis parameters, you may need to ensure that 

applicable regulatory requirements and permit conditions are met while protecting waste 

management unit performance goals and structural integrity. Major factors to consider 

when selecting parameters for evaluating operational limits are listed below:

 Types of waste to be managed.

 Volumes of waste to be managed.

 How waste was received from off-site, if applicable (e.g., drums, roll-offs, piped).

 Source of waste to be managed (i.e., on-site, off-site generator).

 Method of storage, transfer or treatment, if applicable (e.g., stabilization).

 Types of units in which the wastes will be managed (e.g., container storage areas, 

tanks).

16

 Construction materials of the unit.

 Location of the unit (e.g., proximity to property boundary).

This list is not exhaustive and, therefore, other operational factors applicable to your 

facility may need to be considered.

 

16 For purposes of the LDR program, treatment of hazardous waste occurs in non-land based units before a 

prohibited waste is land disposed. Thus, hazardous wastes are typically treated in units such as incinerators, tanks, 

containers, or containment buildings before they are land disposed. Storage units in or on a landfill are defined in 

Part 268 as land disposal. Placement of waste in containers located in or on a landfill is also considered land 

disposal. Waste piles are considered land disposal units. Treatment in surface impoundments is not allowed, 

except under a treatment surface impoundment exemption (§268.4).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-20

2.4.2 Parameter Selection Process

As stated previously, a systematic evaluation of relevant waste analysis criteria (i.e., those 

associated with waste identification, identification of incompatible/unauthorized wastes, 

and process and design considerations) is useful for efficiently identifying waste 

parameters. To this end, Figure 2-2 Waste Analysis Parameter Selection Process illustrates 

a systematic process which can be used to develop a comprehensive inventory of 

applicable waste parameters. This tool is designed to be applied to each hazardous waste 

management unit individually so that parameter selections for each unit are developed 

through separate iterations of the flow process. In addition, attention may need to be given 

to any pre-, in-, or post-process variables that may require selection of additional or 

different parameters.

2.4.3 Rationale for Parameter Selection

Along with identifying waste analysis parameters, the RCRA regulations require that the 

WAP provide the rationale for the selection of each parameter [40 CFR 264/265.13(b)(1)]. 

The rationale must describe the basis for waste analysis parameters and how each will 

measure the physical and chemical waste properties such that wastes are managed within 

regulatory and permit conditions, as well as process and design limitations. This 

information will assist regulators and WAP users with evaluating the viability of parameter 

selection, the appropriateness of incorporating parameters in the WAP, and may help 

eliminate extraneous waste analysis parameters.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-21

FIGURE 2-2: Waste Analysis Parameter Selection Process
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-22

2.4.4 Special Parameter Selection Requirements

Where applicable, WAPs may also need to include procedures and parameters for 

managing specialized wastes in particular types of hazardous waste management units as 

follows:

 Facilities managing ignitable, reactive, or incompatible wastes.

 Bulk and containerized liquid wastes for landfills.

 TSDF process vents. 

 Equipment leaks.

 Air emissions from tanks, surface impoundments and containers.

 Hazardous waste combustors [40 CFR 63.1209(c), 63.1208(b)(8), 264/265.341, 

266.102(a), and 266.103(a), as applicable].

Sampling, analytical, and procedural methods that will be used to meet these additional 

waste analysis requirements for specific hazardous waste management units must be 

included, where applicable, in your WAP [§§264/265.13(b)(6)]. For reference purposes, 

these special requirements are discussed below.

Ignitable, Reactive, and Incompatible Waste Analysis Requirements

WAPs must include provisions to ensure that waste management units meet the special 

requirements for ignitable, reactive, and incompatible wastes [§§264/265.17]. Standard 

tests to identify ignitable, corrosive, and toxic wastes are contained in Chapter 8 of SW-846. 

You should identify reactive wastes as such if they exhibit one or more of the eight 

properties identified in §261.23. As EPA does not currently have a set of approved methods 

for determining reactivity, generators should use acceptable knowledge. Incompatible

wastes, if brought together, could result in heat generation, toxic gas generation, and/or 

explosions. Finally, waste compatibility determinations can serve to establish compatibility 

between wastes of interest for a given process. To determine if particular wastes or storage 

units are compatible, consult the RCRA regulations for a list of some common potentially 

incompatible wastes [Part 264/265, Appendix V]. For compatibility of wastes not listed in 

the regulations, the facility may need to test the waste and the unit for compatibility. 

For further information on waste compatibility, refer to:

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

Environmental Protection Agency, 1980. 

 Design and Development of a Hazardous Waste Reactivity Testing Protocol, EPA-600/52-

84-057, U.S. Environmental Protection Agency, Municipal Environmental Research 

Laboratory, Cincinnati, Ohio, 1984.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-23

Special Requirements for Bulk and Containerized Liquids in Landfills

Owners/operators of hazardous waste 

landfills must ensure that free liquids are not 

placed into the landfill and that restrictions 

on containerized liquids are met [§§

264/265.314]. Specifically, bulk and/or noncontainerized liquids or wastes containing 

free liquids are not to be placed into a 

landfill. In addition, containers holding free 

liquids should not be placed in a landfill 

unless all free-standing liquids: (1) have been 

removed by decanting, or other methods; (2) have been mixed with a non-biodegradable 

absorbent or have been solidified so that free-standing liquid is no longer observed; or (3) 

have been otherwise eliminated. Limited exceptions to the placement of containers holding 

free liquids in landfills include, very small containers, containers designed to hold free 

liquids for reasons other than storage (e.g., some batteries, capacitors), and lab packs. A 

WAP should identify the procedures to ensure that these requirements are met, and if 

applicable, describe the procedures that will be used to determine whether a 

biodegradable sorbent has been added to the waste in the container.

TSDF Process Vent Analysis Requirements

TSDF owners/operators are required to identify and meet specific technical requirements 

for all process vents associated with distillation, fractionation, thin-film evaporation, 

solvent extraction, and stripping processes that manage wastes with a 10 ppmw (ppm by 

weight) or greater total organics concentration on a time weighted annual average basis 

[§§264/265.1034(d)]. The applicability of these process vent requirements is established 

by measuring total organic concentrations in the waste using SW-846 Method 9060. The 

determination that relevant processes are managing organic waste below the regulated 

threshold must be made as follows: (1) by the effective date that the facility becomes 

subject to the requirements; and, (2) for continuously generated wastes, annually, or 

whenever there is a change in the process or waste being managed. The facility’s WAP 

must address sampling and analysis procedures under §§264/265.1034(d), as applicable.

Equipment Leak Waste Analysis Requirements

TSDF owners/operators may need to determine if equipment contains or contacts organic 

wastes with 10 percent or greater total organic content. This trigger threshold may be 

determined by using the following: (1) methods described in ASTM methods D 2267-88, E 

169-87, E 260-85; (2) Method 9060 of SW-846; or, (3) applying acceptable knowledge of 

the nature of the hazardous wastestream or the process by which it was produced. If the 

organic concentrations meet these regulated levels, emission control and monitoring 

standards apply to each valve, pump, compressor, pressure relief device, open-ended valve 

or line, flange or other connector and associated air emission control device or system. 

Considerations for Landfill WAPs

The WAP may need to include a requirement for 

testing for free liquids in containers or, if free 

liquids are not otherwise expected to be present 

in a container, then a visual inspection. If the 

visual inspection detects free liquids, appropriate 

steps may be required (e.g., performance of free 

liquids test, elimination of free liquids, etc.).
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PART TWO: Documenting and Conducting Waste Analysis 2-24

These requirements are established at §§264/265.1063(d). The facility’s WAP must 

address sampling and analysis procedures under §§264/265.1063(d), as applicable.

Air Emissions from Tanks, Surface Impoundments and Containers

TSDF owners/operators may determine that their tanks, surface impoundments, and 

containers are exempt from the air emission standards, as provided at §§264.1082 and 

265.1083. A tank, surface impoundment, or container is exempt, provided that the waste 

management unit meets specified criteria. This includes, for example, a tank, surface 

impoundment, or container for which all hazardous waste entering the unit has an average 

volatile organic (VO) concentration at the point of waste origination of less than 500 parts 

per million by weight (ppmw). The average VO concentration shall be determined using 

specified procedures. The owner or operator shall review and update, as necessary, this

determination at least once every 12 months following the date of the initial determination 

for the hazardous wastestreams entering the unit.

Sections 264.1083 and 265.1084 establish procedures to determine the average VO 

concentration of a hazardous waste at the point of waste origination, waste determination 

procedures for treated hazardous waste, and procedures to determine the maximum 

organic vapor pressure of a hazardous waste in a tank. They also establish procedures for 

determining no detectable organic emissions for the purpose of complying with the air 

emission standards. The facility’s WAP must address sampling and analysis procedures 

under §§264.1083 or 265.1084, as applicable.

Hazardous Waste Combustors

Certain types of hazardous waste combustors (incinerators, cement kilns, lightweight 

aggregate kilns, boilers, and hydrochloric acid (HCl) production furnaces) are RCRA TSDFs 

that are also subject to the Clean Air Act (CAA) National Emission Standards for Hazardous 

Air Pollutants (NESHAP) program. Prior to the adoption of the CAA Hazardous Waste 

Combustor (or HWC) NESHAP standards, emissions from all RCRA hazardous waste 

combustion units were regulated according to Parts 264 and 265 (for incinerators) and Part 

266 (for Boilers and Industrial Furnaces). Thus, the RCRA emission standards/limitations 

and related operating requirements resided in the RCRA permit or interim status regulations, 

and all waste analysis requirements were located in the waste analysis plan (WAP). Between 

1999 and 2005, EPA established new CAA HWC NESHAP emission standards, testing and 

operating requirements for incinerators, cement kilns, lightweight aggregate kilns, boilers, 

and HCl production furnaces burning hazardous waste. The CAA HWC NESHAP is codified in 

Part 63, Subpart EEE. 

In order to avoid (to the extent practicable) having duplicative coverage of emission 

standards and operating requirements in the RCRA permit and the CAA notification of 

compliance and Title V permit, EPA finalized a regulatory approach allowing a facility to 

modify its RCRA permit to remove most or all emission standards and emission related 

operating requirements that are covered by the CAA HWC NESHAP once the source 

demonstrated compliance with Part 63, Subpart EEE. Under this approach, the CAA HWC 
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PART TWO: Documenting and Conducting Waste Analysis 2-25

NESHAP emission standards and emission related operating requirements reside in the 

CAA notification of compliance and Title V permit, while the other RCRA requirements 

associated with the combustion unit and the facility remain in the RCRA permit. Examples 

of requirements that continue to be part of the RCRA permit for these types of HWCs 

include general facility standards, WAPs, closure plans, contingency plans, financial 

assurance, corrective action, and RCRA omnibus provisions. 

With respect to the RCRA WAP, it should not be confused with the CAA HWC NESHAP 

feedstream analysis plan (FAP). While there are separate waste analysis requirements for 

HWCs under the different statutory programs, the requirements are closely related and 

should be coordinated to the extent practicable. (See the discussion of hazardous waste 

combustors in Appendix D of this manual for a crosswalk table which highlights the 

similarities between the RCRA WAP and CAA FAP and identifies sections of this manual 

that may be of assistance in developing a CAA FAP.) As discussed in greater detail in section 

2.9.2 (Procedures for Combustion Facilities), the RCRA WAP would include, for example, 

general RCRA waste analysis requirements that ensure protective receipt and management 

of wastes17 (inclusive of all non-combustion hazardous waste management activities), as 

well as (if needed) waste analysis requirements necessary to ensure compliance with the 

more stringent (relative to MACT) emission and feedrate limitations determined necessary 

as a result of a site-specific risk assessment. Specifically, the RCRA WAP serves to screen 

the incoming waste to the facility which will be treated, stored, and/or disposed, as well as 

to screen out wastes that are prohibited from going to the combustion unit. The CAA FAP 

focuses on the waste before being fed to the combustor to ensure compliance with the CAA 

HWC NESHAP emission standards and feedstream related operating requirements.18 Thus, 

the FAP can be thought of as a subset of the facility’s RCRA WAP, since the incoming waste 

affects what is ultimately combusted.

As alluded to in the previous paragraph, there are limited circumstances in which a RCRA 

WAP may need to include waste analysis requirements necessary to ensure compliance with 

emission-related limitations for combustion units that are also subject to the CAA HWC 

NESHAP. This may occur when:

 The RCRA permit review determines that the CAA HWC NESHAP standards are not 

sufficient to protect human health and the environment for a specific facility. In that 

case, the RCRA permit may include additional feedrate limitations/controls, based on 

the results of a site-specific risk assessment, and the WAP may include procedures to 

ensure compliance with them.

 The owner/operator elects to comply with one of the “RCRA Options” in §270.235 for 

minimizing emissions during periods of startup, shutdown, and malfunction.

 

17 See 40 CFR 264.177, 264.198, and 264.199.

18 Also, the CAA HWC NESHAP requires feedstream analyses that are specific to the comprehensive and 

confirmatory performance tests to ensure these tests accurately quantify the levels and amounts of contaminants 

that are fed into the combustion unit during these tests. See 40 CFR 63.1207(f)(iv).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-26

 Boilers or HCl production furnaces that are area sources under the CAA and elect to 

comply with certain standards for particulate matter, metals other than mercury, 

hydrogen chloride and chlorine under RCRA Part 266, Subpart H instead of the CAA 

HWC NESHAP standards (see §63.1218(e)).

It is important to note that there are other types of RCRA thermal treatment units that are 

not subject to the CAA HWC NESHAP under Part 63, Subpart EEE. For example, carbon 

regeneration units, open burn/open detonation units, and sulfuric acid production units, 

are not regulated pursuant to the CAA HWC NESHAP requirements, but are rather 

regulated pursuant to the applicable RCRA standards for Miscellaneous Units (see Part 264, 

Subpart X) 19 or BIFs (see §§266.102 and 266.103). Thus, these facilities are only subject to 

the RCRA WAP requirements, which include, among others, RCRA WAP feedstream 

characterization requirements prior to treatment to ensure compliance with applicable BIF 

or Subpart X pollutant feedrate and emission limitations. 20 

Also, some boilers and HCl production furnaces are not necessarily subject to the full suite 

of CAA HWC NESHAP standards. Only boilers and HCl production furnaces that are 

determined to be “major sources”21 are required to comply with all CAA HWC NESHAP 

standards. Boilers and HCl production furnaces that are not major sources are considered 

“area sources” and have the option to either comply with the full suite of CAA HWC 

NESHAP standards or a mix of CAA HWC NESHAP standards and RCRA emission standards. 

Specifically, area sources that choose not to be subject to the full suite of CAA HWC NESHAP 

standards are subject to the CAA HWC NESHAP standards for mercury, dioxin/furans, 

carbon monoxide/hydrocarbons, and destruction and removal efficiency, while the RCRA 

standards under Part 266, Subpart H for particulate matter, metals other than mercury, and 

hydrogen chloride and chlorine apply. For additional information, see §§266.100(b)(3), 

270.22, 270.66, and the final rule preamble (Federal Register 70:196 (12 October 2005) 

pps. 59433-59434). As a result, the RCRA WAP would need to cover these pollutants to 

ensure compliance with RCRA feedrate limitations that are then used to ensure compliance 

with the RCRA controlled emissions not covered by the CAA HWC NESHAP requirements. 

 

19 The Subpart X regulations do not include specific performance standards, but instead direct permitting 

authorities to look at requirements from other sections in the regulations to develop appropriate permit 

conditions for miscellaneous units. Thus, permitting authorities may include operating parameters and emission 

limitations from the CAA HWC NESHAP in RCRA permits for thermal treatment units. Regardless of the source of 

the standards, the RCRA WAP is applicable for all units regulated under Subpart X. 

20 The Draft 1994 Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, although never finalized, 

contains information related to combustor constituent feedstreams and the associated sampling and analysis 

strategies (e.g., batch, qualification, and statistical) for determining compliance that readers may still find useful. 

(EPA 530-R-94-019, October 1994). 

21 As defined in the CAA, a major source is any stationary source that emits or has the potential to emit 10 tons per 

year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP. An area source is a stationary 

source that is not a major source. Generally, NESHAP standards do not apply to area sources. However, EPA chose 

to regulate certain area source HWCs (incinerators, cement kilns and lightweight aggregate kilns) under the 

NESHAP standards. Therefore, all incinerators, cement kilns, and lightweight aggregate kilns must comply with 

NESHAP standards. A separate decision was made for boilers and HCl production furnaces such that those area 

sources have the option to comply with all or some of the NESHAP standards. Lastly, EPA determined that all HWC 

area sources are required to have a CAA Title V permit. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-27

In summary, the RCRA WAP is still a required component of a RCRA permit for all RCRA 

facilities that are also subject to the CAA HWC NESHAP standards for the following reason:

The RCRA WAP is needed to ensure the applicable general waste analysis requirements 

found in §264.13 are being met for both on-site and off-site combustion sources (e.g., 

verifying waste received from off-site sources matches the waste identified on the 

manifest, identification of the hazardous constituents, including the ignitable/reactive/ 

corrosive characteristics, verifying the compatibility of the hazardous waste prior to 

mixing that waste with other wastes in tanks or containers prior to further treatment or 

disposal at the facility, and characterizing combustion residues to determine whether 

they exhibit any hazardous waste characteristics that could affect LDR requirements).

2.5 Selecting Sampling Procedures

Sampling is the physical collection of a 

representative portion of a waste or waste 

treatment residual. 40 CFR 260.10 defines 

“representative sample” as a sample of a universe 

or whole (e.g., waste pile, lagoon, ground water) 

which can be expected to exhibit the average 

properties of the universe or whole. EPA has 

clarified that the term “representative sample” 

refers primarily to the issue of sampling accuracy, 

i.e., the samples exhibit the average properties of

the whole waste or treatment residual. 

To be representative, a sample needs to be collected and handled in a way that preserves 

its original physical form and chemical composition and prevents contamination. For a 

sample to provide meaningful data, it is important that it reflect the properties of the waste 

from which it was obtained, that its physical and chemical integrity be maintained, and that 

it be analyzed within a dedicated quality assurance program.

Due to the diversity of hazardous wastes and the number of possible generation (e.g., batch, 

continuous feed) and waste management scenarios (e.g., drums, roll-off boxes, tankers, and 

lugger boxes), the type(s) of sampling procedures will vary. The following subsections 

discuss the proper procedures and considerations for sample collection, sample 

preservation, quality assurance/quality control (QA/QC), and occupational health and safety.

Only the methods referenced in Appendix I to Part 

261 are discussed in this guidance manual. These 

methods have two sources: the American Society for 

Testing and Materials (ASTM) methods and EPA’s 

SW-846. In particular, SW-846 has been developed 

by EPA to assist the regulated community in meeting 

analytical responsibilities under RCRA.

TSD Facilities and Generators

Refer to your state’s requirements that 

apply to you, as they may be more 

stringent and/or broader in scope than the 

federal program.

40 CFR 264/265.13(b) and (c) require that 

WAPs address sampling methods which will 

be used to obtain representative samples. 

Note: Although this section includes 

sampling information relevant to both 

hazardous waste and LDR determinations, 

the need for “representative sampling” 

applies to hazardous waste, but not LDR, 

determinations. For additional information, 

refer to the LDR Phase IV final rule at Federal 

Register 63:100 (26 May 1998) p. 28562.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-28

2.5.1 Sampling Strategies and Sampling Frequencies

An accurate representation of a waste’s physical and 

chemical properties is critical in determining viable waste 

management options. Accordingly, a facility’s WAP must 

specify waste parameters that provide sufficient information 

to ensure:

 Compliance with the applicable regulatory requirements 

(e.g., LDR regulations, newly identified or listed 

hazardous wastes).

 Conformance with permit conditions (i.e., ensure that 

wastes accepted for management fall within the scope of 

the facility permit, and process performance standards 

can be met).

 Effective and appropriate waste management operations (i.e., ensure that no wastes are 

accepted that are incompatible or inappropriate given the type of management 

practices used by the facility).

Sampling Strategies 

The development and application of a sampling strategy is a prerequisite to obtaining a 

representative sample capable of producing scientifically viable data. Strategies may need to 

be selected or prepared prior to actual sampling to organize and coordinate sampling 

activities, to maximize data accuracy, and to minimize errors attributable to incorrectly 

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

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

 Selection of sampling locations.

 Number of samples.

 Sampling frequency.

 Sample collection and handling techniques.

In addition, the following factors may need to be taken into consideration for the wastes to 

be sampled since they can influence the sampling development process:

 Physical properties. 

 Chemical properties. 

 Special circumstances or considerations (e.g., complex multi-phase wastestreams, 

highly corrosive liquids, oily sludges) that may require the wastes to be homogenized 

prior to sampling or other techniques to be used to obtain a representative sample. 

Sampling Methods and 

Quantities

Although a single grab sample 

is easy and inexpensive to 

collect, it may not be adequate 

to characterize a wastestream 

(e.g., under §262.11). The 

sampling methods and 

quantities used need to be 

representative of the 

wastestream being sampled as 

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

PART TWO: Documenting and Conducting Waste Analysis 2-29

Conversely, if a facility is conducting phase separation as a treatment of a waste, each 

phase of the waste may need to be sampled and analyzed separately. 

Based upon the data objectives and other considerations identified in the sampling 

strategy, two major sampling approaches may be employed to collect representative 

samples. These approaches are summarized as follows:

Authoritative Sampling - where sufficient historical, site, and process information is 

available to accurately assess the chemical and physical properties of a waste, authoritative 

sampling (also known as judgment sampling) can be used to obtain representative 

samples. Sample locations are selected based on knowledge of waste properties (e.g., 

homogeneous process streams) and level of uniformity or waste distribution, as well as 

waste management units. The validity of authoritative sampling is dependent upon the 

accuracy of the information used. The rationale for selection of sampling locations is 

important and should be documented.

Random Sampling - due to the difficulty in determining the exact chemical and physical 

properties of most hazardous wastestreams (needed for using authoritative sampling), 

random sampling strategies are most commonly used. Random sampling is based upon 

mathematical and statistical theories and can ensure that representative samples are 

obtained from the waste. Generally, three specific techniques, simple, stratified, and 

systematic random, are employed. 

Table 2-4 Sampling Approach Overview provides a summary of both authoritative and 

random sampling definitions, applicability, and limitations. Figure 2-3 Illustration of 

Random, Stratified Random, and Systematic Sampling illustrates the typical sampling 

distribution associated with each of the individual types of random sampling.

An additional element in the design of an effective sampling strategy is the selection of 

appropriate sample types. Based on the analytical objectives of sampling (e.g., initial waste 

identification versus recharacterization), analytical considerations, regulatory 

requirements, and available resources (for sampling and analysis), two basic types, grab 

and composite samples can be collected, as described in Table 2-5 Major Sample Types.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-30

Different Sampling and Analysis Objectives for Enforcement Agencies and Waste Handlers 

“Proving the Positive” versus “Proving the Negative”

For enforcement agencies and waste handlers, the purpose of a sampling and analysis program is to identify 

chemical constituents and characteristics in waste to adhere to or ensure adherence to regulations. Many 

RCRA regulations contain concentrations that are not to be exceeded to comply with the standard. 

Nonetheless, the sampling and analysis conducted by a waste handler can be different from that conducted by 

enforcement agencies due to a difference in the objectives of each. 

When the objective for an enforcement official is to evaluate a waste handler’s compliance with a “do not 

exceed” standard, the enforcement official will likely initially collect one sample based on professional judgment. 

The waste handler, however, may want to ensure that waste concentrations are low enough so that it would be 

highly unlikely that any individual sample of the waste would exceed a “do not exceed” regulatory standard.

The sampling and analysis objective of the enforcement official is sometimes called “proving the positive.” That 

is, the enforcement official determines whether a concentration of a specific constituent in some portion of the 

wastestream exceeds the regulatory level. This only requires a single measurement above the regulatory level 

to draw such a conclusion, that the waste at least in part exceeds the “do not exceed” regulatory standard. 

“Proving the positive” usually does not depend on low detection limits or high analyte recoveries. Per Federal 

Register preamble (see Federal Register 55:27 (8 February 1990) p. 4442). It reads:

“If a sample possesses the property of interest, or contains the constituent at a high 

enough level relative to the regulatory threshold, then the population from which the 

sample was drawn must also possess the property of interest or contain that constituent.”

The sampling and analysis objectives of a waste handler on the other hand may focus on “proving the 

negative.” While it is never possible to have complete confidence in a determination, the waste handler may 

seek to demonstrate with a high level of confidence that the vast majority of the waste is far enough below the 

regulatory standard so that an additional sample of the waste, perhaps collected by an enforcement official,

would be unlikely to exceed the regulatory standard. “Proving the negative” is far more demanding than 

“proving the positive” and thus encourages proper sampling design and good quality control. Per Federal 

Register preamble (see Federal Register 55:27 (8 February 1990) p. 4441). It reads:

“The sampling strategy for these situations (proving the negative) should be thorough enough 

to insure that one does not conclude a waste is non-hazardous when, in fact, it is hazardous.”

Similar considerations apply when developing a sampling strategy to assure compliance with applicable Part 268 

requirements prior to placing waste in a land disposal unit. Therefore, the waste handler may want to establish 

objectives that focus on “proving the negative.” This is accomplished by using a systematic planning process, 

designing a WAP based on the objectives, collecting and analyzing the appropriate number of samples, and using 

the results from the sample analyses for decision-making.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-31

TABLE 2-4: Sampling Approach Overview

Sample Strategy Definition Applicability Advantages/Disadvantages

AUTHORITATIVE Technique where sample locations are 

selected based on detailed knowledge 

of the wastestream without regard to 

randomization.

Wastestreams of known physical/ 

chemical properties and 

concentrations.

Requires in-depth knowledge of properties and 

hazardous constituents of wastestreams. Rationale for 

sample selection should be documented and 

defensible.

RANDOM

(Simple, 

Stratified, 

Systematic)

Technique where sample selection and 

location are determined through the 

application of statistical methods.

Used to collect representative 

samples where data is insufficient to 

justify authoritative sampling (e.g. 

wastestreams of unknown or variable 

concentration).

See discussions below for each respective random 

sampling technique.

 Simple 

Random

All locations/points in a waste or unit 

from which a sample can be obtained 

are identified, and a suitable number 

of samples are randomly selected.

Used to collect representative 

samples of wastes that are 

heterogeneous throughout the entire 

wastestream or unit (e.g. multiple 

drums of unknown origin).

Advantages: Most appropriate where little or no 

information is available concerning the distribution of 

hazardous constituents.

Disadvantages: May misrepresent wastestreams with 

areas of high concentration or stratification.

 Stratified 

Random

Areas of nonuniform properties or 

concentrations are identified and 

stratified (segregated). Subsequently, 

simple random samples are collected 

from each stratum of the waste or unit.

Used to collect representative samples 

from waste or units that are known to 

have areas of nonuniform properties 

(strata) or concentration (hot spots) 

[e.g. surface impoundments with 

multiple waste layers].

Advantages: Provides for increased accuracy of 

wastestream representation if strata or a typically high 

or low concentration area is present.

Disadvantages: Requires a greater knowledge of the 

wastestream relative to waste where simple random 

sampling is used and may require sophisticated 

statistical applications.

 Systematic 

Random

The first sampling point is randomly 

selected but all subsequent samples 

are collected at fixed space intervals 

(e.g. along a transect or time intervals.)

An alternate procedure used to 

collect representative samples from 

modestly heterogeneous 

wastestreams that provides for 

simplified sample identification.

Advantages: Provides for easier sample identification 

and collection relative to other techniques.

Disadvantages: May misrepresent wastestreams with 

unknown areas of high concentration or stratification.
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PART TWO: Documenting and Conducting Waste Analysis 2-32

FIGURE 2-3: Illustration of Simple Random, Stratified Random and 

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

PART TWO: Documenting and Conducting Waste Analysis 2-33

TABLE 2-5: Major Sample Types

Sample Type Definition Applicability Advantages/Disadvantages

GRAB A sample taken 

from a particular 

location at a 

distinct point in 

time.

Most common type used 

for random sampling. 

Useful in determining 

wastestream variability 

(e.g. range of 

concentration) when 

multiple or frequent 

samples are obtained.

Generally, one grab 

sample is used for 

enforcement compliance 

with LDR nonwastewater 

treatment standards.

Advantages: Simplest technique, best 

measure of variability and range of 

contaminant concentrations.

Disadvantages: May require a larger number 

of samples relative to composite sampling to 

obtain a representative sample.

COMPOSITE A number of 

random samples 

are initially 

collected from a 

waste and 

combined into a 

single sample for 

subsequent 

analysis.

Used where average or 

normalized concentration 

estimates of a 

wastestream’s hazardous 

constituents are desired.

Note: If collecting 

samples to determine 

compliance with LDR 

treatment standards, you 

may not be able to collect 

composite samples. 

Please check the 

applicable regulations 

before proceeding.

Advantages: Reduces analytical costs. May 

reduce the number of samples needed to 

gain accurate representation of a waste.

Disadvantages: Only provides the average 

concentrations of a wastestream (i.e.,

information about concentration range 

is lost). May not be appropriate in a number 

of situations. For example, compositing 

samples from multiple containers is not 

appropriate for hazardous waste 

determination if each container represents a 

completely different point of generation, if 

the waste-generating process dramatically 

changes between/during accumulations, or if 

the containers’ wastes are largely unknown.

Note: You should generally not collect 

composite samples if you are analyzing for 

VOCs unless permitted by the regulations, as 

these compounds can be lost during sample 

mixing. If you are sampling for parameters in 

addition to VOCs (e.g., metals), you may 

composite samples for these other analyses as 

long as the compositing procedure will not 

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

PART TWO: Documenting and Conducting Waste Analysis 2-34

A composite sample is a number of 

individual samples called aliquots 

collected from a volume of waste that 

are combined into a single sample for 

analysis. Composite sampling is an 

attractive option as it can help to 

reduce costs when used appropriately 

and where it is not explicitly 

prohibited by regulation. 

A disadvantage of composite sampling 

is that “hot spot” contaminant 

concentrations can become diluted. 

This problem may be alleviated by 

dividing a do-not-exceed action level

by the number of aliquots comprising 

the composite sample, resulting in a 

new lower action level. After this is 

done, it must be ensured that the 

analytical lower limit of quantitation 

(LLOQ) is less than or equal to the 

newly adjusted (lower) action level. 

EPA believes this approach can be 

useful as a conservative screening 

approach in certain situations. Indeed, 

dividing a do-not-exceed action level 

by the number of aliquots will result in 

a lower, more conservative level. A 

facility may, for example, initially 

decide to take a composite sample for 

comparison to a conservative action 

level. If the composite sample exceeds

it, the facility may then decide to 

collect and analyze grab samples for 

comparison to the original action level, 

which is generally preferable. For 

further information, refer to the 

Superfund guidance on representative 

sampling, Volume 4 (see Section 2.3.2 

“Composite Sample” in the Superfund 

guidance) and Chapter 9 of SW-846, as 

referenced below.

Another factor to be considered when compositing is that the waste being sampled should be 

relatively homogeneous and that none of the anticipated contaminants are volatile 

compounds since volatile substances may be lost during homogenization of the aliquots. 

Grab or Composite Samples?

It is imperative that you understand both the applicable 

regulations and the intended use of the sample data 

before determining whether to collect either grab or 

composite samples.

For example, compliance with the LDR numeric 

concentration-based treatment standards for nonwastewaters typically is to be determined using one “grab” 

sample rather than composite samples. Grab samples 

processed, analyzed, and evaluated individually normally 

reflect maximum process variability, and thus reasonably 

characterize the range of treatment system performance. 

Typically, a grab sample is used to evaluate LDR nonwastewaters and composite samples are used to evaluate 

LDR wastewaters, except when evaluating wastewaters for 

metals (D004 through D011) for which grab samples are 

required [§268.40(b)].

For additional information, see the following:

 Land Disposal Restrictions for Second Third Scheduled 

Wastes. Federal Register 54:120 (June 23, 1989). pps. 

26605-26606. See Treatment Standards Based on 

Single Facility Data and Grab Samples Versus 

Composite Samples.

 Land Disposal Restrictions for Third Third Scheduled 

Wastes. Federal Register 55:106 (June 1, 1990). p. 

22539. See Treatment Standards Based on Single 

Facility Data, Grab Samples Versus Composite Samples, 

and Waste Analysis Plans.

 Land Disposal Restrictions Phase IV: Second 

Supplemental Proposal on Treatment Standards for 

Metal Wastes and Mineral Processing Wastes, Mineral 

Processing and Bevill Exclusion Issues, and the Use of 

Hazardous Waste as Fill. Federal Register 62:91 (May 

12, 1997) p. 26047. See Demonstrating Compliance by 

Grab or Composite Sampling.

 Land Disposal Restrictions Phase IV: Final Rule 

Promulgating Treatment Standards for Metal Wastes 

and Mineral Processing Wastes; Mineral Processing 

Secondary Materials and Bevill Exclusion Issues; 

Treatment Standards for Hazardous Soils, and Exclusion 

of Recycled Wood Preserving Wastewaters. Federal 

Register 63:100 (26 May 1998) p. 28562. See 

Development of New Treatment Standards for 

Hazardous Wastes Containing Metals: Measuring 

Compliance by Grab or Composite Sampling.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-35

Finally, it is very important to ensure that the individual aliquots are all equal in volume 

before they are combined and homogenized.

A grab sample is a single sample from a particular location within a volume of waste at a 

distinct point in time. Grab samples should generally be collected if the integrity of the 

sample may be affected by the physical mixing of samples during the compositing process 

(e.g., volatile constituents), and when determining compliance with the LDR requirements 

as specified (e.g., compliance with UHCs is measured by an analysis of a grab sample unless 

otherwise noted in the regulations). EPA established treatment standards for wastes based 

on grab sampling as it reflects maximum process variability, and thus reasonably 

characterize the range of treatment system performances. 

While EPA established treatment standards and the basis for LDR enforcement on a grab 

sampling approach, a RCRA WAP may authorize a different mode of sampling and 

monitoring in the permit. For example, a demonstration of statistical equivalence between 

a composite sampling protocol and one based on grab sampling could be provided for 

particular wastes. Another example might be to demonstrate why monitoring for a subset 

of pollutants would assure compliance of those not monitored. A RCRA WAP may require 

numerous grab samples to predict compliance for wastes that are not homogeneous while 

a composite sampling approach, possibly comparing results to a level of performance more 

stringent than the treatment standard, might also be justified with fewer total samples. For 

additional information, refer to the preamble in these final rules: Land Disposal Restrictions 

for Second Third Scheduled Wastes (Federal Register 54:120 (23 June 1989). p. 26606) and 

Land Disposal Restrictions for Third Third Scheduled Wastes (Federal Register 55:106 (1 

June 1990). p. 22539). 

EPA notes, however, that enforcement of the LDR treatment standards is based on grab 

samples, not the facility’s waste analysis plan (§268.40(b)). For more information, refer 

to the preamble in the LDR Second Third rule. While a facility’s WAP may include 

sampling protocols that differ from those used to determine the treatment standard, it 

only requires a single grab sample above the regulatory level for an enforcement official 

to determine noncompliance with the LDR treatment standards. If multiple grab samples 

are taken, each sample must meet the treatment standard prior to land disposal without 

exception. If one grab sample fails to meet any applicable treatment standard, the waste 

must be retreated and tested to ensure compliance with applicable LDR treatment 

standards prior to land disposal.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-36

Representative Sampling: 

Strategies for Problematic Wastes and Materials*

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

Example: A large pile of smelter slag where particles range in size from dust particles to 1300 lb casts, making it 

difficult to get a representative sample.

Possible Approach: Non-random sampling based on the experience and judgment of the person performing the 

sampling may be employed (e.g., collecting particles less than 1/2 inch in diameter). This non-random sample 

could provide a reasonable approximation to a random sample since large particles are expected to have similar 

composition to smaller ones because they resulted from the same process. Furthermore, this non-random sample 

is expected to be "representative" of the pile since the composition of small and large particles are similar. Care 

must be taken to ensure that the purpose of the sampling is considered when conducting nonrandom sampling. 

For the above example, the chemical composition of the waste may be independent of particle size; however, 

properties of the waste such as its leaching potential may still be dependent on particle size.

2. High-Volume Wastes

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

very difficult. 

Possible Approach: In such cases, replicate composites composed of random grab samples of the readily 

available material (e.g., residues within 12 inches of the surface) may be taken. Conclusions regarding the level 

of hazard of the waste can be drawn by examining the variability of the values obtained on replicate composites. 

The sampling, compositing and data evaluation process is then repeated until the confidence in the 

representativeness of the mean reaches the desired level (e.g., less than 10% probability that the true mean is 

above an appropriate regulatory threshold). While each individual sample or even composite may not be 

representative of the residue, the sum total of samples taken will represent the average property of the waste 

even though the entire wastestream was not sampled.

3. Numerous, Highly Varied Wastes

Example: A disposal site is found that contains components of qualitatively different properties (e.g., color, 

composition, physical state) and the question to be answered is whether hazardous waste was disposed of at 

the site.

Possible Approach: In this case, one is faced with the situation, not of sampling all components at the site, but 

rather of sampling one or more individual components of the body of waste at the site. Each of the qualitatively 

different components (materials) could be a discrete waste, and the concept of representative sampling would 

refer to sampling of each discrete waste rather than sampling all of the waste at the site as a whole. Therefore, 

when faced with such a situation, the sampler would identify the components of the waste site to be 

characterized and would obtain data representative of the properties of each component of interest. The 

decision as to whether or not the site contains hazardous waste would, therefore, hinge on whether any of the 

individual components disposed were hazardous, and not on whether the average of all of the components at 

the site exhibit the properties of hazardous waste.

* These examples are taken from an EPA notice: Hazardous Waste Management System; Testing and Monitoring 

Activities. Federal Register 55:27 (8 February 1990) pps. 4443-4444. Representative Sample Definition. 

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

PART TWO: Documenting and Conducting Waste Analysis 2-37

Further information on sampling strategies and the optimum applications for each strategy 

is included in the following guidance documents, methods, and standards:

 EPA Observational Economy Series, Volume 1: Composite Sampling, EPA 230-R-95-005, 

U.S. Environmental Protection Agency, Washington, D.C., 1995.

 Guidance for Obtaining Representative Laboratory Analytical Subsamples from 

Particulate Laboratory Samples, EPA/600/R-03/027, U.S. Environmental Protection 

Agency, 2003.

 Guidance on Choosing a Sampling Design for Environmental Data Collection for Use in 

Developing a Quality Assurance Project Plan, EPA/240/R-02/005, U.S. Environmental 

Protection Agency, Washington D.C., December 2002.

 Hot Spots: Incremental Sampling Methodology (ISM) FAQs, Interstate Technology & 

Regulatory Council (ITRC), 2014.

 Incremental Sampling Methodology, Interstate Technology & Regulatory Council (ITRC) 

Web site.

 RCRA Waste Management: Planning, Implementation, and Assessment of Sampling 

Activities, Manual 42, American Society of Testing and Materials, 2000.

 RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation and 

Assessment, EPA 530-D-02-002, U.S. Environmental Protection Agency, Washington, 

D.C., August 2002.

– Chapter 5: Optimizing the Design for Obtaining Data

– Chapter 6: Controlling Variability and Bias in Sampling

– Appendix C: Strategies for Sampling Heterogeneous Wastes

 Superfund Program Representative Sampling Guidance, Volume 4: Waste, EPA 540-R-95-

141, U.S. Environmental Protection Agency, Washington, D.C., 1995. 

 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, Third 

Edition, Through Final Update IVB, U.S. Environmental Protection Agency, Washington, 

D.C., 2008.

– Chapter Nine: Sampling Plan

Sampling Frequencies

The RCRA regulations state that the waste analysis conducted under §§264/265.13(a)(1)

must be repeated as necessary to ensure that it is accurate and up to date” 

[§§264/265.13(a)(3)]. At a minimum, the analysis must be repeated as follows:

 When the owner or operator is notified, or has reason to believe, that the process or 

operation generating the hazardous wastes, or non-hazardous wastes if applicable 

under §§264/265.113(d), has changed [§§264/265.13(a)(3)(i)].
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-38

 For off-site facilities, when the results of the inspection required in §§264/265.13(a)(4) 

(e.g., fingerprint analysis) indicate that the hazardous waste received at the facility does 

not match the waste designated on the accompanying manifest or shipping paper 

[§§264/265.13(a)(3)(ii)]. 

In addition, an off-site facility must inspect and, if necessary, analyze each hazardous waste 

shipment received to determine if it matches the identity of the waste specified on the 

accompanying manifest or shipping paper. [§§264/265.13(a)(4)]

Although there are no required time intervals for re-evaluating wastes that were originally 

analyzed under §§264/265.13(a)(1), you need to develop a schedule for re-evaluating the 

waste on a regular basis to ensure the analysis is accurate and up to date 

[§§264/265.13(b)(4)]. You may need to make an individual assessment of how often waste 

analysis is necessary to ensure compliance with your RCRA permit operating conditions. In 

particular, off-site combustion facilities may need to characterize all wastes prior to burning 

to verify that permit conditions will be met (i.e., fingerprint analysis may not be acceptable).

When the regulations do not specifically stipulate sampling frequency, you may want to use a 

tiered approach to waste re-evaluation. (TSDFs must do so in accordance with their permit.) 

That is, you may consider conducting a full and accurate initial characterization of each waste 

and then slowly reduce the frequency of re-evaluation over time as long as the hazardous 

constituents are consistently below the action level (defined in Section 2.3). For example, if 

a site generates a new wastestream during its manufacturing operations, the number 

of manufacturing batches to sample should be determined through a sound statistical 

basis and with an understanding of the potential for variability in the wastestream. 

This is important, as the waste handler can use the data from this initial shipment as a 

baseline to evaluate data from the subsequent shipments. There are also a number of ways to 

The Cost of Infrequent Analysis 

Increasing sampling frequency may result in additional analytical costs. These costs may be minor in 

comparison to penalties for non-compliance. Consider a situation where a hazardous waste is disposed of as 

non-hazardous waste and the facility has been sampling the waste annually, a frequency they cannot justify.

Specifically, the facility:

 Analyzes a new wastestream in January and determines that it is non-hazardous. 

 Disposes the waste monthly as non-hazardous based on the initial evaluation.

 Re-analyzes the waste in December and finds it contains hazardous levels of cadmium.

 Properly treats and disposes of the December waste based on the cadmium hazard.

The potential consequences:

 The facility may be subject to penalties for improper disposal of the shipments from February through 

November of that year. The RCRA penalty provisions can be found at 40 CFR Part 19.

 The facility may be financially responsible for the clean-up of the improperly disposed waste, which may 

now be blended with and indistinguishable from other wastes in the unit.

 The insurance premiums of the facility may increase.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-39

use historic waste data to determine re-evaluation frequencies. One possible approach is 

detailed in Section 2.8. You do not need to use this specific approach but your WAP must 

state how you will determine re-evaluation frequencies based on waste data.

2.5.2 Selecting Sample Equipment

Following are four broad criteria relating to waste that should be considered when 

determining the most appropriate type of sampling equipment to use for a given sampling 

strategy:

 Physical parameters.

 Chemical parameters. 

 Waste-specific criteria (e.g., oily sludges). 

 Site-specific factors (e.g., accessibility issues).

Specific physical parameters affecting this selection include:

 Physical State

– Liquid (free flowing or highly viscous) or

– Solid (crushed, powdered, or whole) or environmental media (soil, sediment).

 Distribution

– Homogeneous or

– Heterogeneous (stratified/layered, hot spots).

Chemical parameters of the waste can also significantly affect the waste collection effort. 

The person collecting the sample may need to ensure that the sampling equipment is 

constructed of materials that are not only compatible with the wastes, but are not 

susceptible to reactions that might alter or bias the physical or chemical characteristics of 

the waste. Examples in which the sampling equipment material may potentially yield false 

analytical results would be the release of organic compounds from certain plastics or of 

heavy metals (e.g., cadmium, nickel, lead) from metal alloys used in sampling corrosive 

wastestreams.

Waste- and site-specific factors may also affect the use of sampling devices. Examples of 

waste-specific properties that may affect the use of common sampling equipment are the 

collection of oily sludges or highly corrosive wastes. Examples of site-specific situations 

involving complex sampling activities include the collection of representative samples from 

waste management units with limited accessibility. In addition to determining the type of 

sampling equipment used, the waste- and site-specific factors also may require 

modification of the chosen equipment so that it can be applied to the waste.

Once the physical, chemical, waste- and site-specific factors associated with the 

wastestream have been identified and evaluated, appropriate sampling equipment can be 

selected. The equipment most typically used in sampling includes:
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PART TWO: Documenting and Conducting Waste Analysis 2-40

 Composite liquid waste samplers (coliwasas), weighted bottles, and dippers for liquid 

wastestreams.

 Triers, thieves, and augers for sampling sludges and solid wastestreams.

 Bailers, suction pumps, and positive displacement pumps for sampling wells for 

groundwater evaluations.

Liquid Samples

A coliwasa is most appropriate when sampling free-flowing liquids and slurries in drums, 

shallow tanks, pits, and similar waste containers. The stream coliwasa consists of a glass or 

plastic or metal tube equipped with an end closure that the sampler can open and close to 

initiate and/or stop the sampling while the tool is submerged in the material to be sampled. 

A weighted bottle or dipper may be used to obtain a sample of a free flowing liquid or 

slurry from areas with limited accessibility. See Figure 2-4 Samplers for Liquid 

Wastestreams for depictions of coliwasa, weighted bottle, and dipper samplers.

Solid Samples

A thief is suitable for sampling dry granules or powdered wastes whose particle diameter 

is less than one-third the width of the slots in the thief. The thief consists of two slotted 

concentric tubes. The outer tube has a conical pointed tip that allows the thief to penetrate 

the waste you are sampling. The sampler then rotates the inner tube to a closed position so 

that a sample can be retrieved from the wastestream. A sampling trier is a tube cut in half 

lengthwise with a sharpened tip that allows penetration of the tube into adhesive solids 

and allows the sampler to loosen granulated materials. Generally, the trier is 61 to 100 cm 

long with a diameter between 1.27 and 2.54 cm. It is used to sample solids whose diameter 

is less than one-half that of the trier. Augers are used to sample hard or packed solid 

wastes and consist of sharpened spiral blades attached to a hard metal central shaft. 

Augers can be one foot to several feet long. See Figure 2-5 Samplers for Solid Wastestreams 

for depictions of thief, trier, and auger samplers.

Table 2-6 Applicability of Sampling Equipment to Wastestreams presents examples of 

common types of sampling equipment and their applicability for sampling various types of 

wastestreams. Waste-specific conditions at your facility may indicate that the 

recommended equipment is inappropriate. Accordingly, it is best to develop a sampling 

strategy with equipment that is tailored to your site. SW-846, Chapter 9 contains additional 

guidance on the applicability of sampling equipment for different waste matrices. 

Alternatively, consult with a knowledgeable EPA representative, a qualified environmental 

testing laboratory or industry group if you are uncertain as to how to select the appropriate

equipment. Further, it is important to ensure that facility personnel follow the strategy and 

use equipment appropriately. For example, to obtain a representative sample of a waste 

using a coliwasa, the entire contents of the coliwasa must be placed into a single sample 

container. A representative sample would not be obtained by putting the contents into 

multiple different containers, each being analyzed for a separate parameter. This is 

particularly true for multi-layer waste.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-41

FIGURE 2-4: Samplers for Liquid Wastestreams

Coliwasa

Coliwasa

Weighted Bottle

Weighted Bottle

Dipper

Dipper
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PART TWO: Documenting and Conducting Waste Analysis 2-42

FIGURE 2-5: Samplers for Solid Wastestreams

Thief

Thief

Trier

Trier

Hand Augers

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

PART TWO: Documenting and Conducting Waste Analysis 2-43

TABLE 2-6: Applicability of Sampling Equipment to Wastestreams

Waste Location or Container

Waste

Type Drum

Sacks and 

Bags

Open Bed

TRUCK

Closed Bed 

Truck

Storage Tanks 

Or Bins

Waste

Piles

Ponds, 

Lagoons, Pits

Conveyor 

Belt Pipe

Free-flowing 

liquids and slurries

Coliwasa N/A N/A Coliwasa Weighted

bottle (a)

N/A Dipper N/A Dipper

Sludges Trier N/A Trier Trier Trier (b) (b) (b) (b)

Moist powders 

or granules

Trier Trier Trier Trier Trier Trier Trier Shovel Dipper

Dry powders or 

granules

Thief Thief Thief Thief (b) Trier Thief Shovel Dipper

Packed Sand or 

powders and 

granules

Auger Auger Auger Auger Thief Thief (b) Dipper Dipper

Large-grained 

solids

Large

Trier

Large 

Trier

Large Trier Large Trier Large

Trier

Large

Trier

Large

Trier

Trier Dipper

a When the tank is adequately agitated or a recirculation line is accessible, samples can be collected through a side tap.

b This type of sampling situation can present significant logistical sampling problems, and sampling equipment must be specifically selected or designed based on-site and waste conditions. No 

general statement about appropriate sampling equipment can be made.
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2.5.3 Maintaining and Decontaminating Field Equipment

Some analyses, such as pH tests, can be performed at the facility using field equipment. In 

order to ensure data quality, this equipment should be properly maintained and calibrated 

regularly. The maintenance guidelines set forth in the operator’s manual of each piece of 

equipment may help determine calibration frequency as proper maintenance varies by 

model manufacturer. At a minimum, the facility may need to inspect and calibrate the 

equipment prior to use and keep calibration records on file for review. 

All equipment that comes in contact with waste needs to be free of residual materials so 

that it would not influence (i.e., contaminate) the true physical or chemical composition of 

the waste. Therefore, to minimize the potential for cross-contamination, all equipment and 

containers should be cleaned thoroughly and decontaminated prior to use. Also, all 

sampling equipment should be decontaminated after each sampling event. These 

procedures generally consist of an initial step to remove all loose debris and soil from the 

sampling equipment, followed by a thorough cleaning process, including washing with an 

inert detergent solution (such as alconox). As a final step, the equipment is rinsed with an 

appropriate solvent (e.g., volatile alcohols, acetone, or hexane for organics; nitric acid for 

inorganics) followed by several rinses with deionized water. It is EPA’s expectation that all 

decontamination and rinse solutions, especially in enforcement cases, will be properly 

collected, characterized and managed. If material or debris removed from field equipment 

qualifies as RCRA hazardous waste, it must be managed accordingly.

The level of decontamination that is appropriate during and after sampling is dependent 

upon the degree of contamination and the sensitivity of the analytical tests to be 

performed. Where materials and equipment are to be reused, proper decontamination 

procedures should be followed to diminish the potential for cross-contamination of 

samples. If subsequent storage of the equipment does not preserve the cleanliness of the 

decontaminated equipment, the equipment should be decontaminated prior to the next 

sampling event.

Sample containers may be supplied by a laboratory equipment manufacturer or by your 

analytical laboratory. For manufacturer-supplied containers, a certificate of analysis, or 

other documentation may be obtained, which describes the contaminant levels inherent to 

the sample containers. In either case, appropriate quality control measures, as described in 

subsequent sections, should be taken. Furthermore, used containers that have not been 

decontaminated generally should be avoided to reduce the potential of cross-contamination.

2.5.4 Sample Preservation and Storage

Once the sample has been collected, sample preservation techniques and holding times, if 

applicable, need to be employed to ensure that the integrity of the waste remains intact 

while the samples are in transport to an off-site laboratory and/or while stored at the 

laboratory prior to analysis. Sample preservation is generally not applicable for highly 

concentrated samples; however, low concentration samples need preservation. If a sample 

is not preserved properly, the constituents of concern in the sample may be chemically, 
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physically, or biologically altered through degradation or other processes (e.g., 

volatilization, oxidation). Examples of typical sample preservation techniques include:

 Preserving the sample with appropriate chemicals (e.g., adding an acid preservative to 

suppress biological activity).

 Refrigerating samples.

 Storing and shipping samples in the appropriate container and lid type (e.g., collecting 

samples for light sensitive organic contaminants in amber glass bottles).

Appropriate preservation methods allow samples to be stored without concern for physical 

or chemical degradation for the time between sample collection and analysis. However, the 

effectiveness of preservation diminishes over time, thereby potentially affecting the 

sample’s integrity. Accordingly, EPA has established standardized holding times, based 

upon the chemical constituent of interest to ensure the integrity and validity of resulting 

analytical data. For a detailed list of proper sample containers preservation techniques, and 

holding times, if applicable, refer to SW-846, Chapter 2, and the individual SW-846 

methods themselves.

2.5.5 Establishing Quality Assurance/Quality Control Procedures

Quality assurance (QA) is the process for ensuring that all data and the decisions based on 

that data are technically sound, statistically valid, and properly documented. Quality 

control (QC) procedures are the tools employed to measure the degree to which these 

quality assurance objectives are fulfilled. 

As the first component of data acquisition in relation to waste testing, sampling techniques 

may need to incorporate rigorous QA/QC procedures to ensure the validity of sampling 

activities. Since a facility’s compliance with applicable permitting and regulatory 

requirements may be based on a relatively few number of analytical measurements, any 

event (e.g., unidentified contamination, dilution, improper handling) that may compromise 

the collection and measurement of a representative sample is significant. Thus, it is 

important for QA/QC procedures to be established in the WAP and followed. Each facility 

will likely implement its own QA/QC procedures because each facility will have its own 

unique QA/QC requirements. Additionally, all persons involved in sampling activities may 

need to be aware of applicable QA/QC procedures. More detail on what may be needed for 

QA/QC is provided in SW-846. Finally, note that a number of the topics discussed in this 

section dealing with sample collection/management (e.g., precision and bias) also apply to 

laboratory analysis, which is discussed later in this manual. 

Quality Assurance

In many ways, QA can only be measured qualitatively. For example, to assure that samples 

are taken with the same level of precision each time, QA procedures can be as simple as 

making sure that the personnel collecting the sample are trained and experienced. 
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Additionally, a chain-of-custody protocol is a useful qualitative tool for documenting the 

time and location of sample collection activities. The WAP may need to provide facilityspecific procedures, including:

 Sample strategy (including type of samples to be collected).

 Sampling identification numbers and locations.

 Preservation reagents and techniques, as appropriate.

 Chain-of-custody procedures.

 Types of sampling equipment and sample containers.

 Analytical procedures.

 Decontamination procedures.

 Field and laboratory QC procedures (see related discussions below).

 Relevant health and safety considerations.

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

them.

Quality Control

QC procedures, as tools to measure the attainment of QA objectives, lend themselves to be 

measured more quantitatively. Control samples are QC samples that are introduced into a 

process to monitor the performance of the system. Control samples can be used in 

different phases of the data collection process beginning with sampling and continuing 

through transportation, storage, and analysis.

The representativeness of a statistical sample (i.e., a set of samples) can be described in 

terms of precision and bias. Precision is the degree of agreement among repeated 

measurements of the same analyte on the same sample or separate samples. It tells how 

consistent and reproducible the methods are by showing how close the measurements are 

to each other. It does not mean that the sample results actually reflect the "true" value, but 

that the methods are giving consistent results under similar conditions. Bias, on the other 

hand, refers to the systematic or persistent distortion of a measured value from its true 

value. Bias can be measured, for example, by whether QC data fall into an acceptable range 

as determined by the lab or other reliable source.

The analogy of a target often is used to illustrate the concepts of precision and bias. In Figure 

2-6, the center of each target (A through D) represents the true (but unknown) average 

concentration in a batch of waste. The holes in the targets represent measurement results 

from samples taken to estimate the true concentration. The precise holes in the targets are 

those clustered together, irrespective of whether they are near the bull’s eye (see targets A 

and B). The unbiased holes are those close to the bull’s eye, irrespective of whether they are 

clustered together (see targets A and C). For example, target A indicates high precision and 
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FIGURE 2-6: Precision Versus Bias

low bias in the sampling and analysis

results. Generally, high precision and

minimal bias are required when one 

or more chemical constituents in a 

solid waste are present at 

concentrations close to the applicable 

regulatory threshold or action level. 

On the other hand, target D depicts 

the situation where the sampling and 

analytical process suffers from both 

imprecision and bias. The bias will 

result in an incorrect estimate of the 

true concentration, even if 

innumerable samples are collected 

and analyzed to control the impact of 

imprecision (i.e., bias will not “cancel 

out” with increasing numbers of 

samples). 

For more information on precision, 

bias, accuracy, and representativeness, 

see the RCRA Waste Sampling Draft 

Technical Guidance, Planning, 

Implementation and Assessment (EPA 530-D-02-002).

QC measures that can be taken throughout the sampling process to ensure the integrity of 

the overall program include:

Field Blanks are prepared in the field by filling a clean container with pure deionized water 

and appropriate preservative, if any, for the specific sampling activity being undertaken. If 

contaminants are found to be present in the field blank, it might be assumed that 

environmental factors (such as airborne contamination), sampling procedures (causing crosscontamination), or equipment (that is contaminated) were contributing to the levels of 

hazardous constituents that is measured.

Trip Blanks are sample containers that are prepared in the lab using the same type of 

containers that are to be used for field samples. The containers are filled with an inert 

material (such as deionized water) that are carried into and out of the field but are not 

opened at any time during the sampling event. If the trip blanks were found to be 

contaminated, the source of the contamination would be assumed to be the container itself, 

the environment in which the trip blank was prepared, or some other source located 

outside the sample area.
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Equipment Blanks are prepared prior to sampling by running pure deionized water over 

sampling equipment and collecting the water into a clean sample container. If the 

equipment blank is found to be contaminated, the source of contamination could be 

assumed to be from the equipment used during the sampling operations.

Field Split Samples are collected by actually splitting a sample volume in half and 

submitting the samples to two different laboratories. Sometimes, split samples are 

collected for enforcement purposes. The facility (sampler) splits samples with the regulator 

as a check on the facility’s own analytical program and data recordkeeping. Alternatively, a 

facility may collect a split sample to verify that the analytical results determined at its onsite facility lab can be verified at an independent laboratory.

Field Duplicates are independent samples that are taken from the same location at the 

same time and are used to measure the effectiveness of obtaining representative samples. 

The precision (reproducibility of analytical data) resulting from field duplicates provides an 

accurate reflection of the variance inherent to the waste composition and the sampling 

technique. If blanks and duplicates are collected for analysis, they generally should be 

treated as regular samples, which would include conducting the same preservation and 

storage techniques, as well as completing the proper paper work (e.g., chain-of-custody 

documentation) accompanying the samples. The facility should determine, based on its own 

DQOs, what QC samples to collect, when to collect them, and at what frequency and include 

a description of this in the WAP to be reviewed and approved by the permitting officials.

Chain-Of-Custody

It may be a good idea to specify chain-of-custody procedures, both internal and external, in 

the WAP. An example chain-of-custody record is shown in Figure 2-7 Example Chain-ofCustody Record. Chain-of-custody procedures involve documentation of the possession of 

samples from the time they are obtained until they are disposed or shipped off-site for 

analysis. At a minimum, the procedures should specify the following information when 

samples of waste or treatment residuals are collected: (1) the type of waste collected, 

including a brief description and the manifest number, if applicable, and waste code(s); (2) 

names and signatures of samplers; (3) sample number, date and time of collection, and 

designation as a grab or composite sample, including what type of composite sample; (4) 

names and signatures of any persons involved in transferring samples; and (5) if applicable, 

the shipping number, such as an airbill number, for samples shipped to off-site laboratories.
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FIGURE 2-7: Example Chain-of-Custody Record 
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2.5.6 Establishing Health and Safety Protocols

Worker safety and health should be taken into consideration when preparing and 

implementing the WAP at your facility and may need to be part of any personnel training 

program as required by 40 CFR 264/265.16. Employees who perform sampling activities 

should be properly trained with respect to the hazards associated with waste materials, as 

well as with any sampling and waste handling procedures that will assist in protecting the 

health and safety of the sampler.

In addition, employees should be trained in the proper protective clothing and equipment 

that is used when performing sampling activities. Examples of the safety procedures for 

which personnel at your facility may need to be trained, depending on-site-specific 

situations, include:

 Training in the common routes of exposure (inhalation, contact ingestion) that might be 

encountered when taking samples.

 Instruction in the proper use of safety equipment, such as Draeger tube air samplers to 

detect air contamination that employees potentially could be exposed to during sampling.

 Proper use of eye protection, impermeable gloves, protective clothing and footwear, 

and respiratory equipment to guard against exposure.

 Possible hazards associated with handling and sampling dangerous wastes such as 

radioactive, acute toxicity or pyrophoric waste.

You may want to consult the Occupational Safety and Health Act (OSHA), pursuant to 29 CFR 

1910.120, to determine the required training that may be given to your employees. 

Additionally, you may also want to consult the Occupational Safety and Health Guidance 

Manual for Hazardous Waste Site Activities (October 1985), which was developed through the 

joint efforts of OSHA, NIOSH, the U.S. Coast Guard, and EPA to address occupational safety 

and health issues specific to hazardous waste sites. It is optional whether you include these 

procedures in your WAP. The inclusion of health and safety procedures, however, enhances 

the use of the WAP as a hands-on, protective operating tool at your facility.

2.6 Selecting a Laboratory and Laboratory Analytical Methods

2.6.1 Selecting a Laboratory 

The use of proper analytical procedures is important 

in acquiring useful and accurate data. When selecting 

an analytical laboratory, you may want to consider if 

the laboratory has demonstrated experience in 

performing test methods for your particular waste 

types and is capable of providing documentation of its

proven analytical capabilities, available instrumentation, and standard operating procedures. 

40 CFR 264/265.13 do not require WAPs to 

address how laboratories will be selected. 

However, this manual recommends that 

the rationale for selecting a laboratory be 

addressed in the WAP.
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Furthermore, you may want to consider selecting a laboratory able to substantiate its data by 

systematically documenting the steps taken to obtain and validate the data. The following 

discussion provides guidance on the factors to be considered when selecting an analytical 

laboratory.

The analytical laboratory that demonstrates proficiency in the four major areas below is 

more likely to provide accurate data:

 Comprehensive QA/QC programs (both qualitative 

and quantitative).

 Technical analytical expertise.

 Effective information management systems.

 Third party accreditation. 

The relevant considerations that may be used to 

assess laboratory strengths in each of these areas 

are described in more detail below.

Comprehensive QA/QC Programs

Along with sampling activities, a QA/QC program is an integral part of laboratory analytical 

operations. Laboratory QA ensures that analytical methods generate data that are 

technically sound, statistically valid, and documented. Individual QC procedures are the 

tools employed to measure the degree to which these QA objectives are met. Accordingly, 

you may want to ensure that the laboratory addresses the following program elements.

Qualitative QA/QC Elements

A good laboratory generally will have a 

laboratory QA plan, sometimes called a quality 

systems or laboratory quality manual (LQM), 

which you can request and review. The LQM 

generally will detail the lab’s procedures for 

important QA elements such as the organizational 

structure and management policies, sample 

handling and tracking procedures, documentation 

procedures, internal audits, and proficiency 

testing. Table 2-7 Important QA Elements 

describes each QA element and what to look for 

when choosing a lab.

The laboratory will generally also be able to 

provide standard operating procedures (SOPs) 

Considerations for the Facility

 Some amount of off-site, independent 

laboratory analysis is important.

 Frequent use of laboratory analysis 

may be preferential instead of relying 

heavily on generator acceptable 

knowledge.

 Learn if your state program has a lab 

certification program and find a 

certified lab.

Some Key Considerations for the 

Facility

 Some amount of off-site independent 

laboratory analysis is important

 Frequent use of laboratory analysis is 

recommended instead of relying 

heavily on generator knowledge alone

 Learn if your state has a state lab 

certification program and find a 

certified lab

On-Site Facility Operated Labs

On-site testing capabilities can be important to 

confirm that the physical properties of received 

waste are the same as the waste profile. 

However, EPA strongly discourages facilities 

from performing anything beyond fingerprint 

analyses unless they have:

 Comprehensive QA/QC program.

 Technical analytical expertise.

 Effective information management 

systems.

Seeking third party accreditation may be a useful 

means of ensuring your chosen laboratory has an 

adequate QA/QC program.
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for any of the test methods that it performs. This includes having SOPs for SW-846 and/or 

ASTM methods.22 These methods contain only general information on how to perform an 

analytical procedure or technique. They do not detail the specific steps an analyst performs 

to carry out the procedure. Therefore, a laboratory generally provides this information by 

generating its own detailed SOP. The one exception to this is a test method for methoddefined parameters (MDPs). An MDP is a regulated parameter or property whereby a 

particular method is the only one that is capable of measuring the property (e.g., SW-846 

Method 1311, the Toxicity Characteristic Leaching Procedure). 

TABLE 2-7: Important QA Elements

What to look for...

Organizational structure 

and management 

The lab clearly defines the roles and responsibilities of all personnel. 

Sample handling and 

tracking procedures

The lab explains how samples and sample extracts are processed, identified, stored, 

and retrieved. This will help to ensure that lab personnel avoid mistaking one 

sample for another and analyze your samples within the holding time.

Documentation 

procedures

The lab has comprehensive documentation procedures for all phases of operation. 

Internal audits The laboratory performs internal audits on a regular basis. During an internal audit, 

the laboratory will rigorously assess whether it is attaining its objectives as stated in 

the LQM.

Proficiency testing The laboratory regularly participates in a proficiency-testing program. Proficiencytesting programs give a lab a chance to evaluate its analytical performance by 

testing unknown samples provided by a third party. The lab tests the samples and 

reports the results to the third party who then compares the lab’s results with the 

actual results (known only to the third party). The lab is then scored based on how 

it performs. 

Quantitative QA/QC Elements

Besides the qualitative measures (e.g., chain-of-custody procedures), quantitative 

measures may also be used by the laboratory to monitor QA/QC. These measures include 

analysis of method blanks, duplicates, matrix spikes, and surrogate spikes. Table 2-8 

Laboratory QC Techniques presents major QC techniques used by most laboratories to 

ensure data quality. A well-qualified laboratory will routinely employ these QA/QC 

procedures to evaluate precision and accuracy of its analytical instrumentation to assess if 

contamination has occurred, or if other factors exist which could affect data quality. 

 

22 See the ASTM web site at http://www.astm.org/.
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t

TABLE 2-8: Laboratory QC Techniques

QC technique Purpose Description Rate

Method Blank Ensure that any contamination 

resulting from analytical 

equipment or process is identified.

Method blanks are artificial samples, usually 

comprised of distilled deionized water that are 

submitted to the same laboratory preparation and 

analytical processes as your samples. If any 

contaminants are present in this artificial sample 

after preparation and analysis, it can be inferred 

that previous samples or laboratory practices 

caused erroneous or biased results.

Performed at least once each 

analytical batch with a minimum 

of once per 20 samples.

Duplicates

(Laboratory)

Evaluate the precision of the 

analytical process.

Two samples of the waste are obtained from one 

sample container and both are subjected to the 

same preparation and analysis.

Performed at least once with 

each analytical batch with a 

minimum of once per 20 samples.

Matrix Spike Evaluate the efficiency, accuracy, 

and precision, of the method being 

employed to analyze the samples.

Compounds of interest are “spiked” (added) into the 

samples prior to any preparation methods. The 

recoveries of the spiked compounds are then used 

to evaluate the efficiency of the method in detecting 

the compounds of interest.

Performed at least once with 

each analytical batch with a 

minimum of once per 20 samples.

Surrogates Spikes Evaluate the methods’ efficiency 

and accuracy.

Organic compounds which resemble the analytes of 

interest in chemical composition, extraction 

properties, and chromatographic properties. The 

recovery of the surrogate spike is used to indicate 

the effectiveness of the analytical process.

Performed at least once with 

each analytical batch with a 

minimum of once per 20 samples.

Laboratory Control 

Sample or Blank Spike

Evaluate the methods’ efficiency 

and accuracy.

A sample of known analyte composition and 

concentration that is used as a benchmark standard.

Performed at least once with 

each analytical batch with a 

minimum of once per 20 samples.
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Technical Analytical Expertise 

Laboratories may demonstrate technical analytical expertise by being proficient in using the 

established EPA analytical methods for hazardous waste determinations and possessing 

knowledge of any current developments in analytical methods that could affect data quality. 

To ensure that the required information regarding waste composition is provided, a good 

laboratory generally will have a working knowledge of the regulatory levels and prescribed 

analytical methods for routinely analyzed contaminants (e.g., TC constituents).

When selecting an analytical laboratory, you should consider its ability to achieve the 

lower limit of quantitation appropriate for your needs. Lower limits of quantitation may 

need to be compared to regulatory or permitting thresholds to ensure that the laboratory 

method(s) provide sufficient sensitivity (i.e., lower limits of quantitation are less than the 

regulatory levels). Laboratories that are equipped with only limited or outdated analytical 

instrumentation may be incapable of meeting analytical requirements of the regulations.

Information Management 

It is important for the laboratory to generally maintain effective information management 

systems. These systems ensure the availability of all relevant data generated in association 

with a given sample set (e.g., chain-of-custody records, accuracy and precision information, 

and analytical results). Additionally, the ability of a laboratory to produce clean and concise 

analytical reports may be advantageous and help you in maintaining sample documentation. 

A credible laboratory will generally work with you to tailor its reports to meet your specific 

requirements. This may be helpful to ensure that you use the information correctly to verify 

regulatory compliance or evaluate process performance. The laboratory may also be able to 

provide the information needed to prove data validation.

Third-Party Accreditation

Accreditation of environmental laboratories may be a useful indicator in determining if a 

lab is capable of providing accurate and defensible analytical data. The most common types 

of environmental laboratory accreditation programs include state programs and the 

National Environmental Laboratory Accreditation Program (NELAP). NELAP or a state 

governmental agency can accredit a laboratory if that state is a NELAP recognized 

Accreditation Body. Additionally, some states have their own laboratory certification 

programs independent of NELAP. When determining if a laboratory is qualified to perform 

the testing you need, in addition to the criteria above, it may also be useful to ask if they 

hold any accreditations. If so, you may inquire what type of accreditation they possess and 

if the accreditation applies to the methods that you want them to perform. If you are not 

familiar with the accreditation program, you may want to research the accreditation 

requirements to determine if the program is rigorous enough.
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2.6.2 Selecting Laboratory Analytical Methods 

To sustain regulatory and permit compliance, the 

WAP must specify testing and analytical methods. The 

selection of an appropriate methodology is dependent 

upon the following considerations to provide reliable 

data to ensure protective and effective waste management:

 Physical state of the sample (e.g., solid, liquid, or multi-phase).

 Analytes of interest (e.g., volatile organics, metals).

 Data Quality Objectives (e.g., needed lower limits of quantitation, 1/5 to 1/2 of the 

regulatory thresholds and precision and accuracy criteria).

 Information requirements (e.g., verify compliance with LDR treatment standards).

Analytical methods consist of two distinct phases -- a preparation phase and a determination 

phase and for some methods an intermediate step, sample cleanup. The use of an 

appropriate combination of preparation, cleanup, and determination procedures helps to 

ensure the accuracy of data generated from your facility’s waste management program. For 

further guidance on choosing the correct procedure, see Chapter 2 of SW-846.

Preparation Phase 

Preparation methods are selected based upon a consideration of the factors presented 

above and any special requirements associated with the type of analytical determination 

being performed. These procedures are designed primarily to accomplish one or more of 

the following:

 Extract the analytes of interest from the sample matrix.

 Adjust physical properties (e.g., pH).

 Facilitate chemical conversions necessary for analysis.

 Concentrate analytes to allow trace determinations.

Cleanup Phase 

Some samples intended for organics analysis that are either highly contaminated or contain 

extraneous contaminants that are capable of adversely affecting the analysis may require 

an additional procedure, known as a cleanup step, during sample preparation. These 

cleanup procedures remove potential interferences from the sample, thereby making it 

more amenable to subsequent analysis. The most common organic chemical cleanup 

procedures are florisil column, silica gel column, or gel permeation. The decision to 

perform a cleanup step usually is made by the analytical laboratory and often involves 

sophisticated technical judgments concerning sample composition, chemical interactions, 

and specific analytical limitations. If more information is required on the application of a 

particular cleanup method, the information can be obtained from SW-846.

40 CFR 264/265.13(b)(2) require that 

WAPs address test methods which will 

be used to test for selected parameters. 
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Determination Phase 

The application of a sample preparation method and, where required, a cleanup step, is 

accompanied by an appropriate determination procedure specific to the analytes of interest. 

Analytes are divided into classes (e.g., metals, volatile organic compounds), and for each 

analytical class, a standard method has been developed to identify and quantify them. For 

example, organic compounds are typically analyzed by gas chromatography (GC) or gas 

chromatography-mass spectrometry (GC-MS), while metals are analyzed by atomic

absorption spectroscopy (AA), inductively coupled plasma-atomic emission spectroscopy 

(ICP-AES), and inductively coupled plasma-mass spectroscopy (ICP-MS). Due to the number 

of available preparation and determination options, Figure 2-8 Analytical Methods Selection 

Flowchart is presented to facilitate the selection of the most appropriate preparation and 

analytical methods to use when performing waste testing. For both inorganic and organic 

determinations, this figure provides SW-846 methods that may be employed in the analysis 

of wastes for hazardous constituents (i.e., Part 261, Appendix VIII).

Once you have identified the determinative method(s) for the analytes you want to 

quantify, you may need to consider the sensitivity of the method. Analytical sensitivity is 

the smallest concentration of a substance that can be reliably measured by a given 

analytical method. Analytical sensitivities for the same method and analytes can vary 

greatly between laboratories and even between different instruments at the same lab with 

different operating conditions.

It is important to communicate your data 

needs to your laboratory before having them 

analyze your samples. The lab may be able to 

suggest an alternate method of analysis or 

may be able to make simple changes in the 

preparation of the sample to achieve the 

needed sensitivity. In particular, you may 

want to ask the lab what their lower limits of 

quantitation are for the methods and analytes 

you want them to analyze. For example, if you 

want to know if your sample contains 5 mg/L 

(ppm) lead and the lab can only detect to 10 

mg/L, the analysis is not sensitive enough to 

meet your needs. Also, since you rarely have 

complete confidence that your analytical data 

are perfect (e.g., due to the non-homogeneity of most wastes, etc.), the lower limits of 

quantitation may need to be well below the RCRA regulatory levels. Low limits are also 

helpful when determining the confidence level of your data and calculating re-evaluation 

frequencies for each wastestream (discussed in Sections 2.7 and 2.8, respectively). Lower 

limits of quantitation below the regulatory level may be required to ascertain waste 

variability and calculate a confidence level. 

The Lower Limit of Quantitation (LLOQ)

A common measure of laboratory analytical 

sensitivity is the lower limit of quantitation. 

The lower limit of quantitation is the lowest 

concentration at which the laboratory has 

demonstrated target analytes can be reliably 

measured and reported with a certain degree of 

confidence, which must be ≥ the lowest point in 

the calibration curve.

See Update V to SW-846 for additional 

information, especially Chapter 1. Note that 

some laboratories use terms other than LLOQ, 

such as reporting limit.

The Detection Limit

A common measure of laboratory 

analytical sensitivity is the detection 

limit. 

The detection limit is the lowest amount 

of an analyte that a particular laboratory 

can determine for a specific method and 

sample matrix
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FIGURE 2-8: Analytical Methods Selection Flowchart

*Sample refers to the actual waste or a leachate of the waste as required by TCLP (Method 1311). Note: Not all methods are needed for the TCLP, depending on the analytes of interest (e.g., chromium VI, 

PCBs, chlorinated hydrocarbons, etc).

**Note: Not all cleanups are applicable to all of the GC Analysis methods. Consult the SW-846 manual for guidance on applicable cleanup procedures for each analytical method and sample matrix.

The above figure is for illustrative purposes only and may not reflect all potentially applicable procedures. Please consult the SW-846 manual and project DQOs to determine the methods of 

preparation, cleanup and analysis. Note: The methods referenced above may contain subsets of analytes; please consult each method for a list of those analytes (e.g., Method 8310, Polynuclear 

Aromatic Hydrocarbons applies to a subset of 16 analytes, including Acenaphthene and Pyrene).

The methods referenced in the above figure are from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846). SW-846 methods are updated frequently. Please consult the 

current SW-846 online for any subsequent method updates or changes before selecting testing methods. Chapter 2, in particular, is devoted to choosing the correct procedure. 

http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/index.htm
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-58

2.7 Quantifying Data Uncertainty

As part of the waste analysis process, waste handlers

routinely use analytical data to make decisions and 

determine if the data are capable of supporting those

decisions. For example, suppose you analyze a waste for 

organic halogens to determine if it is a candidate for a 

particular waste management method that you have 

tentatively selected. In addition, suppose this method can 

be used only if the waste contains an organic halogen

concentration below 500 ppm. The decision you need to 

make is whether to manage the waste using this method and this is dependent on the 

organic halogen concentration. At first glance, it would make sense to use 500 ppm as your 

action level. An action level is simply a value that causes the decision maker to choose 

between different alternatives. That is, you would decide to use the management method if 

the organic halogen result is less than 500 ppm but would not if the result is 500 ppm or 

greater. The problem with this approach is that you rarely have complete confidence that 

your analytical data are correct due to the non-homogeneity of most wastes and slight 

differences in how you handle, sample, and analyze the waste. This creates a degree of 

uncertainty in what seems like a simple yes or no decision. Even when your analytical 

result is lower than an action level, the uncertainty may result in some possibility that the 

true concentration in the waste is actually higher than the action level, especially if the 

Data Reporting 

Owner/operators of TSDFs are required to keep records and results of waste analyses and waste 

determinations performed as specified. The facility may also want to maintain all information necessary to 

reconstruct the history of each sample so that the associated data may be understood through the 

documentation.

This information includes but is not limited to:

 All waste analytical results with the date of analysis, the lab sample ID, and corresponding manifest 

number clearly identified.

 All associated QC sample results.

 Waste sample tracking information, including internal tracking documentation for samples analyzed onsite and Chain-of-Custody documentation for waste samples sent off-site for analysis. 

In addition, for facilities conducting waste testing:

 All raw data for each analysis (e.g., instrument readings and printouts, sample preparation and cleanup 

protocols, sample weights, etc.).

 Calibration records to include calibration criteria and the frequency at which the calibration is performed.

 Standard operating procedures (SOPs) that accurately reflect current laboratory activities.

 All performance standard and QC sample results and acceptance criteria (e.g., calibration standards, 

blanks, reference samples, etc.).

 Instrument maintenance and repair records.

40 CFR 264/265.13 do not specify 

the method of quantifying data 

uncertainty as described in 

Section 2.7. However, facilities 

are encouraged to use methods 

for quantifying data uncertainty 

that result in an effective basis for 

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

PART TWO: Documenting and Conducting Waste Analysis 2-59

analytical result is nearing the action level. This will vary by situation and may need to be 

determined by considering the consequences of making a wrong decision (e.g., determine a 

waste is not hazardous when it is hazardous).

For example, suppose that, if the waste has elevated levels of organic halogens, the 

consequences could be extensive and include potential damage to the management unit, 

regulatory penalties for non-compliance, and adverse impacts on public health. Due to the 

significance of the consequences, you will likely want to minimize uncertainty that the true 

mean organic halogen concentration is greater than 500 ppm to justify a decision to use the 

management method even when the analytical results are less than 500 ppm. This may be 

accomplished by establishing a confidence level for the mean. A confidence level indicates 

the degree of certainty in the data in terms of a percent. For example, data meeting a 90% 

confidence level can be interpreted that it is 90% certain (10% uncertain) that the true 

organic halogen concentration is below 500 ppm. To apply a specific confidence level to 

your data, you need to determine confidence limits statistically. Confidence limits are the 

upper and lower limits that your data need to fall within to meet a specific confidence level. 

Since most action levels will be based on regulatory standards or permitted concentrations 

that must not be exceeded (or equaled), the upper confidence limit is calculated. If all 

analytical results are below, for example, an upper confidence limit of 90%, then you can say 

that you are 90% certain that the true concentration of organic halogens in the waste is 

below 500 ppm.

It is easier to demonstrate to regulators that your facility has made a good faith 

effort to characterize a waste, even if the characterization is found to be in error, if 

you have statistical estimates with a confidence level of 90% or above (less than a 

10% statistical probability of being wrong).

You can determine the 90% confidence limit if your data are normally distributed using the 

method presented here. If you do not have normally distributed results, you may still 

determine confidence limits for your data but you will need to use a different 

statistical method. See the example on the next page and consult the references below for 

additional information:

 Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous 

Waste Sites, OSWER 9285.6-10, U.S. Environmental Protection Agency, December 2002.

 RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation and 

Assessment, EPA 530-D-02-002, U.S. Environmental Protection Agency, Washington, 

D.C., August 2002.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-60

Calculating the 90% Upper Confidence Limit (UCL) On a Mean

Assume we received the following set of analytical data for the sample discussed above:

Organic Halogen Results

Composite Sample A: 410 ppm

Composite Sample B: 427 ppm

Composite Sample C: 424 ppm

Since the data are normally distributed*, the upper bound of the 90% confidence level may be calculated in the 

following manner:

STEP 1: Calculate the sample mean:

Where, A, B, and C are the individual sample results and n is the number of sample results.

Sample Mean = (A + B + C)/n 

Sample Mean = (410 + 427 + 424)/ 3 = 420

STEP 2: Compute the sample standard deviation*:

Standard Deviation = 9.07

STEP 3: Use the Critical Values of Student’s t Distribution table to look up the value of t*:

t Value = 1.886

STEP 4: Calculate the 90% Upper Confidence Limit**:

90% UCL = Sample Mean + (T Value × Standard Deviation/√n)

90% UCL = 420 + (1.886 × 9.07/√3) = 430

The upper bound 90% confidence limit of the analytical results (430 ppm) was below the action limit of 500 

ppm. The data sufficiently demonstrates that the waste is acceptable for the particular management method 

you have chosen.

Note(s):

*For simplicity in the example above, we have used sample results that are normally distributed and have not 

presented the full calculations for determining the standard deviation calculate or given an explanation of 

how to look up the “t” value using Critical Values of Student’s t Distribution table. If your sample results are 

not normally distributed, you may need to apply different statistical techniques. If you do not know how to 

calculate the standard deviation or use the t- table, please see the references listed at the end of the section 

for more information.

** Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous Waste Sites, OSWER 

9285.6-10, U.S. Environmental Protection Agency, December 2002.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-61

2.8 Determining Re-Evaluation Frequencies

The RCRA regulations require that waste analysis 

performed under 40 CFR 264/265.13(a)(1) be repeated 

as necessary to ensure that it is accurate and up to date. 

At a minimum, the analysis must be repeated as follows:

 When the owner or operator is notified, or has 

reason to believe, that the process or operation 

generating the hazardous wastes, or non-hazardous 

wastes if applicable under §§264/265.113(d), has 

changed [§§264/265.13(a)(3)(i)].

 For off-site facilities, when the results of the 

inspection required in §§264/265.13(a)(4) 

(fingerprint analyses) indicate that the hazardous 

waste received at the facility does not match the 

waste designated on the accompanying manifest or 

shipping paper [§§264/265.13(a)(3)(ii)]. 

In addition, an off-site facility must inspect and, if 

necessary, analyze each hazardous waste shipment 

received to determine if it matches the identity of the waste specified on the accompanying 

manifest or shipping paper [§§264/265.13(a)(4)].

Although the above regulations address the frequency 

of waste analysis, judgment is left to owner/operators 

to determine more exactly what the analytical frequency 

will be in certain instances. It is important for your

WAP to identify how you will determine re-evaluation

frequencies in cases where a frequency is not explicitly 

prescribed by regulation. In doing so, keep in mind 

that, in an enforcement case, regulators may request a 

demonstration that the facility is in compliance with 

specified requirements, and more frequent testing may 

be helpful in such cases. For example, regulators may 

ask a facility to demonstrate that it is not performing 

impermissible dilution under the Land Disposal Restrictions (LDR) program, as provided at 

§268.3. An effective demonstration could involve the submission of test data showing the 

concentration of regulated hazardous constituents in the untreated waste. Facilities should 

keep this in mind when considering a reduction in re-evaluation frequency under the LDR 

or other program and whether to test or use knowledge.

If you would like to enhance your ability to make changes to your waste re-evaluation 

frequency over time, you may want to prepare your WAP to enable a tiered approach for 

40 CFR 264/265.13 specify waste reevaluation frequencies in certain 

situations. In other situations, waste 

re-evaluation frequencies are left to 

owner/operator judgment. Section 

2.8 recommends an approach for 

determining re-evaluation 

frequencies when owner/operator 

judgment is needed. This may 

include the use of acceptable 

knowledge in certain situations, if 

allowed by the permit. For 

example, if a facility assumes its 

material exceeds applicable LDR 

treatment standards and performs 

treatment, there may be no need to 

test until after treatment. Of 

course, a permitted facility’s reevaluation frequency may be 

reduced only in accordance with 

conditions set forth in its permit.

LDR Dilution Prohibition

The LDR dilution prohibition at 

§268.3(a) forbids the dilution of 

wastes that do not meet applicable 

LDR treatment standards as a 

substitute for adequate treatment, 

such as the addition of soil or water 

to waste, in order to reduce the 

concentrations of hazardous 

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

PART TWO: Documenting and Conducting Waste Analysis 2-62

re-evaluation. That is, you may want to conduct a thorough initial characterization of each 

waste and then slowly reduce the frequency of re-evaluation with each subsequent 

shipment as long as the regulated hazardous constituents are protectively below the 

action level and their mean concentrations do not change significantly over time. For 

example, if a facility generates a new wastestream during its manufacturing process, it may 

be a good idea to analyze samples from multiple batches during initial characterization of 

the waste. This could result in a better sense of waste variability. This is important, as the 

waste handler may use the data from this initial shipment as a baseline to evaluate data 

from the subsequent shipments. There are also a number of ways to use historic waste data 

to determine re-evaluation frequencies. The method described in the paragraph below 

demonstrates one possible approach. You do not need to use this specific approach but it is 

important to state in your WAP how you will determine re-evaluation frequencies based on 

waste data.

A possible approach for determining re-evaluation frequency is to compare the average of 

the previous and current waste testing results and then base the re-evaluation frequency on 

the relative percent difference (RPD) of this value and the action level. This method 

necessitates that your facility keep accurate records so that previous data are accessible for 

comparison to current data. Ideally, you would have access to all data starting from the initial 

characterization to the present. You might evaluate the data in two ways. First, you might 

verify that none of the sample results exceed the action level. If the data do not exceed the 

action level in the initial characterization but do exceed the action level in the subsequent 

shipment, you may want to leave the re-evaluation frequency at 100%. Second, assuming the 

data did not exceed the action level, you could calculate the average of the previous results 

and calculate the RPD between this value and the action level. You could then determine the 

re-evaluation frequency based on a fixed schedule like the one used in the examples below 

and presented in Table 2-9 for wastes shipped or generated on-site at least monthly. 

The examples show how you may want to determine re-evaluation frequencies using historic 

data for an off-site shipment of a wastestream. Note that the examples apply when the goal 

is to evaluate general waste characteristics to assess changes in protective handling 

requirements or to monitor long-term average concentration of specific constituents (e.g., 

to demonstrate that the time-weighted annual average organic concentration remains 

below the 10 ppmw regulatory threshold for Subpart AA applicability). Because this 

method is not affected by data trends or the probability that short-term limits might be 

exceeded, it is rarely applicable to determining sampling frequencies when the resulting 

data are used to demonstrate continuous compliance with a feed rate threshold or limit. In 

those applications, sampling frequencies should be based on the likelihood that any one 

sample would exceed an applicable target. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-63

TABLE 2-9: Re-Evaluation Frequencies

If the average difference is: Then:

Within 10% of the action level (RPD ≤ 10%) Recharacterize each shipment

Between 10 and 25% of the action level (RPD >10% but ≤ 25%) Recharacterize quarterly

Between 25 and 50% of the action level (RPD > 25% but ≤ 50%) Recharacterize semi-annually

Greater than 50% of the action level (RPD > 50%) Recharacterize annually

Determine Re-Evaluation Frequencies Using Historic Data – Example A

Assume that you received the following data from the initial characterization and first re-evaluation of a waste 

containing toxaphene. Data from the initial characterization and subsequent shipment are provided below:

Initial Characterization Results (1st Shipment)

Batch Average (X1): 0.44 mg/L

Note: No single result exceeded the action level (L) for toxaphene of 0.50 mg/L.

Re-Evaluation Result (2nd Shipment)

Result (X2): 0.40 mg/L

Number of Shipments (n) = 2

Average of Shipments (A):

= (X1 + X2)/n

= (0.44 + 0.40)/2 = 0.42 mg/L

Relative Percent Difference (Shipment Average and Action Level):

= (L–A)/((L+A)/2) X 100 

= (0.50-0.42)/((0.50+0.42)/2) X 100 = (0.08/0.46) X 100 = 17.4%

Re-evaluate the waste quarterly since RPD = 17%

Once quarterly data is collected, recalculate the average using all three sets of data and determine the RPD 

between the new average and the action level.

Adjust the re-evaluation frequency as needed based on the new RPD.

Please note that it may be advisable to consult a statistician if you are uncertain as to the choice of an 

appropriate parameter, limit, etc., or have concerns with data variability.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-64

2.9 Special Procedural Requirements

2.9.1 Procedures for Receiving Wastes Generated Off-Site

An off-site facility’s WAP must specify the waste 

analyses that the generator of the waste will

provide to substantiate its waste determination 

[§§264/265.13(b)(5)]. It is important for the WAP 

to describe the procedures to be taken by the TSDF

during pre-acceptance to determine if the 

generator’s data accurately and fully represent the 

wastes to be managed. This can include describing 

Determine Re-Evaluation Frequencies Using Historical Data -Example B

Assume that you received the following data from the initial characterization and subsequent reevaluations of a waste containing arsenic. Data from the initial characterization and subsequent shipments 

are provided below:

Initial Characterization Results (1st Shipment)

Average of Batch Results (X1): 4.7 mg/L

Note: No single result was above the action level (L) of 5.0 mg/L

Re-Evaluation Result (2nd Shipment)

Result (X2): 4.8 mg/L

Re-Evaluation Result (3rd Shipment)

Result (X3): 4.3 mg/L

Number of Shipments (n) = 3

Average of Shipments (A):

= (X1 + X2 + X3)/n

= (4.7 + 4.8 + 4.3)/3 = 4.6 mg/L

Relative Percent Difference (Shipment Average and Action Level):

= (L–A)/((L+A)/2) X 100

= (5.0 – 4.6)/((5.0 + 4.6)/2) X 100 = (0.4/4.8) X 100 = 8%

Re-evaluate each shipment, as RPD is 8% 

Once data for the next shipment is collected, recalculate the average using all four sets of data and 

determine the RPD between the new average and the action level.

Adjust the re-evaluation frequency as needed based on the new RPD.

Please note that it may be advisable to consult a statistician if you are uncertain as to the choice of an 

appropriate parameter, limit, etc., or have concerns with data variability.

40 CFR 264/265.13(c) require WAPs to 

specify procedures which will be used to 

inspect and, if necessary, analyze each 

movement of hazardous waste received at

the facility to ensure that it matches the 

manifest. Sections 2.9.1 and 2.9.2 address 

some of these procedures, as specified.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-65

in the WAP what data will be compiled and how the facility will verify it (e.g., are there any 

discrepancies between the generator’s profile data and lab results performed on a sample 

of the waste?). 

It is also important for the WAP to identify the facility’s decision-making criteria for 

approving a candidate waste. Examples of decision-making criteria include: 

 Management methods available at the facility.

 Conditions or limitations of existing permit and regulations. 

 Capability to protectively and effectively manage the waste.

 Facility’s technical experience and judgment.

If a candidate waste is approved, the facility is required to inspect and, if necessary, analyze 

each incoming shipment (e.g., fingerprint tests) to ensure that it does not accept incorrectly 

identified or unacceptable wastes [§§264/265.13(a)(4)]. As discussed in Part One of this 

manual, two key objectives are to 1) ensure that the parameters being tested (e.g., pH) meet 

permit requirements and fall within acceptable limits for protective and effective treatment 

and management and 2) verify that the incoming shipment matches the manifest and is the 

same waste that was approved during pre-acceptance. In this regard, the shipment may need 

to be sampled and analyzed to the extent necessary to verify that it matches the manifest and 

profile. Some off-site facilities accomplish this by performing a systematic process of 

screening and analysis that allows for monitoring of key indicator parameters. In some 

cases, however, more stringent waste analysis may be required. Figure 2-9 Shipment 

Screening provides a methodology that can be used to screen waste shipments.

Shipment screening is especially important for off-site facilities given the variety of wastes 

typically managed. The level of screening that may be required for an off-site facility is a 

function of the facility operator’s knowledge about the generation process. Therefore, 

during pre-acceptance, it may be advantageous for off-site facilities to obtain from the 

generator detailed information regarding:

 The process that generates the waste.

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

 The analytical procedures and results used to characterize the waste or acceptable 

knowledge documentation.

 Certifications and notifications as applicable to LDR wastes.

 Other pertinent information about the waste.

An example of a waste profile sheet is provided in Figure 2-10 at the end of Part Two.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-66

Waste Shipment Arrives

Analyze Waste for Key 

Parameters and Compliance 

with Part 268 Treatment 

Standards, If Applicable

Evaluate Analytical Data

Sample Waste

Visually Inspect Shipment

Accept Waste Shipment

(TSDF is Ultimately 

Responsible for Accepting 

Waste)

Compare Shipment

Externally to Its Manifest

Discrepancy

Discrepancy

Contact Generator

Contact Generator

Recharacterize Waste 

(TSDF or Generator)

Evaluate Analytical Data

Reject Waste 

Shipment

FIGURE 2-9: Shipment Screening
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-67

Based on the facility’s screening, it may identify a discrepancy between an incoming 

shipment and its manifest or waste profile. For example, a waste’s profile sheet might 

indicate that it has a pH range of 2 to 5, but the screening results might indicate the 

incoming shipment has a pH of 8. In such a case, it is important for the facility to take 

further action to resolve the discrepancy. This could include possibly a comprehensive 

recharacterization of the waste before acceptance and, if necessary, preparing a new waste 

profile (i.e., if the facility determines it is a new or different wastestream). Or, it could 

include rejecting the waste if the facility determines it cannot be accepted on-site (e.g., the 

waste is restricted from acceptance in the permit).

Sections 264/265.13(a)(3)(i) and (ii) identify situations when recharacterization is 

necessary at a minimum (e.g., when the results of the inspection indicate that the 

hazardous waste received at the facility does not match the waste designated on the 

accompanying manifest or shipping paper). The procedures for reviewing and 

recharacterizing waste must be specified in the WAP [§§264/265.13(b)(4)]. Facilities are 

encouraged to specify any additional criteria that would trigger recharacterization and the 

follow-up procedures for resolving problems found. 

2.9.2 Procedures for Combustion Facilities

As discussed in Section 2.4.4 of this manual, hazardous waste incinerators, cement kilns, 

lightweight aggregate kilns, boilers, and hydrochloric acid production furnaces are RCRA 

TSDFs that are also subject to the CAA NESHAP program. A RCRA WAP continues to be a 

required component of the RCRA permit for these HWCs; however, the combustor-specific 

feedstream analysis requirements that ensure compliance with the CAA HWC NESHAP 

emission standards and (feedstream related) operating requirements are found in the 

feedstream analysis plan (FAP) and now reside in the CAA HWC NESHAP (40 CFR Part 63 

Subpart EEE). There may be limited cases where a RCRA WAP continues to contain 

combustor-specific feedstream analysis requirements,23 but for many HWCs, the RCRA 

WAP and the CAA HWC NESHAP FAP (or CAA FAP) are maintained as separate documents 

in separate programs. This does not imply however, that the two documents are exclusive 

of one another. 

Specific to HWCs, the RCRA WAP serves to, among other things, identify the incoming 

waste and screen out wastes that the RCRA permit prohibits (e.g. metal-bearing wastes 

prohibited from dilution per Appendix XI to Part 268, radioactive wastes, 

reactive/explosive wastes, etc.) from going to the combustion unit. 24 The CAA FAP focuses 

on the waste before being fed to the combustor to ensure that the feedstream is adequately 

 

23 A RCRA WAP may retain some of the combustor-specific feedstream analysis requirements where: (1) pursuant 

to RCRA omnibus authority, the RCRA permit writer required emission and (emission related) operating 

requirements that are more stringent than the CAA MACT requirements (such as a limitation on mercury emissions 

and feedrate); or (2) a HWC elects to comply with one of the RCRA options in 40 CFR 270.235 for startup, 

shutdown, and malfunction; or (3) area source boilers and HCl production furnaces elect to comply with certain 

RCRA emission standards in lieu of the full suite of MACT standards.

24 For HWCs that are not subject to the CAA NESHAP, the RCRA WAP serves the same purpose, but also usually requires 

additional waste analysis and feedrate monitoring as necessary to ensure compliance with RCRA permit limits.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-68

characterized and the concentration of feedrate-limited pollutants (e.g., chlorine) in the 

feedstream are known. Thus, the CAA FAP can be thought of as a subset of the RCRA WAP, 

since the incoming waste affects what is ultimately combusted. The key point is that the 

RCRA WAP and the CAA FAP should complement one another to ensure protective

handling of the waste and the efficient operation of the HWC. 

State and EPA Regional offices vary in organizational structure and program responsibility 

for implementing the CAA HWC NESHAP. The potential for regulatory overlap, or even a gap, 

for HWCs exists due, in part, to applicable requirements under both RCRA and the CAA. This 

can be especially true for the RCRA WAP and CAA FAP requirements. It is important to 

emphasize that, in most cases, it is not appropriate for the RCRA WAP to simply reference the 

CAA FAP requirements, and not include details in its RCRA WAP regarding the waste analysis 

requirements used to ensure compliance with the RCRA requirements or for the CAA FAP to 

simply reference the RCRA WAP requirements and not include details in its CAA FAP about 

feedstream analysis requirements used to ensure compliance with the CAA requirements. 

Each program has its own set of regulatory requirements for waste analysis that are 

applicable to HWCs. In some cases, a permit authority and HWC may agree to combine the 

RCRA WAP and the CAA FAP requirements into one document. This may be preferred when, 

for example, the RCRA program has retained authority for reviewing and determining 

compliance with the CAA HWC NESHAP. Regardless of the approach taken, it is encouraged 

for permit officials from both programs, along with their HWC facilities, to work together to 

coordinate the RCRA WAP and CAA FAP requirements. (See the discussion of hazardous 

waste combustors in Appendix D of this manual for a crosswalk table which highlights the 

similarities between the RCRA WAP and CAA FAP and identifies sections of this manual 

that may be of assistance in developing a CAA FAP.) 

With respect to the CAA FAP, the regulatory requirements are at §63.1209(c). This section 

currently states: 

(c) Analysis of feedstreams—(1) General. Prior to feeding the material, you must obtain an analysis of 

each feedstream that is sufficient to document compliance with the applicable feedrate limits 

provided by this section.

(2) Feedstream analysis plan. You must develop and implement a feedstream analysis plan and record 

it in the operating record. The plan must specify at a minimum:

(i) The parameters for which you will analyze each feedstream to ensure compliance with the 

operating parameter limits of this section;

(ii) Whether you will obtain the analysis by performing sampling and analysis or by other methods, 

such as using analytical information obtained from others or using other published or documented 

data or information;

(iii) How you will use the analysis to document compliance with applicable feedrate limits (e.g., if you 

blend hazardous wastes and obtain analyses of the wastes prior to blending but not of the blended, 

as-fired, waste, the plan must describe how you will determine the pertinent parameters of the 

blended waste);

(iv) The test methods which you will use to obtain the analyses;

(v) The sampling method which you will use to obtain a representative sample of each feedstream to 

be analyzed using sampling methods described in appendix IX, Part 266 of this chapter, or an 

equivalent method; and 

(vi) The frequency with which you will review or repeat the initial analysis of the feedstream to 

ensure that the analysis is accurate and up to date.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-69

(3) Review and approval of analysis plan. You must submit the feedstream analysis plan to the 

Administrator for review and approval, if requested.

(4) Compliance with feedrate limits. To comply with the applicable feedrate limits of this section, you 

must monitor and record feedrates as follows:

(i) Determine and record the value of the parameter for each feedstream by sampling and analysis or 

other method;

(ii) Determine and record the mass or volume flowrate of each feedstream by a CMS. If you 

determine flowrate of a feedstream by volume, you must determine and record the density of the 

feedstream by sampling and analysis (unless you report the constituent concentration in units of 

weight per unit volume (e.g., mg/l)); and

(iii) Calculate and record the mass feedrate of the parameter per unit time.

(5) Waiver of monitoring of constituents in certain feedstreams. You are not required to monitor levels 

of metals or chlorine in the following feedstreams to document compliance with the feedrate limits 

under this section provided that you document in the comprehensive performance test plan the 

expected levels of the constituent in the feedstream and account for those assumed feedrate levels in 

documenting compliance with feedrate limits: natural gas, process air, and feedstreams from vapor 

recovery systems.

To summarize, feedstream sampling and analysis protocols (e.g., sampling frequency, sample 

size, sample analytical procedure and analytical constituents) that are used to comply with 

applicable feedrate limits must be outlined in detail in the HWC’s CAA FAP and recorded in 

the operating record.25 These characterization protocols are site-specific and waste-specific.

Despite the fact that the regulatory requirements for sampling and analysis of the 

combustion unit feedstream are primarily under the CAA HWC NESHAP, many of the 

concepts in this manual can be useful and applied as needed to both the RCRA WAP and 

CAA FAP for a HWC. One example is sampling frequency. The regulatory requirement 

under the CAA HWC NESHAP at §63.1209(c)(2)(vi) is nearly identical to the requirement 

under RCRA at §264.13. Therefore, the regulated community and permit officials may wish 

to review the discussion in this manual to assist in determining how often a HWC 

feedstream should be sampled and analyzed. 26

Determination of feedstream sampling frequency may depend on considerations such as: 

(1) trends in historical waste data; (2) confidence and extent of knowledge of process; (3) 

potential for changes in waste composition; (4) expected hazardous air pollutant (HAP) 

levels in the feedstream; and so forth. Periodic sampling is required for all feedstreams 

to ensure the analysis is accurate and up to date, however, the actual frequency will 

be site-specific.

Characterization of wastestreams based on process knowledge may be permitted on a sitespecific basis when it can be demonstrated that knowledge is sufficiently accurate to ensure: 

(1) the waste can be protectively handled at the treatment facility; and (2) the treatment 

 

25 Again, it may be possible to combine both RCRA WAP and CAA FAP requirements into one document. However, 

the FAP requirements must be recorded in the HWC’s operating record.

26 The Draft 1994 Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, although never finalized, 

contains information related to combustor constituent feedstreams and the associated sampling and analysis 

strategies (e.g., batch, qualification, and statistical) for determining compliance that readers may still find useful. 

(EPA 530-R-94-019, October 1994). 
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PART TWO: Documenting and Conducting Waste Analysis 2-70

facility is complying with its applicable feedrate and emission limitations.27 Only in rare 

instances, such as those discussed in the next paragraph, would the use of process knowledge 

be an acceptable substitute for actual sampling and analyses in the initial characterization of 

HWC feedstreams. However, process knowledge may often be used to reduce the number of 

constituents analyzed in subsequent characterizations if the initial characterization 

demonstrates that the constituent is not reasonably expected to be present at a level that 

could affect compliance with feedrate or emission limitations.

In cases where it is dangerous, impractical, or unnecessary to use direct sampling and 

analysis, characterization (initial and subsequent) of the feedstream based on process 

knowledge should be used to the fullest extent possible. Materials that are considered 

dangerous can pose extraordinary health, safety or environmental hazards. Examples of 

dangerous materials can include those that are extremely toxic or reactive, sharps, and 

biological wastes. It can also be impractical and/or unnecessary to directly sample, or 

obtain a representative sample of the waste because of the physical nature of the waste, or 

because the composition of the wastes are known. Examples of materials for which 

sampling can be impractical (or unnecessary) include lab packs and lab wastes, “RCRA” 

empty used containers, cylinders, aerosols, household hazardous wastes, mixed 

pharmaceuticals, and unused commercial products/chemicals. 

As discussed earlier in this manual (Section 2.4 Selecting Waste Analysis Parameters), the 

selection of parameters is important in determining what can be protectively managed 

while maintaining regulatory and permit compliance. Specific to HWCs, the selection of 

parameters to be analyzed in the combustor feedstream will vary according to the type of 

HWC, alternate mode(s) of operation, and the wastes received. Parameters for HWCs can 

include ash content, total chlorine, mercury, total metals (combination of semi-volatile and 

low-volatile metals), heat of combustion, and total halogen. A typical feedstream analysis 

scenario may include a prequalification analysis (prior to processing), a fuel blending 

analysis (to inform fuel blending decisions), and batch analysis (representative samples of 

blended waste for each burn tank or batch).

The sampling frequency and selection of parameters for analysis discussions are two examples in 

which this manual can be of assistance to permit officials from both the RCRA and CAA 

programs, as well as the regulated community, when developing a HWC RCRA WAP and CAA 

FAP. Again, readers may refer to Appendix D for a crosswalk table illustrating the similarities 

between the RCRA WAP and CAA FAP requirements.

 

27 Process/acceptable knowledge can encompass a variety of sources such as analytical information, product label 

information, safety data sheets, and manufacturer information.
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PART TWO: Documenting and Conducting Waste Analysis 2-71

2.9.3 Procedures for Ignitable, Reactive, and Incompatible Waste

WAPs for all facilities must include provisions to ensure 

that waste management units meet the special 

requirements for ignitable, reactive, and incompatible 

wastes at 40 CFR 264/265.17. Incompatible wastes, if 

brought together, may result in heat generation, toxic gas 

generation, and/or explosions. Therefore, a WAP must 

address measures to identify potentially ignitable, 

reactive, and incompatible wastes. The information 

provided by the waste manifest and fingerprint testing can be supplemented with other 

testing to identify incompatible wastes. Standard tests to identify ignitable, corrosive, and 

toxic wastes are contained in Chapter 8 of SW-846. You should identify reactive wastes if 

they exhibit at least one of the eight properties identified in §261.23. As EPA does not 

currently have a set of approved methods for determining reactivity, generators will need 

to use acceptable knowledge to determine if their waste exhibits the characteristic of 

reactivity. Finally, waste compatibility determinations can serve to establish compatibility 

between wastes of interest for a given process. The EPA document, A Method for

Determining the Compatibility of Hazardous Wastes (EPA-600/2-80-076), contains 

procedures to evaluate qualitatively the compatibility of various categories of wastes.

2.9.4 Procedures for Complying with LDR Requirements

Generators and TSDFs have special waste analysis 

requirements under the LDR program. 40 CFR 268.7 

requires generators and TSDFs to conduct waste analysis 

to determine the regulatory status of wastes with respect 

to the treatment standards in Part 268, Subpart D. 

Generally, hazardous wastes must meet applicable 

treatment standards prior to land disposal. These 

treatment standards are expressed in two ways: as regulated hazardous constituent 

concentrations in the waste (either an extract of the waste as determined by the TCLP or in 

the total volume of the waste referred to as a total waste analysis) or as specified treatment 

technologies. Wastes with concentration-based treatment standards must be evaluated to 

determine if applicable constituent concentration levels have been attained. This can be 

accomplished by either (1) testing the waste or (2) using knowledge of the process or 

materials used to produce the waste (for generators only). It is important for acceptable 

knowledge to be supplemented with analytical data on the regulated hazardous constituents.

For treatment standards expressed as concentrations in the waste extract [§268.40], the 

TCLP (EPA SW-846 Method 1311) must be employed, except as noted in the rules, to obtain 

an extract of the waste. (There are certain exceptions where Method 1310, the Extraction 

Procedure Toxicity Test, can be used as an alternative for certain arsenic- and leadcontaining waste codes listed in §268.40(a).) The extract will then be tested subsequently 

for the specific hazardous constituents associated with the treatment standard. Treatment 

40 CFR 264/265.13(b)(6) require 

WAPs, where applicable, to specify 

the methods that will be used to 

meet the waste analysis 

requirements for ignitable, reactive, 

and incompatible waste at 

§§264/265.17.

40 CFR 264/265.13(b)(6) require 

WAPs, where applicable, to specify 

the methods that will be used to 

meet the waste analysis 

requirements for the LDR program 

at §268.7.
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PART TWO: Documenting and Conducting Waste Analysis 2-72

standards based on total waste concentrations in §268.40 should use an appropriate total 

waste analysis procedure for its respective hazardous constituents. Please note that many 

wastes have treatment standards expressed as both extract concentrations and total waste 

concentrations depending on their form, i.e., wastewater or nonwastewater.

For wastes with treatment standards expressed as specified technologies in §268.42, and 

for hazardous debris treated to meet the alternative debris treatment standards in §268.45, 

verification through analysis is not necessary. Instead, compliance with these treatment 

standards should be documented in the facility operating record to verify that the 

appropriate treatment technologies have been employed prior to land disposal.

As previously discussed, compliance with LDR treatment standards that are defined as 

concentration-based standards is based on a single grab sample for D004-D011 

wastewaters and for all nonwastewaters (see §268.40(b)). For purposes of LDR

compliance, a grab sample is a one-time sample taken from any part of the treated waste 

prior to land disposal. Using grab sampling to measure compliance with the treatment 

standards ensures conformity with the LDR program goals such that all of the hazardous 

waste to be land disposed is treated to minimize the threats to human health and the 

environment. (See the LDR Phase IV Second Supplemental Proposed Rule (Federal Register 

62:91 (12 May 1997) pps. 26041 and 26047).) If a single grab sample fails to show 

compliance with the LDR standard, then the treated waste must be re-treated before it can 

be land disposed as defined in §268.2. Retreatment compliance is also based on a single 

grab sample. If, for any reason, multiple grab samples are taken, all samples must meet the 

LDR treatment standards to be LDR compliant. 

EPA established treatment standards for prohibited wastes based on grab sampling for two 

principal reasons. (See the LDR Second Third Final Rule (Federal Register 54:120 (23 June 

1989) pps. 26594 and 26605).) The first is that it is normally easier and more expeditious 

for EPA to enforce on the basis of grab samples. Basing compliance on a single grab sample 

allows the enforcement personnel to take a grab sample as an explicitly required method 

for determining compliance, rather than having to replicate a sampling program designed 

by the TSDF that could require the regulatory agency to make multiple trips to the facility. 

Second, grab samples as used for LDR compliance normally reflect maximum process 

variability and thus reasonably characterize the ranges of treatment system performance. 

In choosing the 95th or 99th percentile as the compliance value (i.e., LDR treatment 

standard) from a treatability study data distribution, EPA has ensured a high statistical 

probability that the entire batch of treated waste, irrespective of the concentrations of the 

hazardous constituents, will be at or below the calculated treatment standard when the 

standard is met by a randomly collected sample. Hence, the treatment standard represents 

a level of treatment that is believed to be achievable between 95% and 99% of the time by 

a well-designed, well-operated treatment system. If the treatment standard is exceeded, 

then clearly some fraction of the waste is non-compliant. All current numerical LDR 

treatment standards are based on such an analysis of the treatability study data underlying 

the compliance value, and since the compliance values are based on a single grab sample 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-73

per batch or treatment event, grab sampling is the most appropriate sampling method for 

determining LDR compliance.

Further, in 1994, EPA issued the universal treatment standards (UTS) to simplify and 

provide consistency in the LDR requirements, establishing a single set of requirements that 

applied to most hazardous wastes. (See the LDR Phase II Final Rule (Federal Register 

59:180 (19 September 1994) p. 47892).) Prior to this rulemaking, facilities managing 

hazardous waste were required to meet the LDR treatment standards established for many 

different listed and characteristic hazardous waste before the waste was land disposed. In 

some cases, a constituent regulated under the treatment standard for one waste was also 

regulated in another waste to a different level. The Phase II rule eliminated these 

differences and provided a better assessment of treatability, reduced confusion and eased 

compliance enforcement. Consequently, the establishment of one treatment standard for 

each hazardous constituent resulted in a significant number of numerical treatment 

standards increasing to a higher standard. This increase from the original treatment 

standard (pre-UTS) could be seen as further increasing the likelihood that a single grab 

sample would meet the specified treatment standard if the unit was well-designed and 

well-operated.

By contrast, composite sampling, which is a combination of samples collected at various 

locations or times for a given waste, may result in only an average portion of the waste 

being treated. (See the LDR Phase IV Second Supplemental Proposed Rule (Federal 

Register 62:91 (12 May 1997) pps. 26041 and 26047).) If the Agency had intended for 

compliance to be based on composite sampling, or some other averaging method, the mean 

(or median) value of the underlying treatability data distribution would have been used as 

the compliance value. However, a mean or median value would be substantially lower than 

a value taken from the 90th or 95th percentile of the data set.

A facility’s waste analysis plan will need to provide the basis for the facility’s compliance 

monitoring. This plan must be adequate to assure compliance with Part 268 and not allow 

hazardous waste management practices that are clearly in violation of LDR requirements.28 

A facility remains strictly liable for meeting the treatment standards, so that if the facility 

disposes of a waste that does not meet a specified treatment standard, it is in violation of 

the LDR regulations. A waste analysis plan cannot immunize land disposal of prohibited 

wastes, although such plans can be written to authorize types of sampling and monitoring 

different from those used to develop or verify that land disposal can occur. 

As such, a facility may choose to employ alternative sampling protocols. If a waste analysis 

designated a different mode of sampling or monitoring, there would need to be a 

demonstration that the plan (and the specific deviating feature) is adequate to assure 

compliance with Part 268. EPA has stated, however, that enforcement of the rule is based 

 

28 See, for example, the Land Disposal Restriction (LDR) Requirements Memorandum from Barnes Johnson, 

Director, Office of Resource Conservation and Recovery, U.S. Environmental Protection Agency (RCRA Online No. 

14843), dated April 11, 2014.
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PART TWO: Documenting and Conducting Waste Analysis 2-74

on the treatment standard, not the facility’s waste analysis plan, so the enforcement 

officials would normally take a single grab sample and analyze for all constituents 

regulated by the applicable treatment standards. See Section 2.5.1 Sampling Strategies and 

Sampling Frequencies and Section 2.8 Determining Re-Evaluation Frequencies for relevant

information.

2.10 Discrepancy Policy

Two types of discrepancies can arise during waste acceptance: 1) manifest discrepancies and 

2) discrepancies between the incoming waste shipment and its profile. Therefore, it is 

recommended for a facility receiving off-site shipments to state its discrepancy policy and 

include detailed procedures in the WAP for handling both types of discrepancies promptly 

and effectively. Discrepancies generally indicate 

that an error has occurred in analyzing and/or 

describing the waste and that corrective and 

preventative action measures may be needed to 

prevent its re-occurrence. Facility personnel may 

also need to decide whether to accept or reject the 

waste. Because of this, it is advisable for the 

facility’s discrepancy policy to be coordinated with 

its rejection policy discussed in Section 2.11.

2.10.1 Manifest Discrepancies

40 CFR 264/265.72 define manifest discrepancies as:

 Significant differences between the quantity or type of hazardous waste designated on 

the manifest or shipping paper, and the quantity and type of hazardous waste a facility 

actually receives. Significant differences in quantity are, for bulk waste, variations 

greater than 10 percent in weight, for batch waste, any variation in piece count, such as 

a discrepancy of one drum in a truckload. Significant differences in type are obvious 

differences, which can be discovered by inspection or waste analysis, such as waste 

solvent, substituted for waste acid, or toxic constituents not reported on the manifest or 

shipping paper.

 Rejected wastes, which may be a full or partial shipment of hazardous waste that the 

TSDF cannot accept.

 Container residues, which are residues that exceed the quantity limits for “empty” 

containers set forth in §261.7(b).

The facility’s policies should be consistent with the requirements of §§264/265.72, as 

applicable. For example, upon discovering a significant difference in quantity or type, the 

facility must attempt to reconcile the discrepancy with the waste generator or transporter 

(e.g., with telephone conversations). If the discrepancy is not resolved within 15 days after 

40 CFR 264/265.13 do not require WAPs to 

include discrepancy policies or procedures. 

However, this manual recommends that 

such policies and procedures be 

established and described in the WAP since 

not addressing them could lead to safety 

issues and noncompliance with permit 

requirements for waste acceptance.
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PART TWO: Documenting and Conducting Waste Analysis 2-75

receiving the waste, the facility must immediately submit to EPA or the authorized state a 

letter describing the discrepancy and attempts to reconcile it, and a copy of the manifest or 

shipping paper at issue.

The facility needs to decide if the waste can be accepted despite the discrepancy. This 

involves a determination whether the facility can manage the waste on-site in a manner 

that is protective, effective and in accordance with the provisions of its permit. If the waste 

cannot be accepted, the facility may need to reject it in accordance with its rejection policy. 

In addition, the facility may need to evaluate whether the manifest discrepancy reflects a 

deeper issue than simply a clerical error (e.g., has the generator’s waste changed since preacceptance?). If a deeper problem is suspected, the facility may need to re-evaluate the 

waste profile to determine if a new or revised profile is necessary. This could involve 

sending the waste profile to the generator for re-evaluation and re-certification. For these 

deeper issues, the generator may need to prepare a corrective action plan describing the 

issue and how it will be prevented in the future. 

2.10.2 Discrepancies Between Incoming Waste and Profile

As discussed elsewhere in this manual (e.g., Section 

1.2), it is recommended that the facility closely 

compare each incoming waste to its waste profile to 

ensure it is receiving the waste that had originally 

been approved during pre-acceptance. It is common 

for a generator’s commercial processes to change, 

thereby resulting in a new or modified wastestream. 

New wastes, as well as modified wastestreams that 

no longer meet the waste profile, may need to be 

subject to pre-acceptance, so that the facility can 

consider whether it can manage the waste 

protectively and effectively. 

During acceptance, facility personnel may need to perform visual inspections of opened 

containers (e.g., to confirm basic physical properties, such as color and waste form) and 

chemical screenings as necessary to determine if new and/or modified wastes have been 

shipped to their facility. The chemical screenings may need to include one or more 

parameters with a tolerance limit (e.g., pH limits). A discrepancy occurs if the waste falls 

outside the range or otherwise does not match other aspects of its profile. 

The facility’s policy on discrepancies may also need to detail the facility’s actions for 

addressing it. For example, the facility may need to attempt to resolve the discrepancy by 

calling the generator and requesting additional information. The facility will need to decide 

whether to accept or reject the waste despite the discrepancy. This involves a 

determination whether the facility can manage the waste on-site in a manner that is 

protective, effective and in accordance with the provisions of its permit. The policy may 

also need to indicate how long the waste will be kept on-site pending a decision (unlike 

Some Consideration for the Facility

It is recommended that the facility 

perform a “discrepancy review”

whenever the waste acceptance testing 

shows an unacceptably high variance 

(trigger level to be negotiated with the 

permit agency) from the waste profile 

data (e.g., for Btu value, require a 

discrepancy review if the Btu value varies 

more than 15%).

Some Key Consideration for the 

Facility

The facility should perform a 

“discrepancy review” whenever

the waste acceptance testing shows 

an unacceptably high variance

(trigger level to be negotiated with 

the permit agency) from the waste 

profile data (e.g., for Btu value, 

require a discrepancy review if the 

Btu value varies more than 15%).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-76

manifest discrepancies, the federal regulations do not specify a time limit for discrepancies 

related to waste profiles).

If a decision is made to reject the waste, the facility would then follow the procedures of 

its rejection policy. If the waste is not rejected and the discrepancy cannot be resolved, 

the facility may want to perform a comprehensive analysis of the waste. The results will 

help to determine if it is a new or modified waste. If it is newly generated or modified, a 

new or revised waste profile may be needed. In all cases, the generator may need to be 

asked to submit a corrective action plan that describes the reason for the discrepancy 

and actions to be taken to prevent re-occurrence. 

2.11 Rejection Policy

It is recommended that a facility receiving off-site 

shipments to have a rejection policy that is closely 

coordinated with its discrepancy policy because 

some discrepancies may lead to rejection. The 

policy would ensure that all applicable federal and 

state requirements for rejections (e.g., §264.72) are 

followed. For example, the policy could specify that 

the facility will obtain or confirm the generator’s 

directions on where to forward the rejected waste 

or residue (i.e., either back to the generator or to an alternative TSDF). While the shipment is 

waiting to be returned or sent to another TSDF, the facility would ensure that it is properly 

stored in a secure manner. This would include, for example, storing the waste in a fenced 

area with drainage and protection from weather. The facility must send the rejected waste or 

residue off-site within 60 days (as required for manifest discrepancies). The facility must 

ensure that the rejected load or residue is re-manifested in accordance with applicable 

manifest provisions.

2.12 Recordkeeping

Recordkeeping is an essential aspect of waste 

analysis, as it documents whether the analyses 

were done in accordance with required and 

acceptable procedures. In addition, the analytical 

results can be used to determine compliance with 

federal and state requirements (e.g., LDR 

treatment, if applicable) as well as ensure 

protective and effective management of the waste. 

Therefore, it is recommended that the facility develop a well-organized system for 

recordkeeping that provides the easiest, most straightforward way for addressing these 

objectives.

40 CFR 264/265.13 do not require WAPs to 

include rejection policies or procedures. 

However, this manual recommends that 

such policies and procedures be 

established and described in the WAP since 

not having a policy in place may lead to 

potential safety issues.

40 CFR 264/265.13 do not require WAPs to 

address recordkeeping. However, this 

manual recommends that recordkeeping 

related to waste analyses and evaluations 

be addressed in the WAP because it may 

help to determine compliance with 

regulatory or permit requirements.
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PART TWO: Documenting and Conducting Waste Analysis 2-77

Because of the volume and frequency of waste receipts, it may be advisable for a TSDF

receiving off-site shipments to maintain an electronic system for keeping track of 

generators, wastes, and analytical data. This system can address both the facility’s 

business needs and regulatory obligations for record retention. Systems commonly used 

by TSDFs include a database of customers and shipping partners, basic account 

information, and information on their wastes (e.g., profile data). Such information can 

assist the facility in arranging for shipments and tracking shipments (e.g., using bar 

codes, manifest tracking numbers, etc.) to and from the facility. The database can

maintain information on a range of parameters of relevance to the waste analysis process 

(e.g., quantity/types of hazardous wastes of each generator). It may also be helpful to 

have systems to track each shipment from receipt at the facility through its ultimate 

disposition or re-shipment off-site. Examples of information include:

 Basics of shipments received (e.g., 

time/date, quantity, waste type, 

customer).

 Any significant manifest or other 

discrepancies and other problems 

noted at receipt (e.g., a rejection).

 Management method used on-site for 

each waste (e.g., stabilization, etc.).

 Other waste-specific information related 

to its disposition (e.g., if it was sent offsite for further treatment).

 Summary-level results of waste 

analyses performed on-site (e.g., 

frequency at which waste treated at 

your site passed and failed tests during 

the year and the steps taken to address 

failed tests).

 Information on other problems and 

issues that occur before or after waste 

acceptance (e.g., summary-level data on 

the frequency of discrepancies between 

incoming shipments and their waste 

profiles and how they were resolved).

In addition, the regulations give very wide latitude for maintaining information in your 

operating record. For example, §264.73 states that a facility operating record must include 

records and results of waste analyses and waste determinations performed as specified in 

§§264.13, 264.17, 264.314, 264.341, 264.1034, 264.1063, 264.1083, 268.4(a), and 268.7. 

Features of an Effective Recordkeeping System

A facility’s records are one of the most important 

tools for regulatory inspectors to evaluate 

compliance and for facilities to demonstrate 

compliance. 

It is recommended that a facility’s recordkeeping 

system (including electronic system) be designed to 

provide inspectors with the desired, timely, and 

accurate/complete information. Important system 

features include: 

 Ability to produce summary-level reports on 

compliance and implementation problems 

encountered during the period (e.g., frequency of 

and reason for occurrence), including statistical 

analyses.

 Ease in tracking compliance and implementation

problems to their cause (e.g., a specific waste 

shipment or an inadequate stabilization recipe)

and tracking samples through acceptance.

 Ability to demonstrate that the facility resolved 

problems that were encountered during the 

period.

 Ability to demonstrate that the facility performed 

its analyses consistently and in accordance with 

the WAP (e.g., use of internal checklists and 

audits).
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PART TWO: Documenting and Conducting Waste Analysis 2-78

Because it is broadly written, there are few if any constraints in the type or amount of 

information that you may be asked to retain under this requirement. 

In this regard, you may want to retain records of all analyses required under your WAP. 

This includes, for example, analyses during pre-acceptance, acceptance (e.g., inspections 

and fingerprint analyses), and analyses of on-site management (e.g., residuals from on-site 

treatment or storage). This includes records of analyses that both your on-site facility 

personnel and, if applicable, off-site laboratory perform.

Similarly, if you are a generator, it is recommended that you determine the best system for 

developing and keeping records of your test results and other determinations. Generators 

are required to keep records of their hazardous waste determinations as required by 

§262.40(c) and their LDR determinations as required by §268.7(a)(6). The text box below 

recommends information for generators to retain on their hazardous waste and LDR 

determinations.

Finally, generators and TSDFs may want to consult their regulatory agency to learn more 

about the records that they should retain and/or submit. For example, as a TSDF, you may 

need to submit records of off-site laboratories that are used (e.g., Quality Assurance Plans, 

analytical results, etc.). As part of the permitting process, the agency may request that you 

retain (and include in your permit application) many of the standard operating procedures 

(SOPs) that you use to perform your waste determinations and analyses. 

Some Suggested Recordkeeping for Generator Hazardous Waste Determinations (§262.11) 

and LDR Determinations (§268.7(a)(1))*

 List or inventory of all wastestreams generated at the site that were subjected to testing or acceptable 

knowledge under §262.11 and§ 268.7

– Helps the generator and regulators determine if all solid wastes on-site are being properly evaluated and 

managed under RCRA.

– Should be kept up to date.

 Information to be retained for testing determinations under §262.11 and§ 268.7

– Sampling method (e.g., grab vs. composite; number of samples, etc.), rationale for the number of 

samples collected (e.g., statistical basis), date of samples.

– Parameters analyzed.

– Test methods used, SOPs, credentials of lab that performed the test, date of test.

– Test results, data validation/interpretations, determination.

– Quality control data (e.g., sampling QC data).

 Information to be retained for acceptable knowledge determinations under §262.11 and§ 268.7

– Explanation of determination (e.g., explanation of extrapolations or calculations using SDS, date of 

determination, etc.).

– Background information used in the determination (e.g., industry documents, process information, SDS). 

* Generators are required to keep records of their hazardous waste determinations as required by §262.40(c) 

and LDR determinations as required by §268.7(a)(6) and (8). Records must be kept for at least 3 years, as 

specified.
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PART TWO: Documenting and Conducting Waste Analysis 2-79

2.13 Corrective and Preventative Action Measures

It is recommended that your facility establish a 

waste analysis corrective and preventative action 

program, which could be described in the WAP. 

Corrective and preventative action, in this context, 

is defined as the steps that a facility will take to 

eliminate the cause(s) of a nonconformity or 

undesirable situation due to a deficiency in 

current practices. This may include deviations 

from using proper sampling techniques or out of control quality control data that may 

affect overall data quality. The purpose of corrective and preventative action is to prevent 

the recurrence of the nonconformity or undesirable situation by eliminating the cause. 

Following are some issues that you may want to address in your corrective and 

preventative action program:

 How deficiencies will be identified and reported.

 How a remedy to the deficiency will be determined.

 What the timeframes/deadlines are for determining the remedy, instituting the remedy, 

and verifying that the remedy has been properly implemented.

 Who is involved in each of the above steps and who is responsible for each item.

 Whether contractors (e.g., labs), if used by your facility, have their own corrective and 

preventative action program and whether it is sufficient to meet the needs of your 

facility.

40 CFR 264/265.13 do not require WAPs to 

include corrective and preventative action 

measures. However, this manual

recommends that such measures be 

established and described in the WAP to 

help prevent undesirable situations due to 

a deficiency in current practices.
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PART TWO: Documenting and Conducting Waste Analysis 2-80

FIGURE 2-10: Example Waste Profile Sheet 

(Other formats may be acceptable)

Waste Profile #:_____________________________ EPA Facility ID #:______________________________________________

I. GENERATOR INFORMATION

1. Generator Name: ________

2. EPA ID #: ________

3. Mailing Address:

4. Plant Address:

5. Business Contact: Phone #: ________

6. Technical Contact: ________Phone #:

The following information is requested pursuant to 40 CFR 264/265.13 General Waste Analysis (RCRA).

II. GENERAL WASTE INFORMATION

7. Waste Material Name:

8. Generator Code (Optional): ________

9. Describe process that generates waste:

10. NAICS Code:

11. Is your company the original generator of the waste? No ____ Yes ____ If not, provide the name of the original 

generator: 

________________________

12. If this waste is a still bottom, are you the original generator of the feed stock? No ____ Yes ____ 

13. Rate of Generation: Current Accumulation: Drums: Bulk (gal.):

14. Check all types of containerization for which you request quotation:

____ 55-gallon steel drum ____ 55-gallon fiber drums

____ 30-gallon steel drum ____ 5-gallon pail

____ 85-gallon steel drum (w/o inside container) ____ bulk (waste viscosity must be < 5000 cps)

____ 85-gallon salvage drum (w/drums inside) ____ other:

 _____ Palletized small containers

Overall dimensions of material on pallet: ______ X______X______ (l X w X h)

Dimensions of pallet only: ______ X _____ X ______ (l X w X h)

What are the small containers on the pallet? (1 qt. bottles, 8 oz. aerosol cans, etc.)

III. WASTESTREAM CHEMICAL COMPOSITION**

15. Components Including 40 CFR 261 Appendix 

VII Hazardous Constituents

Concentration 

Range (units)

Average %

(must total 

100%)

TLV (if published)

ACGIH OSHA

 to

 to

 to

 to

 to

* If applicable, this Waste Profile Sheet is a new revision of a previously submitted Waste Profile Sheet dated: _________.

Attach to the Form any additional information which must be known to treat, store, or dispose of the waste in accordance 

with RCRA §§264/265.13, including but not limited to data developed under RCRA Part 261, Laboratory Analysis Technical 

Publications or Materials Safety Data Sheets.

**40 CFR 261 Appendix VIII constituents should be identified for combustion facilities, even if not present in high enough 

concentrations to significantly contribute to the 100% composition.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-81

IV. SPECIFIC ANALYSIS OF WASTE

16. Method used to obtain a representative sample of the analyzed waste (i.e., grab, composite, etc.). Sampling 

methods are described in RCRA 40 CFR 261 Appendix I: ________________________________________________

Generator’s Knowledge & SDS – in completing the next two items, do not leave blanks. If the specific element is 

not present, indicate “None.”

Organic Bound Concentration Range Average

Sulfur to

Chlorine to

Fluorine to

Bromine to

Iodine to

Nitrogen to

Phosphorus to

17. Metals (Actual Content) - Base % WT on 

Arsenic (ppm) Molecular Structure Mercury (ppm)

Barium (ppm) Nickel (ppm)

Cadmium (ppm) Selenium (ppm)

Chromium (ppm) Silver (ppm)

Lead (ppm) Thallium (ppm)

Aluminum (%) Silicon (%)

Magnesium (%) Sodium (%)

18. Does this waste contain PCBs ≥ 50 ppm? No ____ Yes ____ 

If yes, give the concentration regardless of amount and attach supporting documentation:

19. Does this waste contain insecticides, pesticides, herbicides, or rodenticides? No ____ Yes ____ 

If yes, identify each and the concentrations (ppm):

(Include the SDS for each)

20. Does this waste contain dioxin? No ____ Yes ____ 

21. Does this waste contain free cyanide > 250 ppm? No ____ Yes ____ 

22. Does this waste contain free sulfide > 250 ppm? No ____ Yes ____ 

V. TOXICITY

23. Check Applicable Data Explain

Eye

Inhalation

Dermal

Ingestion

Other

Carcinogen (suspected or known)

VI. PHYSICAL PROPERTIES

24. Physical state/viscosity at 70° F: liquid___ semisolid___ solid___ slurry___ sludge___ gas___

Viscosity (cps): 

25. Is material pumpable? No ____ Yes ____ If varies, explain

26. Is waste multilayered? No ____ Yes ____ If yes, please describe and quantify each layer below:

Top (%):

Next (%):

Next (%):

27. Dissolved Solids (%WT) 32. Vapor Pressure at 70oF

28. Suspended Solids (%WT) 33. Specific Gravity

29. Btu Value/lbs 34. pH

30. Ash Content (% WT) 35. Corrosivity

31. Flashpoint (oF) 36. Color
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-82

37. What is the Reactivity Group Number(s) for this waste?_________________________________

(in accordance with Design and Development of Hazardous Waste Reactivity Testing Protocol, EPA-600/2-84-057,1984)

38. Is this material stable? No ____ Yes ____ If no, explain:

39. Is this material shock sensitive? No ____ Yes ____ If yes, explain:

VII. EPA INFORMATION

40. Is this waste hazardous as defined by RCRA 40 CFR Part 261? No ____ Yes ____ If yes, list the applicable EPA 

Hazardous Waste Number(s) and explain why you have assigned the number(s). For example, if you assign D001, 

the reason for selection is that the flash point is less than 140° F. If you assign F002, the reason for selection may be 

that the waste is the still bottom from the recovery of methylene chloride.

EPA Hazardous Waste Numbers Reason for Selection

41. If the answer to #40 is yes, list CERCLA reportable quantities found in 40 CFR Part 302.4:

42. If the waste is not hazardous as defined by federal regulations but is hazardous as defined by state regulations in 

which the waste was generated, please provide the state hazardous waste number(s). Also, provide any state 

hazardous number(s) that are not included in the federal regulations:

State Hazardous Waste Numbers Reason for Selection

VIII. SAMPLING INFORMATION

43. Sample source (e.g., drum, lagoon, pond, tank, vat, etc.):

Date Sampled:______________ Sampler’s Name/Company:_____________________________________________

44. Generator’s Agent Supervising Sampling: 

If no sample required, provide rationale:

IX. LAND DISPOSAL RESTRICTIONS INFORMATION

45. Identify all characteristic and listed EPA hazardous waste numbers that apply (as defined by 40 CFR Part 261). For 

each waste number, identify the subcategory (as applicable, check none, or write in the description from 40 CFR 

268.40).

EPA 

Hazardous 

Waste Code(s)

Subcategory

(enter subcategory or none if 

not applicable))

Applicable Treatment Standards Management 

Restrictions 

(Designate A-D 

per below)

Performance Based (check 

as applicable)

Specified Technology 

(enter 268.42 Table 1 

codes)

Description None 268.41(a) 268.43(a) 268.42

To list additional EPA waste numbers and categories, use additional page and check here: ____

If this waste includes any RCRA Codes D001 through D043, can this waste reasonably be expected to exceed the 40 

CFR 268.48 Universal Treatment Standards (UTS) for any Underlying Hazardous Constituent(s)? No ____ Yes ____. 

If yes, include an attachment that identifies each constituent expected to exceed the UTS.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART TWO: Documenting and Conducting Waste Analysis 2-83

Management under the land disposal restrictions:

A. Restricted waste requires treatment? No ____ Yes ____ 

B1. Restricted waste treated to performance standards? No ____Yes____ Method:_______________________

B2. Restricted wastes for which the treatment standard is expressed as a specified technology (and the waste has 

been treated by that technology)? No ____ Yes ____ Method:______________________________________

B3. Good faith analytical certification for incinerated organics No ____ Yes ____ 

Method:_________________________

C. Restricted waste subject to a variance? No ____ Yes ____ 

Date/Type:_____________________________________

D. Restricted waste can be and disposed without further treatment? No ____ Yes ____ 

X. DOT INFORMATION

In accordance with the Department of Transportation 49 CFR Parts 171 through 177, complete the following:

46. DOT Proper Shipping Name:_______________________________________________________________________

47. DOT Hazard Class:_______________________________________________________________________________

48. DOT UN or NA Number:__________________________________________________________________________

49. Container Label(s) - for containers of 110 gallons or less:___________________________________________________

50. Placards:_______________________________________________________________________________________

(Generator’s hazardous waste shipments must also comply with the labeling requirements of RCRA 40 CFR Part 262)

51. Is this waste a soil and/or debris? No____ Yes, Soil:____ Yes, Debris:____ Yes, Both:_____ 

52. Complete Only for Wastes Intended for Fuels or 

Incineration (Total)

53. Reclamation, Fuels or Incineration Parameters 

(provide if information is available) 

Antimony as Sb (ppm) A. Heat value range (Btu/lb.): to 

Beryllium as Be (ppm) B. Water:

Potassium as K (ppm) C. Viscosity (cps): @ ° F 100° F 150° F

Sodium as Na (ppm) D. Ash (%):

Bromine as Br (ppm) E. Settleable Solids (%):

Chlorine as Cl (*ppm or %) F. Vapor Pressure @ STP (mm/Hg):

Fluorine as F (*ppm or %) G. Is this waste a pumpable liquid? No Yes

Sulfur as S (*ppm or %) H. Can this waste be heated to improve flow? No Yes

*indicate ppm or % I. Is this waste soluble in water? No Yes

J. Particle Size: Will the solid portion of this waste pass 

through a 1/8-inch screen? No Yes

54. Special Handling Information: _____________________________________________________________________

_____________________________________________________________________________________________

XI. ACCOUNTABILITY STATEMENT

55. I hereby certify that all information in this and all attached documents contains true and accurate descriptions of 

this waste. Any sample submitted is representative as defined in 40 CFR 262 Appendix I or by using an equivalent 

method. All relevant information regarding known or suspected hazards in the possession of the generator has 

been disclosed. I authorize (_______________________________) to obtain a sample from any waste shipment for 

purposes of recertification.

_________________________________________________________________ ________________________________

Authorized Signature Date

__________________________________________________________________

Printed (or typed) Name and Title
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART THREE: Checklist 3-1

3.

PART THREE: 

Checklist29

Yes No Comments

1. Facility Description

a. Are all processes that generate hazardous waste 

identified?

b. Is sufficient information provided for each process to 

confirm that all hazardous wastes are identified?

c. Have all hazardous waste management units been 

identified?

d. Are descriptions of all hazardous waste management units 

provided?

e. Have all hazardous and solid wastes been

identified for each unit?

f. Have the methods of waste management (e.g., 

stabilization) been described for each unit?

g. Are process design limitations defined for

each hazardous waste management unit?

h. Have operational acceptance limits been established for 

each hazardous waste management unit?

i. Are procedures in place to determine whether wastes are 

outside of their respective acceptance ranges?

j. Do operational acceptance limits include

applicable regulatory restrictions?

2. Systematic Planning 

a. Does the WAP incorporate a process for systematic 

planning, such as the Data Quality Objectives (DQO) 

process?

b. Do personnel training records (located in the permit 

application) demonstrate that facility personnel supervising 

and conducting waste sampling and analysis have 

received appropriate training in systematic planning?

3. Selecting Waste Parameters

a. Are parameters for waste analysis identified (and, if 

applicable, included in the WAP)?

b. Does the WAP identify a rationale for the selection of each 

waste analysis parameter?

 

29 Refer to Part Two of this manual for additional information on these checklist items. Note that some items are 

mandatory and others are recommended.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART THREE: Checklist 3-2

Yes No Comments

c. Does the WAP include parameters for the special waste 

analysis requirements 40 CFR 264/265.17, 264/265.314, 

264/265.341, 264/265.1034 (d), and 266.102(b), if 

applicable?

d. Have operational acceptance limits been defined as they 

related to waste properties and process?

e. Do operational acceptance limits include regulatory 

restrictions?

f. Do waste analysis parameters address applicable 

operational acceptance limits?

4. Selecting Sampling Procedures

a. Has the number of sampling locations been identified?

b. Are sampling procedures for each waste type identified?

c. Are descriptions and justifications provided for any 

modified or non-standard procedures approved by EPA?

d. Have decontamination procedures for sampling equipment 

been developed?

e. Have sampling strategy techniques (e.g., grab, composite) 

been specified?

f. Are procedures for sampling multi-phase wastes 

addressed, if applicable?

g. Has all sampling equipment been identified?

h. Have the number and types of sampling containers been 

specified?

i. Have sample preservation techniques been specified?

j. Have sampling quality assurance and quality control 

procedures been documented?

k. Are proper packing and shipping procedures documented?

l. Have procedures for the maintenance of all sampling 

equipment been documented?

m. Have the precision and accuracy of all sampling 

equipment been documented?

n. Are health and safety procedures for the protection of 

sampling personnel specified?

5. Selecting a Laboratory and Laboratory Analytical Methods

 a. Are laboratory analytical methods specified for each waste 

managed at the facility? If, not, is other information (i.e., 

acceptable knowledge) used to demonstrate waste 

analysis?

 b. Has a rationale been specified for each analytical method?
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART THREE: Checklist 3-3

Yes No Comments

 c. Do the selected analytical methods meet all regulatory 

requirements for the identification of each hazardous 

waste (e.g., each hazardous waste characteristic)?

 d. Are descriptions and justifications provided for any 

modified or non-standard methods, as approved by EPA?

 e. Have chain-of-custody procedures for samples been 

specified, if necessary?

 f. Does the laboratory have an adequate QA/QC program?

 g. Have QA/QC procedures for each analytical procedure 

been identified?

6. Quantifying Data Uncertainty

 a. Does the WAP incorporate a process for quantifying data 

uncertainty so that laboratory results are capable of 

supporting the facility’s waste management decisions (i.e., 

is there an appropriate level of certainty in the results)?

7. Selecting Waste Re-Evaluation Frequencies

 a. Have site-specific criteria for waste re-evaluations been 

specified?

 b. Is re-evaluation accomplished with adequate frequency?

 c. Are mechanisms in place for re-evaluating the sampling 

program each time the waste generating processes 

change?

 d. Do the re-evaluation procedures specify criteria for the 

acceptance of wastes received from off-site generators?

 e. Do you notify off-site facilities of changes in waste 

characterizations due to process changes and other 

factors?

8. Special Procedural Requirements, Where Applicable

 a. Are procedures in place to verify the sources of the 

information provided from off-site generators or TSDFs?

 b. Have criteria been established for the pre-acceptance 

procedures of wastes based on information from off-site 

generators or TSDFs?

 c. Are procedures for waste inspections in place?

 d. Have fingerprint analysis parameters been developed?

 e. Have criteria been established for the acceptance of 

wastes based on the results of fingerprint analysis?

 f. Is there a methodology for identifying ignitable, 

incompatible, or reactive wastes?

 g. Are procedures in place to conduct testing to determine 

whether wastes are incompatible with each hazardous 

waste management unit on-site?

 h. Have all wastes restricted under the LDRs been identified?
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART THREE: Checklist 3-4

Yes No Comments

 i. Are procedures in place to ensure that wastes meet 

applicable LDR treatment standards prior to land disposal?

9. Discrepancy Policy

 a. Are procedures in place to resolve discrepancies between 

incoming shipment and its manifest? 

 b. Are the procedures in compliance with applicable manifest 

discrepancy regulations (Part 264/265, Subpart E)?

 c. Are procedures in place to resolve discrepancies between 

incoming shipment and its waste profile?

 d. Do these procedures include a process for recharacterizing the waste and revising or preparing a new 

profile when needed?

10. Rejection Policy

 a. Are procedures in place to reject a waste in accordance 

with applicable RCRA regulations (Part 264/264, 

Subpart E)?

 b. Are these procedures coordinated with the discrepancy 

policy as necessary?

11. Recordkeeping

 a. Does the WAP clearly identify all of the types of records 

that will be kept?

 b. Does the WAP indicate the length of time that records will 

be kept and are these timeframes in compliance with 

applicable regulations?

 c. Will the facility produce summary-level reports based on its 

records, to describe its compliance with applicable WAP 

requirements (e.g., on LDR compliance testing)?

 d. Will the facility’s recordkeeping systems produce records 

to on-site inspectors in a timely and organized fashion?

12. Corrective and Preventative Action

 a. Is a corrective and preventative action program in place to 

identify and eliminate the cause(s) of nonconformities and 

undesirable situations due to deficiencies in current 

laboratory practice?

 b. Does the WAP describe how deficiencies will be reported 

and remedies determined?

 c. Does the WAP spell out the timeframes for reporting and 

resolving problems?

 d. Are responsible personnel identified (e.g., by position)?
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-1

PART FOUR: 

Sample WAPs

This chapter presents two WAPs that EPA has compiled from different types of TSDFs. The 

examples are intended to give permit applicants and permit writers ideas and issues to 

consider when preparing or approving a WAP. However, as discussed below, the examples 

are not complete or approvable as presented and should be used only as a learning tool. An 

occasional call-out box is included in the WAPs to highlight certain issues. As a permit 

applicant, you should not simply “copy and paste” text from the examples into your 

WAP. Rather you should carefully understand how to develop your WAP in 

accordance with the regulations and ensure that it is appropriate for your own 

facility. Furthermore, it is important that you carry out and implement the 

necessary procedures, as outlined in your WAP, to satisfy the regulatory WAP 

requirements. Every WAP is different and should account for facility- and state-specific 

considerations and comply with all applicable requirements. 

The following WAPs are presented:

 Example 1 belongs to ACE Chemical Services, which is a commercial treatment and 

disposal facility. It receives hazardous waste shipments from offsite, performs 

stabilization and other forms of treatment, and landfills the treated waste onsite.

 Example 2 belongs to Container Management Incorporated (CMI), which is a 

commercial storage facility. It receives shipments from offsite customers, performs 

minimal waste handling (e.g., consolidation), and ships the waste offsite for further 

management and disposal.

Although the federal regulations are cited in the examples, you should consult and 

reference your own state’s regulations when preparing your WAP. States may require

more and/or different information.

Please note that the example WAPs have been edited as follows:

 The name of the actual TSDF and other identifying information have been removed or 

changed; and

 The WAPs have been edited to reduce their overall length and modify content. For 

example, some of their text, graphics and/or attachments may have been shortened, 

simplified or removed. This was done solely to facilitate their presentation in this 

guidance. Notations have been inserted to indicate when text has been shortened from 

its original version. Any WAP submitted by a permit applicant must include all required 

and appropriate text, graphics, and attachments.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-2

Example WAP 1: Waste Analysis Plan for 

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

PART FOUR: Sample WAPs 4-3

Table of Contents

A. Waste Analysis Plan ____________________________________________ 4-5

A-1 Introduction _______________________________________________________________4-5

A-2 Pre-acceptance Procedure ____________________________________________________4-6

A-2.1 Generator-Supplied Information ..............................................................................................4-6

A-2.2 Initial Review and Analysis.......................................................................................................4-7

A-2.3 Disposal Decision Process ........................................................................................................4-8

A-2.4 Re-Evaluation Process..............................................................................................................4-8

A-3 Acceptable Waste Codes _____________________________________________________4-9

A-4 Analyses during Waste Acceptance and Process Operations __________________________4-9

A-4.1 Verification of Incoming Shipments........................................................................................ 4-12

A-4.1.1 Visual Inspection ........................................................................................................... 4-12

A-4.1.2 Chemical Screening........................................................................................................ 4-12

A-4.1.3 Discrepancy Resolution.................................................................................................. 4-15

A-4.1.4 Supplemental Verification.............................................................................................. 4-15

A-4.1.5 Final Acceptance............................................................................................................ 4-15

A-4.2 Process Operations Procedures.............................................................................................. 4-16

A-4.2.1 Storage.......................................................................................................................... 4-16

A-4.2.2 Stabilization .................................................................................................................... 4-17

A-4.2.3 Landfill Disposal............................................................................................................. 4-18

A-5 Restricted Wastes__________________________________________________________4-20

A-6 Rejection Policy ___________________________________________________________4-20

A-6.1 Authority ............................................................................................................................... 4-21

A-6.2 Safety .................................................................................................................................... 4-21

A-6.3 Scheduling............................................................................................................................. 4-21

A-6.4 Documentation...................................................................................................................... 4-21

A-6.5 Notification............................................................................................................................ 4-21

A-6.6 Rejection ............................................................................................................................... 4-22

A-7 Discrepancy Resolution _____________________________________________________4-22

A-7.1 Manifest Discrepancy............................................................................................................. 4-22

A-7.2 Discrepancies Between Waste Received at Facility and Waste Profile..................................... 4-22

A-8 Sampling Methodology _____________________________________________________4-23

A-8.1 General Methods and Equipment........................................................................................... 4-24

A-8.2 Specific Methods and Equipment........................................................................................... 4-24

A-8.2.1 Containers and Tanks..................................................................................................... 4-25

A-8.2.2 LDR “Grab” Sampling ..................................................................................................... 4-25

A-9 Parameters and Analytical Methods ___________________________________________4-26
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-4

A-10 Quality Assurance /Quality Control____________________________________________4-28

A-10.1Introduction .......................................................................................................................... 4-28

A-10.2Sampling Program.................................................................................................................. 4-28

A-11 Data Reporting ____________________________________________________________4-29

A-12 Recordkeeping ____________________________________________________________4-29

A-13 Corrective Action __________________________________________________________4-31

Appendices____________________________________________________________________4-32

Appendix A-1 Waste Profile Sheet.................................................................................................... 4-32

Appendix A-2 Overview of the Pre-Acceptance Process .................................................................... 4-32

Appendix A-3 Overview of the Incoming Load Process...................................................................... 4-32

Appendix A-4 Aqueous Waste Treatment......................................................................................... 4-32

Appendix A-5 Landfill and Stabilization............................................................................................. 4-32
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-5

4.

A. Waste Analysis Plan

In accordance with the regulatory requirements set forth in 40 CFR 264.13, ACE Chemical 

Services, L.L.C. (ACE) has developed this Waste Analysis Plan as an integral part of the 

permit application for its treatment, storage and disposal facility. The procedures set forth 

in this plan dictate that this facility will be in compliance with all requirements of 40 CFR 

264.13. A copy of this plan will be available at the facility at all times. 

A-1 Introduction

The purpose of this Waste Analysis Plan (WAP) is to 

identify and document the necessary sampling 

methodologies, analytical techniques and overall 

procedures which are undertaken for all wastes that enter this facility for storage, treatment 

or disposal. Specifically the plan delineates the following:

 Pre-Acceptance Procedures – Section A-2 outlines the procedural steps ACE will take 

to evaluate the acceptability of a candidate waste stream pursuant to permit conditions 

and operating capabilities prior to shipment and acceptance of the waste for 

management at the site, including re-evaluation frequency.

 Acceptable Waste Codes – Section A-3 summarizes the wastes that ACE facility is 

approved to accept.

 Waste Analyses Performed by ACE Facility – Section A-4 describes the analyses 

performed on incoming shipments and wastes in process operations.

 Restricted Wastes – Section A-5 summarizes wastes that ACE facility is not approved 

to accept.

 Rejection Policy – Section A-6 discussed the policy and procedures that ACE will use 

for the acceptance or rejection of waste received by the facility.

 Discrepancy Policy – Section A-7 discusses ACE facility’s procedures for resolving 

manifest discrepancies and discrepancies between incoming waste shipments and their 

waste profile.

 Sampling Methodology – Section A-8 outlines the proper sampling method(s) for a 

given waste type (solid, sludge, liquid) and containment (drum, tank, impoundment 

pile, etc.). ACE personnel can then obtain waste identification samples to help ensure 

accurate analytical results when a waste is analyzed.

 Analytical Parameters, Techniques and Rationale – Section A-9 outlines the 

parameters, rationale and methods ACE will utilize to determine or identify certain 

waste properties to ensure proper management of the waste at the site. 

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-6

 Quality Control Policy – Section A-10 outlines the quality control policy this site will 

follow to achieve high quality analytical results.

 Data Reporting – Section A-11 identifies the data 

that ACE facility will supply to the state Director 

under this WAP.

 Recordkeeping – Section A-12 identifies the records 

that ACE facility will retain on site related to waste 

analyses performed under this WAP.

 Corrective Action – Section A-13 describes the procedures that ACE facility will take to 

resolve issues, needs or problems that may arise in connection with its laboratory 

operations.

The Approvals Manager, Laboratory Manager, Technical Manager, General Manager or 

their designees are individually and collectively herein referred to as “ACE site 

management”.

A-2 Pre-acceptance Procedure

ACE has developed a series of control procedures to determine the acceptability of specific

wastes for management at the site, referred to as the “Pre-acceptance Procedures.” The

pre-acceptance procedures include the following steps:

 Generator-supplied information is what a customer must provide to enable ACE to

make an initial decision regarding the appropriateness/acceptability and possible

management of a candidate waste stream.

 Initial review and/or analysis of the generator-supplied material allows ACE to

conduct an initial evaluation for management capabilities at the facility.

 Disposal decision is the process of reviewing all the documentation supplied by the

generator and/or ACE and documenting the acceptance or rejection of the candidate 

waste stream.

 Re-evaluation process determines the frequency a waste stream will be re-evaluated 

once it has been accepted.

A-2.1 Generator-Supplied Information

The waste generator will supply ACE with the following information and materials for each 

new candidate waste stream, except where noted herein.

 Waste Profile Sheet, (WPS), which will contain pertinent chemical and physical data.

At a minimum, the generator supplies all the information required by 40 CFR 

WAP Accountability

Consider identifying those individuals, 

by title, who are ultimately responsible 

for ensuring WAP compliance. This will 

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

PART FOUR: Sample WAPs 4-7

264.13(a)(1) needed to characterize the waste for proper treatment, storage, or 

disposal. ACE may assist the generator in completing information provided by the 

generator based on its evaluation. The complete package is reviewed and approved by 

the generator at the completion of the approval process.

 A standard profile is a profile that is used for multiple waste streams that are similar 

in physical and chemical characteristics. Standard profiles will be used only for wastes 

that share the same:

– Generating process. The generating process should be described in sufficient 

specificity. For example, for electroplating, this would include an indication of type 

of electroplating (zinc electroplating, chromium electroplating, etc.) and a narrative 

description of the generating process.

– Raw ingredients used in the generating process. The waste profile should

include a complete list of the ingredients used in the process that generates the 

waste; and

– Onsite management method. If two wastes require different management 

methods at the ACE facility (e.g., pre-treatment vs. no pretreatment before 

stabilization), they require different waste profiles.

 A representative sample is required of all waste streams, with limited exceptions.

Refer to Sections A-4 and A-9 of this WAP for parameters to be analyzed during preacceptance. No representative sample is required for the following:

– Lab packs. Lab pack chemicals are managed in 

accordance with all applicable state regulations

based on certifications presented.

– “Empty” containers of waste materials.

Commercial products or chemicals. This applies 

to a portable container which has been emptied 

but which may hold residues of the product or 

chemical (e.g., portable tanks, drums, barrels,

cans, bags, liners, etc.). A container shall be determined RCRA “empty” according to 

the criteria specified in 40 CFR Part 261.7.

 Land Disposal Restriction Notification/Certification Information and/or Data (40 CFR 

Part 268).

 Other supporting documentation such as additional analytical results or a safety data

sheet (SDS), as necessary to provide additional waste characterization. 

A-2.2 Initial Review and Analysis

Once ACE receives the generator-supplied information and it is reviewed, a determination 

will be made if further analyses by the generator or ACE are required. All waste samples 

will be subjected to the analyses identified in Section A-4, as appropriate. Additional testing 

may also be requested by the site management if needed.

Sampling During Pre-Acceptance

Analysis of a sample may be 

necessary during pre-acceptance

(e.g., if the receiving facility has 

compliance requirements for 

treatment or disposal, such as LDR 

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

PART FOUR: Sample WAPs 4-8

If, during the pre-acceptance procedure, ACE determines that the waste information

indicated by the testing does not completely conform to the information on the WPS, the 

generator is notified of the apparent inconsistency. If the inconsistency is resolved, the preacceptance procedure continues. The waste may be rejected or accepted during this phase 

of the procedure.

A-2.3 Disposal Decision Process

The pre-acceptance procedure is concluded when the review of the generator supplied 

information and any appropriate mandatory analyses is complete. At this time, ACE makes 

a “disposal decision” on the candidate waste. Disposal decisions are based on:

 Management methods available.

 Conditions or limitations of existing permits and regulations. 

 Capability to safely manage the waste.

 WPS description of the process generating the waste.

 Knowledge of the waste generating process. 

 WPS description of the chemical and physical properties of the waste. 

 Any additional documentation supplied by the generator (e.g., LDR certifications).

 Results of any verification analyses.

 Results of any analyses of process operations procedures.

 Management’s technical experience and judgment. 

A-2.4 Re-Evaluation Process

In accordance with 40 CFR 264.13(a)(3), a waste profile 

re-evaluation will be conducted when one of the 

following occurs:

 A generator notifies ACE that the process generating 

the waste has changed;

 The results of inspection or analysis indicate that the 

waste received at the facility does not match the

identity of the waste designated on the

accompanying manifest (or shipping paper) or pre- acceptance documentation (See 

Discrepancy Policy in Section A-7); or

 At the end of each calendar year for all wastes received and managed during the year, as 

follows:

WAP Performance Evaluation

Consider including provisions in the 

WAP for the facility to evaluate their 

WAP performance continually and 

keep records. This will promote ongoing improvements and assist 

regulators during compliance 

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

PART FOUR: Sample WAPs 4-9

– ACE will conduct a comprehensive annual review of all wastes accepted onsite by 

comparing the results of fingerprint analyses (which are maintained in ACE’s inhouse waste tracking system) to the WPSs to identify any pattern of discrepancy 

(e.g., pH of fingerprinted waste that falls outside its tolerance limits (as described 

herein) more than 20% of the time).

– ACE will conduct an annual evaluation of its post-treatment results to identify 

instances where the treatment standards were not met and treatment had to be 

repeated. In these cases, ACE will evaluate the incoming waste to determine if their 

WPSs are accurate or if they should be re-characterized and WPSs revised to 

provide better information to enable more effective treatment.

– ACE will send all WPSs to the generators annually for their review, revisions if 

needed, and re-certification. Generators will be asked to re-evaluate each WPS to 

determine if the generation process (e.g., raw ingredients, generating process) or 

waste (e.g., waste codes) has changed such that a new or revised WPS is needed.

A-3 Acceptable Waste Codes

In brief, this facility accepts waste codes D001 through 

D043, F001 through F039 (except F020 through F028), 

K001 through K172, P001 through P205, U001 through 

U411 (except as otherwise noted in Section A-5 of this WAP regarding restricted waste).

Refer to the latest version of this facility’s RCRA permit (dated December 2011) for a 

complete list of the RCRA waste codes that this facility is approved to accept and manage 

onsite. The list in the permit supersedes the language in this WAP.

A-4 Analyses during Waste Acceptance and Process 

Operations

As discussed in Section A-2, ACE site management 

samples each waste that undergoes the preacceptance procedures, with limited exceptions.

When a shipment of hazardous or non-hazardous 

waste is received at the ACE facility, verification of 

the shipment is performed. Verification activities 

include container receipt inspection. It also 

includes chemical screening according to the 

frequencies specified in this section. Any 

discrepancies between the verification results and 

waste profile must be resolved in accordance with 

the Discrepancy Policy discussed in Section A-7 

before the shipment can be accepted at the facility.

In addition, process operations procedures are performed to ensure that the waste is 

managed safely and in accordance with applicable regulations.

This is not a mandatory WAP 

element under 40 CFR 264.13.

Summary of All Analyses Performed

It is recommended that a summary of all 

sampling/analysis performed at the facility 

(e.g., parameters and testing frequency) be 

presented in one place in the WAP. Tables 

and graphics are helpful. See Tables A-1 

and A-2 for example. Subsequent sections 

of the WAP can go into greater detail.

Note that this WAP does not summarize 

testing of wastes generated by ACE; 

however, there should be some discussion 

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

PART FOUR: Sample WAPs 4-10

Table A-1 summarizes the parameters that are examined for each of these screening 

analyses. Parameters for waste analysis during pre-acceptance are shown in Column 2.

Once the waste is approved during pre-acceptance, all incoming shipments are subjected to 

mandatory verification, including inspections and chemical screening (Column 3A). In 

addition, supplemental analyses may be performed to resolve discrepancies between the 

verification results and waste profile (Column 3B). Finally, analyses are performed as 

necessary for process operations that are conducted onsite (Columns 4A-C). Specifically, 

for incoming wastes that will be placed into storage, ACE performs the mandatory 

verification in Column 3A to determine appropriate storage procedures, such as 

segregation of incompatible waste (Column 4A). For incoming wastes to be stabilized, ACE 

performs the mandatory verification in Column 3A to determine appropriate treatment 

(Column 4B). Finally, ACE performs “Suitability for Landfill” analyses (e.g., TCLP to ensure 

compliance with 40 CFR part 268 treatment standards) for any waste to be landfilled at the 

ACE facility (Column 4C). This includes (1) incoming wastes for which the generator or 

treater has certified compliance with all applicable treatment standards and (2) wastes 

stabilized onsite by the ACE facility. Note that ACE’s onsite treatment is designed to 

address only the inorganic constituents of the waste; it does not treat organics. Table 

A-2 summarizes the frequency by which each of these analyses must occur. Refer to ACE’s 

SOPs for additional information on sampling frequency.

TABLE A-1: Analyses Performed by ACE Facility a

1. Indicator 

Parameters

2. PreAcceptance

3. Incoming Shipments 4. Process Operations Procedures

A. Mandatory 

Verification

B. 

Supplemental

A. Storage of 

Incoming 

Shipments

B. Stabilization 

of Incoming 

Shipments C. Landfillb

Physical Description X X X

NAcNAd

O

pH Screening X X X O

PCB Screening X X X O

Suitability for Landfill X X X

Water Mix Screening X X X O

Flammability Potential 

Screening

X X X O

Sulfide Screening X X X O

Radioactivity 

Screening

X X X O

Ash Screening X O X O

Compressive Strength X O X O

Conductivity X O X O

a. X = parameters that are examined for each waste.

O = parameters that are examined as necessary. NA = not applicable.

b. This column applies to the following that are destined for the ACE landfill: (1) stabilized wastes received from offsite that have been certified 

by the generator or treater as meeting all applicable LDR treatment standards and (2) wastes that have been stabilized onsite by ACE facility. 

The table shows that such wastes are subject to the “Suitability for Landfill” analyses (e.g., TCLP) before disposal. Other analyses may also be 

performed at site management’s discretion. ACE facility also implements an Additional Review Program described in Section A-4.2.3. 

c. Incoming wastes to be placed in storage will be subject to mandatory verification in Column 3A.

d. Incoming wastes to be stabilized before onsite disposal will be subject to mandatory verification in Column 3A. 

NOTE: Table A-1 has been shortened in order to reduce the overall length of this example WAP. This was done 

solely for purposes of presentation in this guidance document.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-11

TABLE A-2: Summary of Frequency of Analysis

Pre-Acceptance

Verification of Incoming Shipments Process Operations Procedures

Mandatory Verification Supplemental

Storage

of Incoming 

Shipments

Stabilization of 

Incoming 

Shipments Landfilla

On each waste 

undergoing preacceptance, 

except as 

otherwise 

specified

On each incoming shipment 

as follows:

 Visual inspection of each 

shipment, including 

inspection of opened

containers to confirm 

physical description

 Chemical screening of 

each bulk load

 Chemical screening of 

each container 

shipment as determined 

by ACE site 

management. See 

Section A.4.1.2 of this 

WAP for additional 

information.

Whenever a 

discrepancy 

between waste and 

WPS is found that 

cannot be resolved 

by generator and 

ACE

For incoming 

wastes to be 

placed in storage, 

see the frequency 

for Mandatory 

Verification 

For incoming 

waste to be 

stabilized, see the 

frequency for 

Mandatory 

Verification

For stabilized waste that is shipped to 

ACE for which the generator or treater 

has certified full LDR compliance: each 

shipment will be analyzed for Landfill 

Suitability. This frequency can be 

decreased, as follows, if 10 successive 

shipments meet all applicable LDR 

standards:

 1 in 10 shipments is analyzed for all 

required parameters; and

 Every shipment is analyzed for an 

indicator parameter (e.g., pH) to 

confirm treatment effectivenessb

For waste that has been stabilized by 

ACE onsite: each batch will be analyzed 

for Landfill Suitability

ACE will also visually inspect each waste 

before placement in the landfill to 

ensure that no free liquids are present. 

A paint filter test (or comparable test) 

will be performed if there is any 

question, the liquids will be removed, 

and the test will be repeated.

a This column applies to (1) wastes received from offsite that have been certified by the generator or treater as meeting all applicable LDR treatment standards and are destined for the ACE landfill 

and (2) wastes that have been stabilized onsite by ACE facility and are destined for the ACE landfill.

b If any shipment fails to meet the treatment standards, 100% testing must be resumed, as specified in this WAP, until a subsequent set of 10 successive shipments meet all applicable 

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

PART FOUR: Sample WAPs 4-12

The following sections provide more information on the analyses that ACE site 

management will perform.

A-4.1 Verification of Incoming Shipments

Verification of incoming shipments involves inspection of containers and chemical 

screening. As part of the facility’s training program described in the Part B permit, 

personnel will be taught how to perform the verification procedures effectively and safely.

A-4.1.1 Visual Inspection

The container receipt inspection is a mandatory 

element of the confirmation process. Therefore, 100 

percent of the incoming shipments are inspected and 

physically verified for damage and to ensure the waste 

containers are those indicated on the documentation. 

This activity is a mechanism for identifying any 

document discrepancies or damaged containers before 

acceptance. The container receipt inspection is 

performed by ACE management, who will ensure that 

the shipment: (1) is received in good condition and 

does not include bulging or other irregularities, (2) is 

the waste indicated on the manifest or shipping papers, and (3) is complete. In addition, at 

least one container from each profiled waste in a shipment will be opened and its contents 

will be visually inspected to confirm it matches the physical description on its profile. The 

visual inspection will address color, viscosity, and waste form (e.g., debris, PPE, sludge), at 

a minimum.

A-4.1.2 Chemical Screening

Chemical screening is considered an additional verification element. Selection and 

interpretation of the appropriate chemical screening method(s) are conducted by 

personnel who are qualified as described in the permit. The objective of chemical screening 

is to obtain reasonable assurance that the waste received by the TSD unit is consistent with 

the description of the waste on the waste profile and to provide information that will be 

used to safely manage the waste at the TSD unit. After chemical screening is done, tamperresistant seals are applied over the container opening on each outer container screened. 

As shown in Table A-2, each bulk load (i.e., truck) will be screened chemically. Samples 

from the front, middle and back of each load will be obtained and composited, if possible.

However, composite samples across separate loads will not be taken. 

Container shipments will be chemically screened according to the Performance Evaluation 

System (PES) and associated procedures, described below.

Visual Inspection of Containers

This WAP requires visual inspection 

of 100% of shipments received, 

including opening some containers to 

view their contents. This is important 

for confirming the physical 

description of the waste and 

supplementing the chemical 

screening, which is performed on 

only a subset of containers.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-13

Chemical Screening Frequency for Container Shipments. Shipments of containers 

received by ACE will be chemically screened as follows:

 If each container in a shipment holds a different 

profiled waste, each container will be chemically 

screened as follows:

– Once per year: No concerns identified. 

– Once every 6 months: Concern(s) identified in 

one criterion.

– Once every 3 months: Concerns identified in two 

or more criteria.

 However, if multiple containers in a shipment (i.e., 2 

or more) hold the same profiled waste, one or more 

samples will be collected from them and chemically 

screened. Based on the identification of concerns 

during the Performance Evaluation System 

(described below), ACE site management will 

establish the initial chemical screening frequency for 

multiple containers based on the following criteria:

– If no concerns are identified: Initial chemical screening frequency of, at a minimum, 

10 percent. 

– If concerns are identified in one criterion: Initial chemical screening frequency of, at 

a minimum, 20 percent.

– If concerns are identified in two or more criteria: Initial chemical screening 

frequency of 30 percent.

 For example, if ACE receives a shipment of 2 to 10 containers holding the same profiled 

waste, ACE would sample one of them, assuming no concerns were identified. If ACE 

receives a shipment of 11 to 20 containers holding the same profiled waste, ACE would 

sample two of them, assuming no concerns were identified.

Composite samples will not be taken across containers holding different profiled 

wastes. 

Description of Performance Evaluation System (PES). The PES is used to determine the 

initial chemical screening frequency of each generator’s containerized waste streams. This 

includes determining the number of concerns we have regarding each waste. We organize 

our concerns under “criterion.” We revise the criteria and concerns annually based on 

operating conditions, regulatory requirements, and other relevant considerations.

Examples of criteria include:

 Historical performance of the generator (e.g., has the generator’s performance in 

characterizing its wastes been satisfactory, and if not, what concerns have been 

identified?);

Chemical Screening Frequency

This approach to chemical screening 

may appeal to some facilities because it 

allows a gradual reduction in frequency 

for certain shipments. However, the 

approach raises some issues:

 Is it acceptable to chemically screen 

certain shipments only once or 

twice per year? What if the 

generator’s waste changes mid-year 

and the facility is not notified. How 

would this change be detected?

 Does the screening approach give 

too much discretion to the facility 

to determine initial frequencies and 

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

PART FOUR: Sample WAPs 4-14

 Nature of the waste (e.g., is it a novel/unknown waste stream, and if so, what potential 

concerns are associated with its management at this facility?); and

 Elapsed time since generator’s last shipment (e.g., has the generator made a shipment 

within the past year, and if not, is there a concern, such as potential changes in its waste 

generating processes that we may be unaware of).

PES provides a periodic status of an individual generator’s performance for containerized 

waste received. Also, PES provides a mechanism for determining corrective actions, 

resolving waste acceptance issues, and chemical screening frequency adjustments when a 

problem has been discovered.

In addition, an annual performance evaluation is used to trend a generator’s performance 

and is used to raise the generator’s overall group of wastestream chemical screening 

frequency based on the type of issue. The evaluation should be objective and should

consider the discrepancy issues documented during the pre-acceptance and verification 

functions. The ACE site management will: (1) perform annual evaluations based on 

deficiencies and discrepancy issues identified, (2) evaluate unsatisfactory performance for 

corrective actions, and (3) adjust chemical screening rates accordingly.

Process for Reducing the Chemical Screening Frequency for Multiple Containers 

Holding Same Profiled Waste. After the initial screening frequency for a given waste 

profile has been established or increased, the chemical screening frequency can be reduced 

in accordance with the following process.

The chemical screening frequency will be reduced gradually, as shown in Table A-3. 

Reduction is based on the ability to demonstrate that five containers from the profiled 

waste in question pass verification. In addition, reduction to the minimum frequency 

requires that the ACE site management documents an acceptable evaluation of the 

corrective action plan, if applicable. At no time will the chemical screening frequency be 

reduced below 10 percent for waste received from offsite.

Table A-3 shows that, for containers for which no concerns were identified during the PES, 

a 10 percent screening is established. This frequency cannot be reduced further. For 

containers for which concerns were identified in one criterion, the initial screening of 20 

percent will be reduced to 10 percent after 5 containers pass verification. For containers 

for which concerns were identified in two or more criteria, the initial screening of 30 

percent will be reduced to 20 percent after 5 containers pass verification and to 10 percent 

after 10 containers pass verification.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-15

TABLE A-3: Reduced Chemical Screening Frequencya

Concerns Identified

Initial Screening 

Frequency

Reduced Frequency 

After 5 Containers 

Pass Verification

Reduced Frequency 

After 10 Containers 

Pass Verification

None 10%bN/A N/A

Concern(s) identified in one criterion 20% 10%bN/A

Concerns identified in two or more criteria 30% 20% 10%b

a This table applies to multiple containers holding the same profiled waste. N/A = not applicable.

b 10 percent is the minimum screening frequency allowed.

A-4.1.3 Discrepancy Resolution

Discrepancy issues identified during verification of any shipment (i.e., bulk or container) 

could result in a waste container that does not meet ACE waste acceptance criteria. If a 

possible discrepancy issue is identified, the actions described in Section A-7 of this WAP 

must be taken.

A-4.1.4 Supplemental Verification

If the mandatory verification of incoming shipments identifies a discrepancy with the WPS, 

and the discrepancy cannot be resolved by the generator, then ACE will perform 

supplemental analysis of the waste, reject the waste back to the generator, or ship the 

waste to an alternate treatment, storage, or disposal facility. ACE will notify the state 

Director of any wastes rejected back to generators. A supplemental analysis includes tests 

for the parameters shown in Table A-1 in Section A-4.

Any waste that is subject to a supplemental analysis will be quarantined until the 

discrepancy with the WPS is resolved.

Supplemental analysis will be subcontracted to an independent state certified or NELAC 

laboratory that uses ASTM and/or SW-846 analytical and test methods. The results of all 

supplemental analyses will be documented in a log maintained as part of the facility 

operating record.

A-4.1.5 Final Acceptance 

Upon verification that a containerized waste or bulk waste is consistent with the 

corresponding WPS, the waste will be moved from the receiving area to an appropriate 

storage cell. Movement to an appropriate storage cell shall occur within the time 

limitations required by the state’s regulations (e.g., 24 hours) after off-loading waste from 

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

PART FOUR: Sample WAPs 4-16

Any waste that does not conform to the corresponding WPS will be quarantined until the 

discrepancy is resolved with the generator. Upon resolution of the discrepancy, the waste 

will be moved to an appropriate storage cell by the end of the work shift.

A-4.2 Process Operations Procedures

Many of the analyses needed for the storage, treatment, and disposal functions are 

performed during incoming load identification. These are not repeated unless it is known 

or believed that the waste characteristics may have changed during storage or processing

and monitoring of the changes is necessary. Existing and anticipated process operations at 

the facility, for which current and periodic sampling and analyses is important, include 

the following:

 Storage;

 Stabilization; and

 Landfill disposal.

The analytical procedures for each of these processes are described separately below. 

A-4.2.1 Storage

When waste is received at the ACE facility, a verification analysis is performed to determine 

its physical and chemical properties (e.g., pH, flammability, etc.). ACE site management will 

review the results of the verification analyses to determine the safe management of waste 

to be placed in storage.

Based on the verification analysis, the site management will determine the compatibility of 

the waste with the storage unit materials of construction and with wastes already stored 

therein. In addition, stored containerized liquid and solid wastes will be segregated with 

respect to ignitability, reactivity, corrosivity, and compatibility. Liquid wastes which are 

transferred from drums, portable tanks or tank trucks may be bulked and placed in bulk 

storage prior to further treatment.

Waste in Containers (Drums). Stored containerized wastes are segregated with respect

to ignitability, corrosivity, reactivity, and compatibility. Appendix V of Part 265, as well 

as the U.S. Department of Transportation (DOT) Hazardous Precedence List (49 CFR Part 

173.2) and the Segregation and Separation Chart of Hazardous Materials (49 CFR Part 

177.848), shall be employed for the initial determination of compatibility. The following 

table lists DOT hazard classes with incompatible hazard classes for wastes in drum 

storage areas.

NOTE: Some portions of Section A-4.2 have been removed in order to shorten the overall length of this 

example WAP. This was done solely for purposes of presentation in this guidance document.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-17

TABLE A-4: Incompatible Hazard Classes

Hazard Class Incompatible Hazard Classes

Flammable Liquid

Flammable Solid 

Oxidizer or Organic

Peroxide 

Corrosive

Oxidizer, Organic Peroxide 

Corrosive, Oxidizers 

Corrosive, Flammable Liquid,

Flammable Solids 

Oxidizer, Organic Peroxide Flammable Solids

Based on the initial hazard determination and final identification of the waste, the 

drummed waste is organized into segregated storage areas. Flammable, corrosive and 

oxidizing waste materials are kept separate from incompatible materials by storage in 

separated, walled off/bermed areas within the drum storage unit.

Waste in Tanks. Liquid wastes delivered in bulk form by tank trucks or decanted from 

drums or portable tanks are placed in bulk storage tanks or directly into reactors prior to 

further treatment. Prior to transferring any different waste(s) into a storage tank, the 

compatibility of the waste with the material already in the tank will be determined by the 

liquid waste compatibility test. Following routine screening, specific storage and process 

compatibility will be determined. The parameters that will be used to determine 

compatibility are as follows:

 Stratification – The general miscibility of the materials will be examined. If 

stratification would appear to create a problem, the materials will not be combined.

 Heat Generation – Materials that upon mixing would generate sufficient amounts of 

heat or undergo exothermic reactions strong enough to exceed the design capability of 

the storage unit shall not be combined.

 Gas Evolution – Materials that upon mixing liberate flammable, explosive or toxic 

vapors, fumes or mists in quantities of concern, shall not be combined unless the 

storage unit is designed with appropriate engineering controls.

 Undesirable Reactions – Materials that upon mixing result in the formation of a large 

amount of precipitate or in the solidification or gelling of the mixture shall not be 

combined.

A-4.2.2 Stabilization

For the purpose of this discussion, treatment will include, at a minimum, stabilization of 

waste, and in some instances, will include a pre-treatment step prior to stabilization. The 

pre-treatment may include using other reagents such as oxidizing or reducing agents to 

chemically convert constituents into a form more suitable for stabilization. 

Incoming wastes to be stabilized before disposal will be subjected to the mandatory 

verification. The pre-treatment analyses also will include a bench scale development of a 

recipe suitable for achievement of these standards. This recipe will be analyzed using the 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-18

appropriate test method (e.g. TCLP, etc.) to demonstrate that the LDR waste can be 

treated to meet the appropriate standard of prohibition and to establish the treatment 

guideline to be used on the waste. In addition, compression strength testing may be 

performed to demonstrate the strength of the treated waste. The treatment guidelines, 

established during the procedure, demonstrated to achieve the appropriate treatment 

standard, will be used to treat that LDR waste. In lieu of bench scale recipe development a 

previously developed and established recipe may be identified for use (e.g., recipe 

utilized on a similar waste).

Stabilization operations may involve combining multiple waste streams or shipments, i.e., 

to optimize treatment volume. Wastes to be combined will be selected based on their 

chemical matrices, EPA codes and recipe requirements. For waste tracking purposes, the 

treatment residue will carry all waste stream identities (profile numbers and shipment 

identities, i.e., work order number, manifest number, etc.). For batches with multiple EPA 

codes, the combined most restrictive standards will apply to the treated residue.

A-4.2.3 Landfill Disposal 

A sampling/analysis program is an integral part of this phase of operation. The results of 

this program serve to evaluate compliance with site permit conditions, confirm disposal 

method selection, and determine safety constraints. Incoming wastes for which the 

generator or treater has certified compliance with the LDR standards, as well as batches 

that have been stabilized onsite by ACE facility, will be subjected to the “Suitability for 

Landfill” analyses. See Table A-1 in Section A-4 for these analyses. The “Suitability for 

Landfill” testing is conducted to assure that the treatment process continues to be effective 

in meeting the treatment standards. 

For wastes that have been stabilized by ACE onsite, each batch will be analyzed for Landfill 

Suitability.

For stabilized waste that is shipped to ACE for which the generator or treater has certified 

full compliance with LDR treatment requirements, each shipment will be analyzed for 

Landfill Suitability (i.e., 100% testing of shipments). This frequency can be decreased if 10 

successive shipments or batches meet all applicable LDR standards. Specifically, it can be 

decreased such that 1 in 10 shipments is analyzed for all required parameters and every 

shipment is analyzed for an indicator parameter to confirm treatment effectiveness.

However, if any shipment fails to meet the treatment standards post-treatment, 100% 

testing must be resumed until 10 successive shipments meet all applicable LDR standards.

ACE will identify the specific offsite sources and waste profiles associated with the failed 

shipment and ensure that 100% testing is applied to them.

An Additional Review Program (ARP) is used to further monitor incoming waste shipments 

destined for the ACE facility landfill. Ten percent of shipments per month will be selected 

randomly by on-site personnel as requiring additional review (not to exceed 20 

shipments/month). In addition onsite personnel may request additional review using the 

sampling and analytical protocols from the ARP listed in this permit. Any additional request 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-19

will be justified by the state Director in writing. For the bulk solids, a composite will be 

taken as described in Section A-8. The sample will be of sufficient volume to allow a split 

sample to be supplied to the state Director. If a shipment of containers is selected, a 10% 

composite of each profile destined for the ACE facility landfill on the load may be identified 

for additional review. Further compositing of similar waste streams may be allowed with 

state Director approval.

The Additional Review Program (ARP) samples are analyzed as follows: 

RCRA Hazardous Wastes with Numerical (Concentration Based) LDR Treatment Standards

 Sample will be analyzed for constituents listed for each EPA code associated with the 

shipment for which numerical LDR standards have been promulgated. Additional 

analyses may be requested by site management if justified, to address areas of concern. 

Examples of these analyses include:

– TCLP metals

– PCB

– Volatiles

– Semivolatiles

 Wastes that are to be stabilized on-site will have their compliance with LDR standards 

verified according to the frequency specified in this WAP.

 Loads destined for stabilization will be managed under site SOP for testing stabilized 

residuals. Loads not requiring stabilization will be tested for LDR TCLP metals and 

volatiles (e.g., Method 8240) with routine site detection limits. Other organics of 

concern may be requested based on agreement by site management and state Director.

 Due to the extensive listing of constituents, F039 ARP samples will be tested for routine 

volatiles, semivolatiles and the characteristic TCLP metals.

Non-Hazardous Waste and Waste Without LDR Standards

 TCLP metals: lead cadmium and chromium -these are very frequently found industrial 

metals and a broad random screen is justified. The other five regulated TCLP metals 

may be requested by site management if there is a concern about their presence based 

on information on the waste profile.

 PCB oil bearing waste as determined by a review of the waste profile will be tested.

 2% Organic Limit Analysis (OLA) - a GC/FID screen is run for priority pollutants except 

on oil bearing wastes. If petroleum hydrocarbons are identified in the scan, they may be 

quantified by calculation as nonane. GCMS analysis may be used for confirmation as 

needed. Alternately, other approved organic analysis methods, such as volatiles by 

GCMS may be used to determine the concentration of the organic constituents. Organic

analysis to verify < 2 % is not required if the state Director has authorized a higher 

percentage on a case-by-case basis as prescribed.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-20

If unexpected results are obtained during the ARP testing, the generator will be contacted 

and we will attempt to resolve the issues. Questions will be raised as to the appropriate 

hazard code classification and application of LDR standards. An update of the profile and 

the disposal decision may be considered. If the analysis indicates that LDR standards have 

been exceeded for wastes that are either stabilized elsewhere or certified as meeting the 

treatment standards as generated, it shall be reported to the state Director.

No Free Liquids in Landfills

Under no circumstances will ACE allow the placement of bulk or non-containerized liquid 

hazardous waste or hazardous waste containing free liquids in its landfill. ACE site 

management will visually inspect each container to ensure that no free liquids are present. 

If free liquids are detected, the facility will perform a paint filter test (or comparable test

required by the state) to confirm the absence or presence of free liquids. If the test 

indicates their presence, ACE will remove them and perform the test again if necessary. 

ACE site management also will determine the cause of the free liquids and make needed 

adjustments to ensure they do not occur again.

A-5 Restricted Wastes

ACE does not accept, for treatment or disposal, any current

production waste or outdated products which are listed as

hazardous waste by EPA because it contains, as a

hazardous constituent (see 40 CFR Part 261, Appendix VII), a form of polychlorinateddibenzo-dioxin (PCDD) or polychlorinated-dibenzo-furan (PCDF) (e.g., F020, F021, F022, 

F023, F026, F027, etc.). 

ACE also does not accept:

 Radioactive wastes.

 Military or civilian ordnance.

 PCB wastes, as defined by TSCA (greater than or equal to 50 ppm).

 Gaseous wastes in high-pressure cylinders.

A-6 Rejection Policy

The purpose of this section is to set forth the policy and 

procedures that ACE will use for the acceptance or 

rejection of waste received by the facility.

This is not a mandatory WAP 

element under 40 CFR 264.13.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-21

A-6.1 Authority

ACE site management has the responsibility of insuring that the appropriate testing of each 

incoming shipment of waste has been performed. They have the authority for acceptance 

or rejection of each shipment.

A-6.2 Safety

The transporter delivering waste to the facility will abide by ACE’s safety and operational 

rules and regulations. Transporters will use trucks equipped with safety items and other 

necessary equipment so the unloading of the materials can be accomplished safely.

Inadequate or unsafe equipment is reason for rejection of any shipment.

A-6.3 Scheduling

All incoming shipments of alternative fuels must be scheduled with ACE in advance. A 

shipment arriving without the necessary pre scheduling may be rejected or significantly 

delayed.

A-6.4 Documentation

All shipments of incoming waste materials may be accompanied by: 

 A manifest that complies with state and federal hazardous waste regulations. 

 Any other documentation required for the transport of said materials to the facility. 

Incoming shipments arriving without the necessary documentation may be rejected. 

Exceptions to this case may exist if material handled is shipped by rail and the manifest is 

mailed separately.

A-6.5 Notification

In the event that an incoming shipment must be rejected, the onsite personnel will give 

notification to the following entities:

 ACE site management

 Generator 

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

PART FOUR: Sample WAPs 4-22

A-6.6 Rejection

A rejected shipment at ACE’s facility shall be returned to the generator or the generator’s 

designated alternate facility. The generator will be notified that the shipment has been 

rejected.

A-7 Discrepancy Resolution

As used in this WAP, a “discrepancy” is either:

 A manifest discrepancy per 40 CFR 264.72, which 

includes significant differences between the quantity or 

type of waste designated on the manifest or shipping 

paper, and the quantity or type of waste the facility actually receives (described further 

below); rejected waste; and container residues. Significant differences include:

– For bulk wastes, variations > 10% difference in weight.

– For containerized waste, variation in piece count.

– Variations in type discovered by inspection or waste analysis.

 A discrepancy between the chemical or physical properties of a waste received at the 

facility and its waste profile (e.g., pH that falls outside of its tolerance limits, 

flammability, etc.). Refer to Section A-9 of this WAP for information on the parameters 

verified for incoming shipments and examples of discrepancies.

A-7.1 Manifest Discrepancy

All attempts will be made to resolve manifest discrepancy issues with the generator.

Resolution will be noted in the operating record. Unresolved discrepancies will be 

submitted to the Regional Administrator by letter within 15 days from receipt of the 

incoming shipment.

There may be situations where ACE will accept unmanifested waste shipments. Please refer 

to 40 CFR 264.76.

A-7.2 Discrepancies Between Waste 

Received at Facility and Waste Profile

If a discrepancy between the waste received at the 

facility and its waste profile is identified, ACE will 

perform the following before acceptance: 

Discrepancies

Include provisions in the WAP for both 

resolving discrepancies and ensuring 

they do not recur, such as determining 

if a new or revised waste profile is 

needed and requiring the generator to 

submit a corrective action plan.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-23

 The generator is notified and requested to supply additional knowledge to assist in the 

resolution of the concern(s). If the generator supplies information that alleviates the 

concern(s) identified, no further action is required.

 The ACE site management and the generator discuss the discrepancy issue and identify 

the appropriate course of action to resolve the container/shipment in question, i.e., pick 

another sample set, return the container/shipment, divert the container/shipment to 

another TSD unit that can accept the container/shipment and resolve the issue, or the 

generator resolves the issue at the TSD unit. If the discrepancy issue(s) results in the 

failure of a shipment, the chemical screening frequency for all streams that could 

exhibit a similar issue(s) from the generator are adjusted to 100 percent until the 

issue(s) adequately can be addressed. 

 On resolution of the initial discrepancy issue, ACE site management requests the 

generator to provide a corrective action plan (CAP) that clearly states the reason for the 

failure and describes the actions to be completed to prevent re-occurrence. The 

generator could request a reduction in verification of additional streams that the 

generator believes are unaffected. This request must be accompanied by a justification 

that identifies why this stream(s) would not exhibit the same discrepancy issue.

 ACE site management reviews the CAP and stream justification for adequacy. If the 

stream justification is adequate, ACE site management could provide an alternative 

frequency. ACE site management documents these actions and keeps this 

documentation in the operating record in accordance with Section A-12.

A-8 Sampling Methodology

Sampling is performed by the ACE facility and by (or as directed by) the waste generator at 

the generator’s facility. Specific sampling procedures are dependent on both the nature of 

the material and the type of containment. SW-846 states that, “a less comprehensive 

sampling approach may be appropriate if information regarding the distribution of waste

components is known or assumed.” This section presents sampling methodologies to be 

utilized on-site by ACE personnel.

When a waste arrives at the facility for management, a determination has previously been 

made by the generator that the waste is either:

1. a listed hazardous waste in 40 CFR Part 261, Subpart D; 

2. a characteristic waste as defined in 40 CFR Part 261, Subpart C; or

3. a non-hazardous waste.

The generator-supplied characterization provides ACE with information concerning both 

the distribution and nature of the waste components (see Section A-2 for discussion

NOTE: Some portions of Section A-8 have been removed in order to shorten the overall length of this example 

WAP. This was done solely for purposes of presentation in this guidance document.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-24

regarding the information or data to be supplied by the generator). The purpose of the 

inspection, sampling or analysis when a waste material arrives at the site is to ensure that 

the shipped waste matches the description of the waste designated on the accompanying

manifest or shipping paper and WPS.

Therefore, ACE can often use a less comprehensive sampling approach, as described in 

Sections A-8.2.1, to yield a waste identification sample (see EPA documents SW-846 “Test 

Methods for Evaluating Solid Waste”, Third Edition, September 1986, Chapter Nine).

A-8.1 General Methods and Equipment

As practicable, the sampling techniques used for specific types of waste correspond to

those referenced in 40 CFR 261, Appendix I and presented in Table A-5. Because Appendix I 

sampling methods have not been formally adopted by the EPA Administrator, ACE may 

modify the technique as necessary to obtain a representative sample. Any changes made 

after final permitting will be forwarded to the state Director for review and acceptance. The

sampling equipment and procedures described in this WAP represent the facility’s 

recommended sampling protocol for general types of waste material and containment.

Specific waste materials or shipments may require different sampling techniques.

Therefore, deviations from the recommended protocol do not constitute an excursion from 

acceptable sampling practices or the conditions of this WAP. All methodologies will be 

updated and revised as the references are updated and revised.

A-8.2 Specific Methods and Equipment

In addition to ASTM and EPA sampling procedures, ACE has instituted specific

methodologies for taking samples from various containment sources. The type of container

may be transportable (e.g., such as drums), portable transport units (e.g., tanks, roll-off 

boxes), and tanker or dump trucks; or stationary, such as tanks, in-process sources, waste 

piles, and containments. The sampling devices are selected depending on the size and type 

of containment and on the specific material involved. The device to be used in each 

situation is described below.

Access to any type of container will influence the location within the container from which 

samples can be taken. Samples will be taken to address vertical variations in the waste 

because there is a much greater tendency for wastes to be heterogeneous in a vertical 

rather than a horizontal direction, and horizontal variations are generally easier to detect if 

examination indicates strata in the waste, then each layer may be composited in proportion 

to its estimated volume or sampled individually.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-25

TABLE A-5: Sampling Methods and Equipment

Material (or waste type) Method Equipment

Extremely viscous liquid 

Crushed or powdered material 

Soil or rock-like material 

Soil-like material 

Fly ash-like material 

Containerized liquids

ASTM Dl40a

ASTM E300 a

ASTM D346 a

ASTM E300 a

ASTM D420 a

ASTM E300 a

ASTM D1452 a

ASTM E300 a

ASTM D2234 a

ASTM E300 a

SW-846B or

ASTM E300 a

Tubing, thief or Coliwasa

Tubing, trier, scoop, or shovel

Tubing, trier, auger, scoop, or shovel

Tubing, trier, auger, scoop, or shovel

Tubing, trier, auger, scoop, or shovel

Coliwasa, tubing, weighted bottle, 

bomb, or tank sampling port

a American Society for Testing Materials. Annual Book of ASTM Standards. Philadelphia, PA. 1982 or most recent edition.

b Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Third Edition, U.S. Environmental Protection Agency, Office 

of Solid Waste, Washington, DC, September 1986, as amended by all recent updates.

A-8.2.1 Containers and Tanks

A container is a portable device in which a material is stored, transported, treated,

disposed of, or otherwise handled. The sampling of small containers (e.g., drums, cartons,

and other small units) varies with the physical nature of the waste material. For

flowable materials, the sampling device of choice is either a Coliwasa unit or open tube

sampler, which is used to draw a full vertical section. Drums of aqueous and organic 

liquids are sampled with a four foot glass tube. A composite sample may be obtained by 

mixing equal portions of each container included in the sampling lot. Solids or sludges or

other small containers are sampled with a scoop (disposable plastic or using the bottle

itself) or a shovel if a heavy digging tool is required. If the material on top appears nonrepresentative (e.g., “speedi-dry, “oil dry”, etc.), a subsurface sample will be obtained. The 

top portion may be transferred to another container in order to obtain a subsurface

sample. Alternately, a metal sample thief, trier or tubing (a piece of conduit or small

diameter pipe) may be used to obtain a core sample of the drummed solid.

A-8.2.2 LDR “Grab” Sampling

The Land Disposal Restrictions, 40 CFR 268, have specified the use of “grab” sampling for

most of the compliance demonstrations to the Land Disposal Restrictions BDAT treatment 

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

PART FOUR: Sample WAPs 4-26

A-9 Parameters and Analytical Methods

The parameters which constitute the analyses performed by ACE facility are identified in 

Table A-6. ACE will use either SW-846 or ASTM methods for each parameter, as shown in 

the table. ACE has its own laboratory SOPs which the laboratory follows. The analytical 

parameters and techniques used by ACE through its operating experience have been

chosen for their ability to provide the information required to properly manage a waste.

TABLE A-6: Analytical Parameters, Reference Methods, ACE Method, and Rationale

Parameters Reference Methods ACE Method # Reason

Physical Description Not applicable Visual Inspection Verification and system 

compatibility

pH Screening

SW-846 9045

ASTM D4980 ACE-4

Verification and system 

compatibility

PCB Screening

SW-846 3580

SW-846-8000

SW-846 8082

ACE-3 Prohibited material

Suitability for LandfillaSW-846 1311 ACE-6

Verification and system 

compatibility

Water Screening Mix ASTM D4982 ACE-10 Verification and system 

compatibility

Flammability Potential Screening ASTM 505 ACE-7

Verification and system 

compatibility

a

Suitability for Landfill involves mandatory verification, a leachable metals assessment if the waste contains metals, as well as additional tests 

if needed (e.g., tests for cyanides). This row of the table addresses only to the leachable metals assessment (i.e., Toxicity Characteristic 

Leaching Procedure).

Following is a discussion of the method(s) and rationale for each parameter:

 Physical Description is used to determine the 

general physical characteristics of the waste 

(e.g., color, waste form). This facilitates 

subjective comparison of the waste with prior 

waste descriptions or samples.

 pH Screening is undertaken to indicate the 

pH range and the general corrosive nature of 

the waste. pH screening may not apply to 

certain waste types, e.g., organic waste, or insoluble solid waste. For each approved 

waste stream, tight tolerance limits (e.g., +/- 2 pH unit change) will be established 

based on the operating requirements of the relevant treatment and disposal systems 

at the facility and other relevant considerations. If the pH of an incoming shipment 

NOTE: The text and table in this section have been shortened in order to reduce the overall length of this 

example WAP. This was done solely for purposes of presentation in this guidance document.

Tolerance Limits for Fingerprint Tests

The purpose of the fingerprint tests is to 

verify that the shipment matches its 

manifest and waste profile. Consider 

establishing tolerance limits for one or 

more parameters such that verification can 

be made objectively (see pH screening).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-27

falls outside of this range, re-qualification will take place to review the waste and 

update its WPS.

 PCB Screening is used to ensure that no materials are stored or used at the facility that 

would require a Toxic Substances Control Act permit. PCB wastes, as defined by TSCA 

(greater than or equal to 50 ppm), will not be accepted at the facility.

 Suitability for Landfill is a testing program that assesses the acceptability of the 

stabilized waste for land disposal. All stabilized wastes to be disposed of in the ACE 

landfill are subjected to mandatory verification, a leachable metals test if applicable, as 

well as additional tests deemed appropriate. Waste streams that are to be land disposed 

after being stabilized are classified into general categories.

1. Inorganic solids and sludges with no RCRA metals (e.g., calcium fluoride, sulfate, and 

phosphate mixture)

– Mandatory verification.

2. Inorganic process sludges and solids with metals (e.g., WWT sludges with F and 

D codes)

– Mandatory verification.

– Leachable metals assessment. 

3. Soil or other inorganic solids with metals (e.g., fly ash with lead, 0 code materials)

– Mandatory verification.

– Leachable metals assessment.

4. Inorganic solids with cyanide, which may include metals (e.g., potliner)

– Mandatory verification.

– Leachable metals assessment may be performed.

– If cyanide screening is positive, analyze for cyanides amenable to chlorination or 

total cyanide to determine whether the waste qualifies for land disposal.

 Water Mix Screening is used to determine whether the waste has a potential to 

vigorously react with water to form gases or other hazardous products, or whether it 

generates significant heat. This testing does not apply to wastes that are already in 

contact with excess water, or for which sufficient analytical data exist that indicate no 

potential reactivity with water.

 Flammability Potential Screening is used to indicate the fire-producing potential of 

the waste. This testing can be applied to all waste liquids, semi-solids, but need not be 

applied if other information (e.g. WPS in conjunction with the results of the other 

screens, SDS, etc.) indicates the waste is not ignitable.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-28

A-10 Quality Assurance /Quality Control

A-10.1 Introduction

The following Quality Assurance/Quality Control (QA/QC) 

information for the ACE facility is being provided as 

required by 40 CFR 270.30(e) and in accordance with the 

following EPA guidance documents.

QA/QC procedures are applicable to both sampling procedures and analytical techniques. 

QA/QC information for these two elements of the waste analysis program has been 

included in this Waste Analysis Plan (WAP) as recommended in the waste analysis plan 

guide manual.

This section does not provide specific performance standards or quality control procedures 

for individual sampling and analysis techniques. Such specifics are defined on a corporatewide basis for all ACE facilities. The specific performance standards are dynamic and are 

revised as warranted to reflect technological advances in sampling and analytical 

techniques. ACE QA/QC policies are found in the corporate Quality Assurance and Control 

Policies, portions of which have been extracted and included in the following sections. The 

performance standards will be available for review at the facility.

A-10.2 Sampling Program

Sampling procedures for specific facility operations are described in Section A-8 of the 

WAP. The selection of the sample collection device depends on the type of sample, the 

sample container, and the sampling location. The selection and use of the sampling device 

is supervised by the QA Manager, who is thoroughly familiar with both the sampling and 

analytical requirements. The type of device to be used in the various sampling situations is 

specified in Section A-8.2, Specific Methods and Equipment.

Sampling equipment is constructed of non-reactive materials such as glass, PVC plastic, 

aluminum, or stainless steel. Care is taken in the selection of equipment to prevent 

contamination of the sample and to ensure compatibility of materials. The specific material 

of construction to be used for each sampling activity is specified in Section A-8.2.

Sampling is performed for each waste stream in a manner that ensures the samples are as 

representative as possible under the conditions of the sampling event. Full vertical sections 

are drawn from tanks and containers, where appropriate and where access allows, as 

described in Section A-8.2.

With a few exceptions, all bulk and containerized waste loads will be sampled (see Section 

A-4). Container samples that are related to one generator and waste profile may be 

composited prior to analysis, provided that individual samples are similar in physical 

appearance. Precautions are taken to minimize loss of volatiles.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-29

All samples must be appropriately labeled. No field notebook is used in sampling 

hazardous waste shipments or process samples. Anything unusual noted during sampling 

would be noted in the comments area of the label. No chain of custody form is employed 

within the plant. The samples are turned directly into the lab. A chain-of-custody will 

accompany any sample being sent to a contract lab. Sampling information is entered into 

the facilities operating record.

Hazardous waste samples are generally not amenable to preservation. For samples 

collected at ACE for organic analysis, the preservation and holding times will be in 

accordance with Chapter 4 of SW-846. Samples for 2% Organic Limit Analysis screen will 

generally be analyzed within 14 days. For treated wastewater samples from the plant, 

metals aliquots are preserved by the addition of HNO3 to pH <2 and cyanide aliquot is 

preserved by the addition of NaOH to pH > 12. After TCLP extraction for leachable metals 

an aliquot for metals is fixed by adding HNO3 to pH < 2.

A-11 Data Reporting

ACE will report discrepancies to EPA if they are not 

resolved within the timeframes specified at 40 CFR 264.72.

In addition, ACE will supply any analytical data to EPA 

when requested. This includes the following information, which must be kept at the facility:

 Receiving Papers – Date, time, sample ID, customer name, stream ID, and sample 

receipt/delivery.

 Worksheet Raw Results – For each test (instrument readings, sample weights, etc.), 

date, initials of analyst, and sample ID.

 Sample Master Logbook – Date, sample ID, type, initials, result, etc.

 Calibration and Performance Sample Results – Initials, result, results of calibrations, 

duplicates, known standards, blanks, blind samples, and reference samples. QC results 

are compiled and each set of results will be compared with QC limits, and records 

should show the basis for QC limits.

 Instrument Maintenance and Repair Record On the Following Analytical Systems

– ICPs, GCs, calorimeters, ion chromatographs, and Hg analyzer.

A-12 Recordkeeping

ACE maintains the Laboratory Data Management System 

(LDMS) to automate the waste disposal process using 

comprehensive application software packages. The system 

automates the major aspects of waste treatment and disposal (waste analysis data, 

discrepancies, corrective actions, etc.) to improve the efficiency and minimize data errors.

This is not a mandatory WAP 

element under 40 CFR 264.13. 

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-30

Waste tracking, laboratory data management and process control interface are major 

components of waste disposal that are automated by the LDMS.

A complete set of records will be maintained at the facility for each generator, including 

information generated during pre-acceptance, acceptance, and waste treatment. This 

information will include, but not be limited to:

 WPS

 Pre-qualification analysis

 SDSs (if available)

 Generator laboratory analysis (if available)

 Sample log sheets

 Photocopy of each manifest

 Records demonstrating compliance with, and decisions made under the analyses 

performed by ACE facility. In particular, a record of all analyses will be maintained by 

ACE for each waste sampled/analyzed, as part of the facility operating record. The 

mandatory and supplemental analyses records will include:

– A copy of the chain of custody document

– Copies of all applicable analytical and test results and lab reports including the 

results of the mandatory analysis 

– A copy of the original (incoming) manifest

– A copy of the original WPS

– Documentation of any discrepancies identified by verification analyses

– If applicable, a copy of any written or correspondence with the generator related to 

resolving a WPS discrepancy and documentation of relevant conversations with the 

generator regarding same.

– If applicable, copies of any written correspondence with the generator and state 

Director related to resolving a manifest discrepancy and documentation of relevant 

conversations with the generator or state Director regarding same.

– If applicable, a copy of the revised WPS

 Records documenting ACE’s records to resolve discrepancies between an incoming 

waste and its waste profile.

In addition, ACE will produce bi-annual reports that 

summarize the following for state inspector review:

 The frequency at which incoming shipments do not 

conform to their waste profiles. The report must

indicate the steps taken by the facility to evaluate 

and resolve the discrepancies, including if new or 

revised WPSs were produced.

Facility-Prepared Reports

When preparing the WAP, include 

provisions to assist regulators during 

compliance inspections, such as 

facility-prepared reports summarizing 

key problems and difficulties 

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

PART FOUR: Sample WAPs 4-31

 The frequency at which treated wastes do not meet the LDR treatment standards. The 

report indicates the steps taken by the facility to evaluate the incoming wastes and 

treatment process to resolve failures.

All waste analysis records will be kept as a part of the facility operating record and will be 

maintained as required by law.

A-13 Corrective Action

While the goal of the ACE QA/QC program is to provide 

sufficient training, equipment, facilities, technical support, 

and supervisory oversight to avoid inadequate 

measurements or data, it is recognized that data quality can fall outside established limits for 

a variety of reasons. The program provides for reporting and reviewing procedures that 

permit early and effective corrective action should it be needed. Specifically:

 All samples are registered and tracked via an electronic Laboratory Data Management 

System (LDMS) to ensure that the necessary analyses are performed. 

 Data generated each day are entered into appropriate logbooks and the LDMS tracks 

each sample. These systems provide an opportunity for quick review of the data to see 

if the various results are internally consistent. Apparent discrepancies are brought to 

the attention of site management.

The site management reviews completed data information on all samples prior to shipment 

receipt. This data is then filed for future reference.

If problems are found, several corrective actions are considered depending on the apparent 

source. These include, but are not limited to:

 Re-sampling

 Re-analysis of the sample

 Performance audit of the analyst

 Systems audit

 Inter laboratory comparison study

 Review of SOP for error or inadequacy.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-32

Appendices

Appendix A-1 Waste Profile Sheet

The waste profile sheet (WPS) has been removed from this WAP. See Figure 2-9 of this 

manual for an example of a WPS.

Appendix A-2 Overview of the Pre-Acceptance Process

The overview has been removed from this WAP. See Section 1.2 of this manual for a 

discussion of the pre-acceptance process.

Appendix A-3 Overview of the Incoming Load Process

The overview has been removed from this WAP. See Section 2.9 of this guidance for a 

discussion of procedures for handling incoming loads.

Appendix A-4 Aqueous Waste Treatment

The diagram of aqueous waste treatment has been removed from this WAP.

Appendix A-5 Landfill and Stabilization

The diagram of landfill and stabilization has been removed from this WAP.

NOTE: The information in the appendices has been omitted to reduce the overall length of this example WAP.

This was done solely for purposes of presentation in this guidance document.

NOTE: The information in the appendices has been omitted to reduce the overall length of this example WAP. 

This was done solely for purposes of presentation in this guidance document.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-33

Example WAP 2: Waste Analysis Plan of 

Container Management Incorporated (CMI)
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-34

4.

Table of Contents

1.0 General Overview........................................................................................................ 4-36

2.0 Waste Prequalification Procedures.............................................................................. 4-37

2.1 Waste Information Profile (“WIP”) ................................................................................................ 4-37

2.2 Determination of Outbound Designated Facility............................................................................ 4-38

2.3 Lab Pack Waste............................................................................................................................. 4-38

3.0 Acceptable Waste Codes ............................................................................................. 4-38

4.0 Analysis and Acceptance.............................................................................................. 4-38

4.1 Level I Analysis.............................................................................................................................. 4-40

4.2 Level II Analysis:............................................................................................................................ 4-41

4.3 Level III Analysis:........................................................................................................................... 4-42

4.4 Final Acceptance and Placement of Waste in Storage.................................................................... 4-43

5.0 Restricted Wastes........................................................................................................ 4-43

6.0 Rejection Policy ........................................................................................................... 4-43

7.0 Discrepancy Policy ....................................................................................................... 4-44

7.1 Manifest Discrepancies................................................................................................................. 4-44

7.2 Discrepancies Between the Waste and WIP................................................................................... 4-45

8.0 Outbound Waste Screening Procedures...................................................................... 4-45

9.0 Waste Sampling ........................................................................................................... 4-46

9.1 Sampling Methods........................................................................................................................ 4-46

9.2 Sample Tracking Documentation................................................................................................... 4-46

9.3 Sampling Personnel....................................................................................................................... 4-46

9.4 Sample Labels............................................................................................................................... 4-47

10.0 Parameters and Rationale ........................................................................................... 4-47

11.0 Test Methods............................................................................................................... 4-48

12.0 Quality Assurance and Quality Control ....................................................................... 4-52

12.1 Sampling Program......................................................................................................................... 4-52

12.2 Analytical Program........................................................................................................................ 4-52

12.3 Conclusion.................................................................................................................................... 4-53

13.0 Recordkeeping and Reporting ..................................................................................... 4-53

14.0 Corrective Action ......................................................................................................... 4-54
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-35

Appendices........................................................................................................................... 4-55

Appendix C: Standard Operating Procedures for Opening and Sampling Containers................................. 4-56

Appendix D: Bulk Consolidation Tracking Sheet ....................................................................................... 4-57

Appendix F: Example Level I QA/QC Report............................................................................................. 4-58

Appendix G: Level II/III QA/QC Checklist.................................................................................................. 4-59
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-36

1.0 General Overview

Pursuant to 40 CFR 270.14 (b)(3), a hazardous waste 

management facility is required to develop and follow a 

Waste Analysis Plan (WAP) that meets the requirements of 

40 CFR 264.13 (b) and (c). This waste analysis plan establishes the following:

 The procedures for qualifying, accepting and analyzing the contents of each waste 

container managed at Container Management Inc. (“CMI”).

 The waste analyses and supplemental information that hazardous waste generators or 

their authorized agent (customers) will supply.

 The frequency at which analysis of waste will occur to ensure that waste is 

characterized accurately.

 Procedures for handling discrepancies and rejected shipments.

 The methods used to obtain a representative sample of waste to be analyzed.

 The parameters for which each waste will be analyzed and the rationale for selecting 

these parameters.

 The test methods used to test for each parameter.

 A quality assurance/quality control (QA/QC) program for waste sampling and analysis, 

along with a corrective action program.

 The recordkeeping and reporting procedures associated with this WAP.

Emphasis is placed upon obtaining accurate information about the chemical and physical 

makeup of each waste received by CMI. This information, which is to be detailed in a wastespecific Waste Information Profile (WIP) maintained as part of the facility record, may be 

based on the generator knowledge of the waste and/or chemical and physical analyses of a 

representative sample of the waste.

CMI accepts “containerized” and “bulk” waste for storage prior to consolidation and/or 

shipment off-site. Wastes managed by CMI may be regulated under the Resource 

Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA), 

Superfund (CERCLA), and the state’s Hazardous Waste Management Regulations (HWMR). 

CMI accepts wastes in a variety of physical forms, including liquids, sludges, solids, and 

compressed gases. For the purposes of this WAP, “containerized” waste is waste managed 

in containers that can be moved manually or with a forklift (e.g., U.S. Department of 

Transportation (“U.S. DOT”) approved shippable containers, drums, pails, bags, boxes, 

pallets, ton sacks, flasks, cylinders). “Bulk waste” is received and shipped in accordance 

with applicable U.S. DOT regulations.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-37

CMI also accepts “lab packs” which are containers that hold a variety of chemicals, products 

or small quantities of laboratory samples. Each lab pack container is prepackaged in 

accordance with applicable U.S. DOT regulations that are based on compatibility, content, 

and size of individual samples. An inventory-packing list accompanies each lab pack 

container and identifies, among other things, the content, quantity and size of each 

container within the lab pack, and applicable RCRA and state-specific hazardous waste 

code(s). See Appendix B of this WAP for an example Lab Pack form.

CMI also accepts “bulk or consolidation packs” that are containers that hold one type of 

material (e.g., paints). Each bulk or consolidation pack container is prepackaged in 

accordance with applicable U.S. DOT regulations.

2.0 Waste Prequalification Procedures

All waste accepted by CMI must be approved through the prequalification process. As 

described below, the prequalification process requires completion of a Waste Information 

Profile (WIP) by the generator or their authorized agent, and review and approval of the 

WIP by CMI.

2.1 Waste Information Profile (“WIP”)

A WIP must be completed, signed and submitted by the waste generator or the generator’s 

authorized agent for each waste received by CMI. A sample of the waste may be necessary 

for prequalification purposes.

Each WIP is reviewed by CMI to determine if CMI can accept the waste. The CMI WIP form 

is included in Appendix A of this WAP. A generator may use a different WIP form, provided 

the form is reviewed by CMI and found to be equivalent to the CMI form.

Based on the sample and information provided in the WIP, a CMI Supervisor or Senior 

Waste Technician may either approve the WIP or determine that additional information is 

necessary prior to approving the waste. A WIP shall not be approved if any pertinent

section of a WIP is omitted; an inconsistency is identified on the WIP (e.g., acidic solution 

with pH 14); the generator does not provide sufficient information about the waste 

generating process and/or materials used in the process. 

In the event that a WIP is not approved, additional information (e.g. SDS) must be provided 

or the waste must be analyzed further before the WIP can be approved by CMI. The WIP 

shall document the use of generator knowledge and/or analysis in making a hazardous 

waste determination. All supporting documentation must be included with the copy of the 

WIP maintained at the CMI facility. Any completed WIP for waste that is unused “product” 

material, with the exception of household-generated wastes and waste contained within 

lab packs, must include a Safety Data Sheet. In all cases, if the CMI Supervisor or Senior 

Waste Technician is not confident that a waste has been characterized accurately, he or she 

shall not approve the WIP.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-38

Upon approval of a WIP, the CMI Supervisor or Senior Waste Technician shall ensure that 

the applicable CMI “process code” and CMI “approval code” information is added to the top 

of the WIP form. 

Each WIP must be reviewed by the generator or the generator’s authorized agent on an 

annual basis. Following this review, the generator or authorized agent must provide a 

signed statement to CMI that either certifies the waste generating process and the chemical 

and physical characteristics of the waste remain unchanged or specifies any changes to the 

waste or generating process. If a signed certification statement is not returned to CMI, the 

WIP will be canceled.

2.2 Determination of Outbound Designated Facility

As part of the prequalification process following WIP approval, the CMI Supervisor or 

Senior Waste Technician also selects a designated facility to which CMI will likely ship the 

waste after the waste has been received by the CMI facility. Selection of the designated 

facility is based on the WIP, assigned RCRA and state-specific hazardous waste codes, any 

applicable land-disposal restriction regulations, generator request/requirement, and any 

requirements or restrictions of the designated facility’s permit or license. Upon selection of 

a designated facility, approved waste may be scheduled for transport and delivery to CMI. 

2.3 Lab Pack Waste 

In addition to the prequalification requirements described in sections 2.1 and 2.2, above, 

for each lab pack waste stream, the CMI Supervisor or Senior Waste Technician must 

review and approve a packing list compiled for each lab pack container using the Lab Pack 

Contents Form (see Appendix B of this section). If any incompatible or unacceptable 

material is listed on the Lab Pack Contents Form, the generator or generator’s agent is 

given the option of either properly repacking that material or having the lab pack container 

rejected by CMI.

3.0 Acceptable Waste Codes

This facility is permitted to accept the vast majority of 

RCRA hazardous waste codes in the state’s Hazardous 

Waste Regulations. See Part A of this permit for a full list of 

the codes that CMI is permitted to accept.

4.0 Analysis and Acceptance

When a shipment of waste (containerized waste, bulk waste, and/or lab packs) arrives at 

the CMI facility, a CMI Supervisor or Senior Waste Technician is responsible for either 

receiving or rejecting the waste upon completing the following procedure:

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-39

 Review the manifest or shipping paper for accuracy and completeness

 Unload containers to the CMI waste receiving area (i.e., Cell A-1)

 Check container labels for completeness and consistency with the WIP

 Check the condition of each container and verify that it is U.S. DOT-approved

 Verify that each container type is consistent with the information on the WIP, manifest 

and waste stored therein

 Assign a unique container number to each container using the facility computer system, 

and affix a sticker marked with that unique number to the container

 Perform the Level I waste analysis procedure described below

 If applicable, perform the Level II and Level III waste analysis procedures described 

below

CMI will utilize a tiered approach for analyzing incoming shipments at the facility. A Level I 

analysis will be performed on each shipment received. Level II analysis will be performed 

when the Level I analysis indicates unresolved discrepancies between the waste and its 

WIP. Level III analysis will be applied to all containers received on a periodic basis (e.g., to 

evaluate the accuracy of the WIPs maintained by CMI). Table 1 gives an overview of these 

analyses and Table 2 summarizes their frequency. Refer to Sections 4.1 through 4.3 of this 

WAP for additional information on the Level I, II and III analyses.

TABLE 1: Analyses Performed by CMI Facility

Parameters Pre-Qualification

Incoming Shipmentsa

Level I Level II Level III

% Liquid % Solid % Sludge by content X X NA NAb

Color X X NA NAb

Viscosity X X NA NAb

pH Screen, except solid and non-aqueous 

wastes

X X X X

Water Reactivity X NA X X

Reactive Sulfides Screen X NA X X

Ignitability X X

c

X X

Reactive Cyanides Screen (Spot Test) X NA X X

a. As used in this table, NA = not applicable

b. These parameters are analyzed under Level I.

c. If the evaluation of waste properties indicates that the waste is potentially ignitable, CMI will screen the waste for flash point utilizing a 

bench-top screening procedure. 

NOTE: Table 1 has been shortened in order to reduce the overall length of this example WAP. This was done 

solely for purposes of presentation in this guidance document.

NOTE: Table 1 has been shortened in order to reduce the overall length of this example WAP. This was done 

solely for purposes of presentation in this guidance document.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-40

TABLE 2: Frequency of Analysis

Pre-Qualification

Incoming Shipments

Level I Level II Level III

1.1.1 Each waste will be 

sampled, with limited 

exceptions

 Visual inspection of each bulk 

load and container

 Sampling of each bulk load

 Sampling of each container in 

a shipment, except that:

 In the case of multiple 

containers of the same 

profiled waste, 1 sample 

will be taken from 1 out of 

every 10 containers

 Samples will not be taken 

for specified wastesa

1.1.2 If Level I analysis 

identifies a discrepancy 

between the waste and 

WIP and it cannot be 

resolved with the 

generator, a Level II 

analysis is performed b

The contents of 1 out 

of every 500th 

container of waste 

(including solid and 

non-hazardous waste) 

received by CMI will 

be sampled and 

tested 

a. Exceptions are for lab packs and non-sampleable wastes (e.g., fluorescent lamps).

b. Alternatively, the waste can be rejected back to the generator or forwarded to an alternative TSDF.

4.1 Level I Analysis

The CMI Supervisor or Senior Waste Technician will open and inspect each container and 

bulk load in the waste receiving areas (i.e., Cell A-1 for containers, and within the outdoor 

secondary containment bays for bulk loads). With the exception of multiple containers of the 

same waste (i.e., waste described by the same WIP and that appear consistent upon visual 

inspection), Lab Packs, and other “non-sampleable” wastes (e.g., fluorescent lamps, batteries, 

PPE), a sample will be collected from each container and bulk load in accordance with the 

facility’s Sampling SOP (see Appendix C of this section) for the purpose of performing Level I 

analysis. In the case of multiple containers of the same waste, each container will be opened 

to visually confirm consistency between waste in the various containers, but only a single 

sample will be collected from one of every ten containers received. For lab packs, the content 

of each container is compared to the Lab Pack Contents Form.

Upon opening each container, the waste will be visually compared to information on the 

container label, manifest, and WIP. For liquids and semi-solids, a thief/tube will be used to 

check for layering and, if applicable, to determine the approximate percentage of each 

layer. The collected sample will be evaluated for the following properties:

 % Liquid, % Solid, % Sludge content (by CMI-1 method)

 Color (CMI-1)

 Viscosity (CMI-1)

 pH (CMI-2), except for solid and non-aqueous wastes
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-41

If the evaluation of waste properties indicates that the waste is potentially ignitable, CMI 

will screen the waste for flash point utilizing a bench-top screening procedure (CMI-5). 

Waste streams that are potentially subject to flash point screening include: non-lab pack 

wastes, non-virgin products, and liquid wastes that are not already characterized as 

exhibiting the characteristic of ignitability (D001). 

The results of the visual inspection and sample evaluation will be compared to the WIP. If 

the Level I analysis identifies a discrepancy with the WIP, CMI will immediately contact the 

generator or the generator’s agent and attempt to resolve the discrepancy.

Any waste that does not conform to the WIP will be quarantined in Cell A-1. If the 

discrepancy is resolved by contacting the generator, the waste will be moved to an 

appropriate storage cell by the end of the work shift. If the discrepancy cannot be resolved 

by the generator, CMI will follow the Level II procedure below, and the waste will remain 

quarantined in Cell A-1. 

Level 1 analysis is documented using the Level I QA/QC report (see Appendix F of this 

WAP). 

4.2 Level II Analysis:

If the Level I analysis identifies a discrepancy with the WIP, and the discrepancy cannot be 

resolved, then CMI will perform Level II analysis of the waste, reject the waste back to the 

generator, or ship the waste to an alternate TSDF in accordance with the Discrepancy 

Policy in Section 7.0 of this WAP. CMI will make every effort to resolve the discrepancy and 

accept the waste. The state’s Waste Management Division will be notified of any wastes 

rejected back to generators in the state, as described in the Rejection Policy in Section 6.0 

of this WAP. Level II analysis includes the following tests, as appropriate:

 pH

 Water Reactivity 

 Reactive Sulfide Spot Test 

 Ignitability 

 Reactive Cyanide Spot Test 

 Oxidizer Screen 

 Specific Gravity 

 % Suspended Solids 

 Chlorine Spot Test 

 Polychlorinated Biphenyl (PCB) Screen 

 Flash Point 

 Free Liquids/Paint Filter Test

 RCRA 8 metals

 Volatile Organics

 Any other parameter deemed necessary

Any waste that is subject to Level II analysis will be quarantined in Cell A-1 until the 

discrepancy with the WIP is resolved.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-42

Level II analysis will be subcontracted to an independent state certified or NELAC 

laboratory that uses ASTM and/or SW-846 analytical and test methods. The results of all 

Level II analyses will be documented in a log (see Appendix G of this WAP) maintained as 

part of the facility operating record.

4.3 Level III Analysis:

CMI will select and analyze waste samples received at the facility as follows:

The contents of one out of every 500 containers of waste (including solid and non-hazardous 

waste) received by CMI will be sampled and tested according to this Level III analysis 

procedure. CMI’s container tracking system will be used to identify every 500th container 

received by CMI in sequential order. In the event that the contents of the 500th container 

cannot be sampled (e.g., batteries, CRTs, lamps, lab packs, etc.), or is verified to be either an 

unused “product” material (SDS available) or household hazardous waste, CMI will count 

forward (i.e., 501st, 502nd, etc.) until a container of waste is located that can be sampled. CMI 

will document the unique container number(s) of each waste container that is by-passed in 

the facility operating record along with the rationale for by-passing each container. 

On an annual basis, CMI will review the Level III analysis procedure and the previous year’s 

Level III analysis results (i.e., testing data) to ensure that a variety of waste types and 

customers have been, and will continue to be, represented. This annual review will be 

documented in the facility operating record. Any potential changes to the Level III analysis 

procedure that are identified by CMI based on this review should also be documented in 

the facility operating record.

Once a container is identified for the purpose of conducting Level III analysis, the CMI 

Supervisor or Senior Waste Technician will collect a sample in accordance with CMI’s SOP 

(see Appendix C of this section). In addition to completing Level I analysis and 

documenting the physical description of the waste, the following parameters will be tested, 

as appropriate:

 pH

 Water Reactivity

 Reactive Sulfide Spot Test

 Ignitability

 Reactive Cyanide Spot Test

 Oxidizer Screen

 Specific Gravity

 % Suspended Solids

 Chlorine Spot Test

 Polychlorinated Biphenyl (PCB) Screen

 Flash Point

 Free Liquids/Paint Filter Test

 RCRA 8 metals

 Volatile Organics

 Any other parameter deemed necessary
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-43

Level III analyses will be subcontracted to an independent state certified or NELAC 

laboratory that will use ASTM and SW-846 analytical and test methods. 

A record of all Level II and Level III analysis will be maintained by CMI for each waste 

sampled/analyzed, as part of the facility operating record. The Level II and Level III records 

are described in Section 13.0 of this WAP.

If a WIP is determined to be inaccurate through Level II or Level III analyses, the CMI 

Supervisor or Senior Waste Technician will review for accuracy all other WIPs 

corresponding to wastes generated by the generator who submitted the inaccurate WIP.

4.4 Final Acceptance and Placement of Waste in Storage

Upon verification that a containerized waste or bulk waste is consistent with the 

corresponding WIP, the waste will be moved from the receiving area (Cell A-1) to an 

appropriate storage cell. Movement to an appropriate storage cell shall occur within the 

timeframe specified in the state regulations (e.g., 24 hours) from the transport vehicle.

Any waste that does not conform to the corresponding WIP will be quarantined in Cell A-1 

until the discrepancy is resolved with the generator. Upon resolution of the discrepancy, 

the waste will be moved to an appropriate storage cell by the end of the work shift.

5.0 Restricted Wastes

There are few restrictions on the wastes that CMI can 

accept. We cannot accept:

 Radioactive wastes.

 Conventional or chemical ordnance.

 Gaseous wastes in high-pressure cylinders.

6.0 Rejection Policy

It is the policy of CMI to follow the procedures set forth at 

40 CFR 264.72 when managing rejected loads and nonempty containers (i.e., container holding residues that 

exceed the quantity limits for “empty” containers set forth at 40 CFR 261.7(b)). Specifically, 

CMI will perform the following actions after a decision is made to reject a waste or residue:

 Obtain or confirm the generator’s directions on where to forward the rejected waste or 

residue (i.e., either back to the generator or to alternative TSDF);

This is not a mandatory WAP 

element under 40 CFR 264.13.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-44

 While the shipment is waiting to be forwarded, ensure that it is stored securely by the 

delivering transporter or by CMI . CMI will secure the waste in Storage Unit 22, which is 

a fenced area with drainage and protection from weather;

 Send the rejected waste or residue off-site within 60 days, if applicable;

 Ensure the rejected load or residue is re-manifested in accordance with 40 CFR 

264.72(f)-(g); and

 Maintain records of the above actions. Refer to Section 13.0 of this WAP for 

recordkeeping.

7.0 Discrepancy Policy

CMI will adhere to the following procedures when 

attempting to resolve discrepancies.

7.1 Manifest Discrepancies

A manifest discrepancy is defined at 40 CFR 264.72 as significant differences between the 

quantity or type of waste designated on the manifest or shipping paper, and the quantity or 

type of waste the facility actually receives. It also includes rejected wastes and container 

residues. CMI will follow the procedures in section 264.72 to address manifest discrepancies:

 Attempt to resolve the discrepancy (e.g., by calling the generator);

 If the discrepancy cannot be resolved within 15 days, send a letter immediately to the 

state’s Waste Management Division describing the discrepancy and attempts to resolve 

it, along with a copy of the manifest at issue;

 Decide if the waste can be accepted by CMI despite the discrepancy. This involves a 

determination whether CMI can manage the waste on-site in a manner that is safe, 

effective and in accordance with the provisions of its permit;

 If the waste cannot be accepted, reject it in accordance with CMI’s Rejection Policy in 

Section 6.0 of this WAP;

 Perform a WIP re-evaluation to determine if a new or revised WIP is necessary. This 

could involve sending the WIP to the generator for re-evaluation and re-certification. 

The new or revised WIP will be subjected to the Pre-Qualification process described in 

Section 2.0 of this WAP; and

 Maintain records of the above actions. Refer to Section 13.0 of this WAP for 

recordkeeping.

Note: CMI does not accept “unknown” wastes. All wastes received by CMI must be 

approved prior to shipment to the CMI facility. In the event that an unknown waste is left at 

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-45

the CMI facility during off hours, CMI will immediately contact the state’s Waste 

Management Division. Following this consultation, CMI will attempt to identify the waste 

using Level I and/or Level II analyses for the purpose of accepting the waste or preparing 

the waste for shipment to an appropriate off-site facility.

7.2 Discrepancies Between the Waste and WIP

If a discrepancy between the waste received at the facility and its WIP is identified (e.g., 

discrepancy in pH, flammability, etc.), CMI will perform the following:

 Attempt to resolve the discrepancy by calling the generator and requesting additional 

information;

 Decide whether to accept or reject the waste despite the discrepancy. This involves a 

determination whether CMI can manage the waste on-site in a manner that is safe, 

effective and in accordance with the provisions of its permit;

 If a decision is made to reject the waste, follow the procedures in the Rejection Policy in 

Section 6.0 of this WAP;

 If the waste is not rejected, perform a Level II analysis to fully characterize the waste. 

Refer to Section 4.0 of this WAP for the procedures associated with a Level II analysis;

 Ask the generator to provide a corrective action plan that describes the reason for the 

discrepancy and actions to be taken to prevent re-occurrence;

 Perform a WIP re-evaluation to determine if a new or revised WIP is necessary. This 

could involve sending the WIP to the generator for re-evaluation and re-certification. 

The new or revised WIP will be subjected to the Pre-Qualification process described in 

Section 2.0 of this WAP; and

 Maintain records of the above actions. Refer to Section 13.0 of this WAP for 

recordkeeping.

8.0 Outbound Waste Screening Procedures

Containerized wastes that are compatible materials, supplemental fuels, used oil, or 

wastewater may be consolidated into bulk transportation vehicles at the CMI facility (see 

Section D of this permit). Prior to transferring waste into a bulk transport vehicle, the CMI 

Supervisor or Senior Waste Technician will review all applicable WIPs, test for 

compatibility (see method CMI-12); for supplemental fuels, CMI will also test for PCBs.

Waste that is bulked on-site for outbound shipments will be tracked using the Bulk 

Consolidation Tracking Sheet (see Appendix D of this section). Upon completion, this 

waste tracking form will be maintained with the facility copy of the outbound manifest as 

part of the facility operating record.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-46

Bulk transport vehicles may be kept on-site for a maximum of 72 hours from the time/date 

when waste is first loaded onto the vehicle. All bulk transport vehicles will be located 

within secondary containment throughout loading (and/or unloading) operations.

9.0 Waste Sampling

Procedures for collecting representative samples are identified below. Collected samples 

will either be returned to their original container or consolidated with compatible 

materials prior to shipment off-site for proper disposal. Any “waste” material generated by 

sampling activities is either returned to the original waste container or CMI will utilize a 

new container.

9.1 Sampling Methods

The methods and equipment used for sampling waste vary with the form and consistency 

of the waste to be sampled. CMI will select the most appropriate representative sampling 

methods, techniques, devices, and containers from those included/described in either the 

EPA document “Test Methods for Evaluating Solid Wastes” (SW-846) or the “American 

Society for Testing and Materials” (ASTM) standards. A representative sample is defined as 

a sample exhibiting average properties of the whole waste.

CMI standard operating procedures designed to protect worker health and ensure worker 

safety while sampling the variety of waste types received by the CMI facility are included in 

Appendix C of this section.

9.2 Sample Tracking Documentation

All sampling will be performed by CMI personnel. 

Samples collected for on-site Level I analysis will be documented utilizing the Level I 

QA/QC report (see Appendix F). 

All Level II and III sampling will be documented utilizing the “Sample Record” log and the 

“Level II/Level III QA/QC Checklist” included in Appendix G of this section. Chain-ofcustody forms (see Appendix E of this section) are used for tracking Level II and Level III 

samples sent for off-site laboratory analyses and testing.

9.3 Sampling Personnel

Sampling is performed in the waste receiving area (Cell A-1) by the CMI Supervisor or 

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

PART FOUR: Sample WAPs 4-47

9.4 Sample Labels

Labels are affixed to each sample container prior to, or at the time of, sampling. At a 

minimum, the labels include the following information, if applicable:

 Generator name

 Common name of waste

 Name of sample collector

 Date of collection

 Unique container number

 WIP/waste stream number

A unique container number sticker, that matches the unique container number assigned to 

the original waste container, is also affixed to sample containers used for Level II and III 

analyses. Labels will be affixed after the sample has been removed and the container is 

resealed such that the container top and/or bung cannot be opened without disfiguring the 

label, thereby flagging those instances that other wastes may have been introduced.

10.0 Parameters and Rationale

The following table summarizes the analytical parameters and rationales used to 

determine the general and specific characteristics of a waste stream. ASTM and SW-846 are 

used as guidelines in developing the following analytical methods:

TABLE 3: Parameters and Rationale 

Parameter Method Rationale for Selection

Physical Description CMI-1

Used to determine the general characteristics of the waste stream. This 

facilitates subjective comparison of the sample waste with prior 

descriptions. CMI personnel check for color, general form, layering, and 

consistency.

pH Screen CMI-2

Required of all water-bearing liquid, solid, and semi-solid waste streams 

to determine the corrosivity of the waste. The apparent pH of nonaqueous wastes will also be performed. Tight tolerance limits (e.g., +/- 2 

pH unit change) will be established based on the storage requirements 

at the facility and other relevant considerations. 

Water Reactivity CMI-3

Used to determine whether the waste has a potential to react with 

water to generate heat, flammable gases, or other products. The test 

does not apply to wastes already in contact with excess water.

Reactive Sulfides Screen 

(Spot Test) CMI-4

Used to indicate whether the waste produces hydrogen sulfide upon 

acidification below pH 2. It is not required if the pH of the waste is <6 or 

if the waste is not water-soluble. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-48

Parameter Method Rationale for Selection

Ignitability CMI-5

Indicates the fire-producing potential of the waste and determines 

whether the waste is RCRA-ignitable. This test will be applied to all 

wastes liquids, solids, and sludges that are selected for analysis.

Reactive Cyanides Screen 

(Spot Test) CMI-6

Indicates whether the waste produces hydrogen cyanide upon 

acidification below a pH of 2. It is not required for wastes with pH <6 or 

if the waste is not water-soluble. 

Oxidizer Screen CMI-7

A general qualitative test used to determine if a waste is an oxidizer. 

Oxidizers have the potential to react with a wide range of wastes and 

therefore often need to be segregated.

Specific Gravity CMI-8

Used in conjunction with other test data to determine probable 

characteristics of materials and their conformance to the WIP.

Percent Suspended Solids CMI-9 Used in assessing the feasibility of wastewater treatment.

Chlorine (Spot Test) CMI-10 Indicates if the material is chlorinated. Information is used to check 

conformance to the WIP, as well as disposal options.

Polychlorinated Biphenyls 

Screen CMI-11 Determines PCB content in order to verify WIP information and assess applicability under TSCA.

Compatibility Testing CMI-12

Prior to a waste being commingled with other wastes, it is tested to 

verify compatibility. Liquid or sludge wastes are combined to assess 

their compatibility. Solid waste compatibility is determined based on 

generator-provided information and records of bulk materials 

previously received and/or currently stored.

Total RCRA 8 Metals CMI-13 Determines if the concentration of arsenic, barium, cadmium, chromium, 

lead, mercury, silver and selenium exceeds the limits in 40 CFR 261.24. 

Total RCRA characteristic 

Volatile Organics CMI-14

Determines if the waste is potentially listed (e.g., contains a volatile 

organic compound potentially used as a solvent) and if the 

concentration of any volatile organic compound exceeds the limits in 40 

CFR 261.24.

11.0 Test Methods

The test methods used to confirm that waste received by CMI conforms to the 

corresponding WIP are described below.

CMI-1: Physical Description

The waste is sampled, visually inspected, and its physical appearance is recorded, the 

description is to include:

 color

 physical state (% solid, % sludge, % liquid)

 layers (single, bi-layered, multi-layered)

 presence of freestanding liquid using SW846-9095 as a guideline (Paint Filter Liquids 

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

PART FOUR: Sample WAPs 4-49

If necessary, a Coliwasa tube or thief/tube is to be used to check for layering and to 

determine the approximate percentage of each layer and approximate percentage of solid, 

sludge, and liquid.

CMI-2: pH Screen

The pH of a solid is measured by placing 20 grams of sample into a cup. 20 milliliters (ml) 

of deionized water is added and the mixture is stirred for 30 seconds. The pH of the slurry 

is then taken and recorded using SW846-9040 and SW846-9041 as guidelines. The pH of 

liquids and sludges is taken using SW846-9040 and SW846-904l as guidelines.

CMI-3: Water Reactivity

The water reactivity of a liquid or solid is determined by adding approximately 3 mL of 

water to 0.1 mL of liquid or 0.1 gram of solid. The mixture is observed to detect heating 

(more than 15o C temperature rise) or turbulent gas evolution (more than 10% of the 

mixture volume). If the mixture reacts as described above, the test is considered positive. If 

the addition of water causes the material to be considered reactive under any definition of 

40 CFR 261.23 or state regulations, the material is considered water-reactive.

CMI-4: Reactive Sulfides Screen (Spot Test)

2 to 4 drops of the material are placed on a spot plate. Then, a strip of lead-acetate paper 

moistened with 1 drop of water is placed over the spot plate cavity containing the waste. 

Next, 2 to 3 drops of 3M HCl is added. Black PbS forms in the paper after 0.5 to 1 minute if 

sulfide is present. The threshold limit of this method is around 4 PPM sulfide.

CMI-5: Ignitability

The ignitability screen is determined by placing the sample in a 125 to 250 mL cup. The cup 

is covered and allowed to stand for at least five minutes. After five minutes the cover is 

removed and a flame is placed near the opening of the cup. If a flash occurs, the ignitability 

screen is considered positive. If no flash is observed, a small amount is placed on the end of 

a spatula and heated over a flame. If the material ignites and sustains a flame for 10 

seconds, the result is Negative B (per industry standard). If the sample does not sustain a 

flame for 10 seconds or ignite, the result is Negative C. A closed cup flash test will be used 

to determine flash point of any Negative B material.

CMI-6: Reactive Cyanides Screen (Spot Test)

Cyanide is determined by placing 2 to 4 drops or a small spatula tip of the sample on a spot 

plate. Two drops of water are then added to the waste. Next, one drop of chloramine-T 

solution followed by one drop of pyridine-barbituric acid solution is added to the waste. If 

the solution turns dark red or carmine after 10 to 30 seconds, this is a positive response.

The presence of cyanide can be detected above 60 ppb in aqueous samples (3 drop size) 

and 10 ppm in solid samples (1 gram size).
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PART FOUR: Sample WAPs 4-50

Reagents:

 Chloramine-T solution: 1 gram of Chloramine-T is dissolved in 100 ml of distilled water.

 Pyridine-barbituric acid: 1.5 g of barbituric acid is mixed with 5 mL of water and 7.5 mL 

of pyridine. The mixture is treated with 1.5 mL of concentrated HC1 and diluted to 25 mL.

CMI-7: Oxidizer Screen

The method used is a qualitative examination for the presence of oxidizing materials in 

liquid, sludge, and solid samples.

 Liquids and Sludges

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

in HCl. The wetted strip is then dipped into the sample. The color change is then noted. 

If the color turns light brown to dark purple or black, then the result is interpreted as 

positive, and the waste is managed as an oxidizer. The color is indicative of the type of 

oxidizer present.

 Solids

The procedure requires that 2 mL of deionized water be added to 11 grams of sample. 

The mixture is then stirred for 30 seconds. A strip of KI-starch paper is wetted in HC1 

and then dipped into the slurry. The color change of the KI paper is then noted. If the 

color turns light brown to dark purple or black, then the result is interpreted as positive 

and the waste is managed as an oxidizer. The light brown color is indicative of nitric 

acid while the purple/black color results from the presence of peroxides.

CMI-8: Specific Gravity

The Specific Gravity of a liquid is determined by weighing 10 mL of the sample (at room 

temperature) and dividing this value by 10. The alternate method of using a hydrometer 

may be used if sufficient sample is present.

CMI-9: Percent Suspended Solids

Total suspended solids are determined by bringing the sample pH to approximately 3 using 

10% sulfuric acid. A determination of the sample’s pumpability is made without stirring. 

The sample must not gel or turn to sludge. The sample is centrifuged for five minutes and 

the percent solids are calculated.

CMI-10: Chlorine (Spot Test)

A small amount of the sample is placed in a test tube. Litmus paper is placed over the 

sample as heat is applied. A red coloration of the paper indicates the presence of chlorine. 

An additional test is done by placing a small amount of the material in a flame on a wire 

loop. A green color indicates the presence of chlorine.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-51

CMI-11: Polychlorinated Biphenyls Screen 

Method SW846-8082 is used to determine PCB content.

CMI-12: Compatibility Testing 

Prior to a waste being commingled with other wastes, it is tested to verify compatibility. A 

representative sample of the waste is mixed with a representative sample of the wastes to 

be commingled. This is done under controlled conditions by personnel trained regarding 

chemical reactions.

Representative portions of the wastes to be commingled are mixed together at the same 

measured temperature to verify compatibility. For example, if a partially full container is to 

be consolidated into another partially full container, a representative sample is drawn from 

both containers, the samples are mixed. The mixture is then observed for the following:

 Evolution of gas characterized by bubbling or foaming

 Heat release evidenced by a temperature increase of more than 15 degrees over the 

measured temperature

 Polymerization of the mixture to an un-pumpable viscosity within 30 minutes

 Miscibility or the formation of layers

 Precipitate formation

 Emulsification

If any of these conditions are observed, the wastes are considered incompatible.

CMI-13: RCRA 8 Metals (totals with digestion)

 Liquids

Methods SW846-6010/7470

 Solids

Methods SW846-6010/7471

CMI-14: Volatile Organic Compounds (totals)

 Liquids

Volatile Organic Compounds – Method SW846-8260C 

 Solids

Volatile Organic Compounds (with extraction) – Methods SW846-5035/8260 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-52

12.0 Quality Assurance and Quality Control

The following quality assurance/quality control (QA/QC or 

“quality”) information for this facility is being provided as 

required by 40 CFR 270.30(e) and in accordance with the 

following EPA guidance documents:

 Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Third 

Edition, Final Update I, U.S. EPA, Office of Solid Waste, Washington, DC, July 1992, 

Chapter One, updated editions.

 Handbook for analytical Quality Control in Water and Wastewater laboratories, EPA 

600/4-79-019, March 1979, US Environmental Protection Agency (USEPA), 

Environmental Monitoring and Support Laboratory (EMSL), Cincinnati, OH.

Quality protocols are applicable to both sampling and analytical techniques. This section 

does not provide specific QA/QC performance standards for individual sampling and 

analysis techniques. Such specifics are defined in specific operating procedures of the 

laboratories performing the tests. Portions of these policies have been summarized in the 

following sections.

12.1 Sampling Program

With some exceptions, all bulk and containerized waste shipments are sampled (see 

Section 4.0 of this WAP). Individual container samples that are related may be composited 

prior to analysis. Sampling procedures are described in Section 9.0 of this WAP. The 

selection of the sample collection device depends on the type of sample, the sample 

container, the sampling location and the nature and distribution of the waste components. 

In general, the methodologies used for specific materials correspond to those referenced in 

40 CFR Part 261, Appendix I. The selection and use of the sampling device is supervised or 

performed by a person thoroughly familiar with the sampling requirements.

Sampling equipment is typically constructed of non-reactive materials such as glass, PVC 

plastic, aluminum, or stainless steel. Care is taken in the selection of the sampling device to 

prevent contamination of the sample and to ensure compatibility of materials. For example, 

glass bottles are not used to collect hydrofluoric acid wastes.

12.2 Analytical Program

CMI performs minor analyses on-site and subcontracts with independent, state certified or 

NELAC laboratories for all pre-qualification and Level II and III analyses. CMI and these 

laboratories have developed programs of analytical quality practices and procedures to 

ensure that precision and accuracy are maintained. These programs – which include use of 

control standards, duplicates, spikes, and blanks – are required. Non-company laboratories 

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-53

employed by the company demonstrate quality control practices that are comparable to 

CMI’s practices. 

Good laboratory practices which encompass sampling, sample handling, housekeeping and 

safety are required by specific CMI procedures.

12.3 Conclusion

The aforementioned sampling and analytical quality practices help ensure the data 

obtained are precise and accurate for the waste stream being sampled. The analytical 

results are used by facility management to decide whether or not to accept a particular 

waste and, upon acceptance, to determine the appropriate method of treatment, storage, 

and disposal. Results are also important to ensure that wastes are managed properly by the 

facility and that incompatible wastes are not inadvertently combined. The quality of these 

results is as important as the results themselves. Thus, the quality of the analytical data, 

along with the thoroughness and care with which the sampling and analyses are performed 

and reported, provides an important basis for day-to-day operational decisions.

13.0 Recordkeeping and Reporting 

CMI will report manifest discrepancies to EPA as specified 

at 40 CFR 264.72. In addition, CMI will subcontract with 

independent, state certified or NELAC laboratories to 

perform the Level II and III analyses, will maintain analytical data on-site, and will supply 

any analytical data to EPA when requested.

The following records will be maintained in the facility’s operating record:

 A record of Level I analyses as documented on the Level I QA/QC report (see 

Appendix F).

 A record and results of all Level II and Level III analysis will be maintained by CMI for 

each waste sampled/analyzed:

– A copy of the chain of custody document (see 

Appendix E of this WAP)

– Copies of all applicable analytical and test results 

and lab reports including the results of the Level 

I analysis 

– A copy of the original (incoming) manifest

– A copy of the original WIP

– Documentation of any discrepancies identified by the Level I, II or III analysis 

– If applicable, a copy of any written or correspondence with the generator related to 

resolving a WIP discrepancy and documentation of relevant conversations with the 

generator regarding same.

Issue to Consider

Note that some states have statespecific requirements for reporting.

This is not a mandatory WAP 

element under 40 CFR 264.13.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-54

– If applicable, copies of any written correspondence with the generator and state 

Waste Management Division related to resolving a manifest discrepancy and 

documentation of relevant conversations with the generator or state Waste 

Management Division regarding same.

– If applicable, a copy of the revised WIP.

– The completed Level II/Level III QA/QC checklist (see Appendix G of this WAP)

 Records of analyses, corrective action plans and other actions taken under the Rejection 

Policy and Discrepancy Policy in this WAP.

In addition, CMI will produce bi-annual reports that summarize the frequency at which 

incoming shipments do not conform to their waste profiles. The report must indicate the 

steps taken by the facility to evaluate and resolve the discrepancies, including if new or 

revised WPSs were produced.

14.0 Corrective Action 

CMI will subcontract with independent, state certified or NELAC laboratories for prequalification and Level II and III analyses. CMI and subcontracted laboratories have 

processes in place to ensure quality assurance and quality control (see Section 12.0 of this 

WAP). In addition, CMI and subcontracted laboratories have methods for correcting 

problems when they are identified. If problems/discrepancies are found, CMI may take a 

range of corrective actions, such as performing an audit of the laboratory, reviewing and 

revising applicable SOPs, and periodically evaluating subcontracted laboratories and 

entering into new subcontracts if CMI has a concern about the quality of work.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-55

Appendices

The information in the appendices has been reduced to shorten the overall length of this 

WAP. This was done solely for purposes of presentation in this guidance document. The 

following appendices were removed:

 Appendix A: Example Waste Information Profile (WIP) Form

 Appendix B: Example Lab Pack Contents Form

 Appendix E: Example Chain of Custody Form
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

PART FOUR: Sample WAPs 4-56

Appendix C: Standard Operating Procedures for Opening and Sampling Containers

Sampling of Containers

Coliwasas, tubes, drum thieves, and corers are examples of the devices used to sample 

containers. Samples are taken from locations displaced both vertically and horizontally 

throughout the waste. For liquids (or liquids with precipitated solids), the sample collector 

uses a Coliwasa or equivalent. The sampling device is inserted into the container from the 

top and is pushed down slowly until the bottom of the container is reached. The device is 

sealed to retain the contents. The contents of the sampling device are then transferred to a 

polyethylene or glass bottle that is labeled with waste identification information.

A corer or equivalent device is used to sample containers that are solid in nature. These 

containers are generally filled with dirt and sludges. Several areas from the container are 

sampled and composited into a jar in order to ensure a representative sample. The sample 

collector removes a sample that uniformly represents the waste composition of the 

container (i.e., all layers and phases are represented in the sample).

Sampling of Bulk Material 

Bulk solids are sampled using a simple random sampling strategy. The bulk solids 

container, usually a roll-off box or a dump trailer, is divided into sections. A corer is used in 

each section to draw a sample from as deep as possible. On occasion, a shovel is used to 

access lower levels of a bulk container. The samples are composited together so that there 

is one sample that represents that particular bulk solids shipment.

Bulk liquids are sampled using a Coliwasa or similar device that can sample vertical 

anomalies. Each compartment of tanker truck is sampled. Compartment samples from the 

same generator and waste stream will not be composited prior to analysis.

Tank trucks without manways are sampled through a valve. The valve is flushed prior to 

the sample being drawn.

Debris

Debris is sampled as much as possible; however, not all wastes are amenable to sampling 

(e.g., universal waste batteries, CRTs, lamps or ballasts, lab packs, etc.). A container of 

debris often contains a wide variety of materials. For example, it may contain spill 

absorbent, Tyvek suits, rubber booties, gloves, and paper towels. It may be difficult to 

obtain a representative sample.

In virtually all situations, debris has one thing in common: non-hazardous materials are 

contaminated with very small to trace amounts of organic and inorganic hazardous 

constituents.

Frozen Waste

CMI will not sample waste that is frozen. The container will remain in the receiving area 

until the waste can be sampled and be stored on pallets.
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PART FOUR: Sample WAPs 4-57

Appendix D: Bulk Consolidation Tracking Sheet

Outbound Facility: __________________ Date: ___________________________

Type of Shipment: __________________ Initial: __________________________

Pump Start Time: __________________ Pump Stop Time: __________________

Container # Location Weight Size Waste codes Notes
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PART FOUR: Sample WAPs 4-58

Appendix F: Example Level I QA/QC Report

Date: __________________________

Time: __________________________

Initials: _________________________

Manifest Number: _____________________________

Waste Information Profile (WIP) Number: _____________________________

Number of Drums in Batch: _____________________________

Profile Description of Waste: _____________________________

Description of Waste (Observed): _____________________________

Physical Characteristics/Screen Results: ____________________________________________________________

_____________________________________________________________________________________________

% Liquids

% Solids

% Sludge

Color

Viscosity

pH

Flash Point

% Fuel*

Perform a visual inspection on each waste container, including covers and closure devices. Check for visible cracks, 

holes, gaps, or other open spaces into the interior of the container when the cover and closure devices are secured 

in the closed position. Examine the physical and structural integrity of the container (e.g., is it bulging, etc.):

Acceptable  Unacceptable 

If “Unacceptable”, explain corrective actions taken: 

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

*Waste containing less than 1% fuel cannot be managed under the state’s “fuel-to-fuel” exemption (i.e., the waste 

does not contain a recoverable amount of fuel)
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PART FOUR: Sample WAPs 4-59

Appendix G: Level II/III QA/QC Checklist

Sample Date: __________________________________________

Generator: __________________________________________

Waste Stream (WIP) #: __________________________________________

Drum #: __________________________________________

If not the 500th container, justification for bypassing: 

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

Results of Level II/III Analysis:

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

Documents to be included in Level II/III WAP file:

 Copy of Original Manifest ________

 Copy of Original WIP ________

 Copy of Level I QA/QC Report ________

 Original Chain of Custody ________

 Analytical Results ________

Additional documentation to be included in Level II/III WAP file (if applicable):

 Revised WIP ________

 Manifest Discrepancy Letter ________

 Correspondence with Generator/Customer ________ 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDICES A‐0

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

APPENDIX A: Hazardous Waste Identification A-1

Appendix A:

Hazardous Waste Identification

RCRA Section 3001 provides EPA with the authority to develop criteria for the 

identification of hazardous wastes. Under Section 1004(5) of RCRA, a hazardous waste is 

defined as: 

a solid waste, or a combination of solid wastes which, because of its quantity, 

concentration, or physical, chemical, or infectious characteristics, may cause, or 

significantly contribute to an increase in mortality or an increase in serious 

irreversible or incapacitating reversible illness, or pose a substantial present or 

potential hazard to human health or the environment when improperly treated, 

stored, transported, disposed, or otherwise managed. 

The regulatory definition of a hazardous waste (40 CFR 261.3) defines two ways that a 

waste may be hazardous. First, solid wastes are hazardous wastes if EPA lists them as 

hazardous wastes; the lists of hazardous wastes are found in Part 261, Subpart D. Wastes 

listed by EPA as hazardous contain hazardous constituents, are acutely hazardous, and/or 

exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity. Second, EPA 

identifies four characteristics of a hazardous waste. Accordingly, solid wastes are 

hazardous if they exhibit any of the following four characteristics of a hazardous waste: 

ignitability, corrosivity, reactivity, or toxicity (based on the results of the TCLP). Definitions 

of these hazardous waste characteristics are found in Part 261, Subpart C. Exclusions to the 

regulatory definitions of solid waste and hazardous waste are found in §261.4.

Generators must conduct a hazardous waste determination according to the approach 

specified in §262.11. Figure A-1 can be used to assist in making this hazardous waste 

determination, and can serve as a roadmap when reviewing the rest of Appendix A. Persons 

who generate a solid waste first must determine if the solid waste is excluded from the 

definition of hazardous waste under the provisions of §261.4. If the waste is not excluded, 

the generator must determine if it is listed as a hazardous waste; if the waste is not listed, or 

for the purposes of complying with the LDR requirements in Part 268, the generator must 

determine if the waste exhibits a characteristic of a hazardous waste, either by testing the 

waste or by utilizing acceptable knowledge about the waste or process or materials used to 

generate the waste.

Listing Determination

Once the generator determines that a solid waste is not excluded from regulation as 

hazardous, then he/she must determine if the waste meets one or more of the hazardous 

waste listing descriptions. The hazardous waste lists include wastes from nonspecific 

sources (termed “F-listed wastes,”) and specific sources (i.e., K-listed wastes). F-listed 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX A: Hazardous Waste Identification A-2

wastes include spent solvents, electroplating wastes, and dioxin-bearing wastes. The Klistings include wastes from wood preserving operations, organic and inorganic chemical 

production, pesticide formulation, explosives manufacturing, petroleum refining, iron and 

steel production, pharmaceutical manufacturing, and the lead, zinc, copper, and aluminum 

industries. The third group of hazardous waste listings includes discarded unused 

commercial chemical products, off-specification products, and spill residues of such 

products (i.e., P- and U-listed wastes).

The hazardous waste listings also apply to certain mixtures of solid wastes. Under the 

“mixture rule” in 40 CFR 261.3(a)(2)(iii) and (iv), mixtures of listed hazardous wastes and 

solid non-hazardous wastes are defined as hazardous wastes and retain their listing 

designations unless the hazardous waste in the mixture is listed solely based on a 

particular characteristic (i.e., ignitability [I], corrosivity [C], or reactivity [R]) and the 

mixture no longer exhibits any of these hazardous waste characteristics. For example, a 

mixture of a spent methylene chloride formulation (listed as F002 because of its hazardous 

constituent’s toxicity) and used oil would be defined as a hazardous waste and be 

designated as F002 whether or not the mixture exhibited a hazardous waste characteristic. 

The mixture remains a hazardous waste unless the generator successfully petitions to 

delist the waste according to procedures outlined in §260.22.

The hazardous waste listings also apply to solid wastes derived from the treatment, storage, 

or disposal of a listed hazardous waste. The “derived-from rule” (§261.3(c)(2)) defines 

residual solid wastes derived from the treatment, storage, or disposal of a listed hazardous 

waste as a hazardous waste and retain their listing designations unless the hazardous waste 

is listed solely based on a particular characteristic and the derived-from wastes no longer 

exhibits any of the hazardous waste characteristics. Examples of wastes defined as hazardous 

through the derived-from rule include ash resulting from the incineration of off-specification 

toluene (U220), and leachate resulting from the disposal of API separator sludge from the 

petroleum refining industry (K051) in a landfill. As with the mixture rule, a generator may 

petition EPA to delist a waste that is derived from a listed waste.

EPA also regulates mixtures of hazardous wastes and other materials that are not solid 

wastes. The “contained-in policy” states that materials containing a listed hazardous waste 

must be managed as hazardous wastes until the other material no longer contains the 

listed waste. This provision mainly applies to mixtures of listed hazardous wastes and 

environmental media (e.g., contaminated ground water, contaminated soil). An example of 

a waste regulated under the contained-in policy is soil contaminated with cyanides that has 

been excavated from under a tank that contains spent cyanide plating bath solutions from 

an electroplating operation (F007); this soil would be managed as F007.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX A: Hazardous Waste Identification A-3

Is the waste 

excluded under 

40 CFR 

§261.4?

 Has the waste been delisted in accordance 

with 40 CFR §§260.20 and 260.22? or

 Does the mixture or derived-from residue 

qualify for any of the exclusions from the 

mixture and derived-from rules in 40 CFR 

§261.3?

 Does the waste meet any of the listing 

descriptions in 40 CFR Part 261, Subpart D? or

 Is the waste mixed with a listed hazardous 

waste? or

 Is the waste derived from the treatment, 

storage, or disposal of a listed hazardous 

waste?

For purposes of the Land Disposal 

Restrictions program of 40 CFR 

Part 268, does the listed waste 

exhibit a characteristic of 

hazardous waste in 40 CFR Part 

261, Subpart C?

Does the waste exhibit a 

characteristic of hazardous 

waste in 40 CFR Part 261, 

Subpart C?*

Not a Hazardous Waste

No

Not a Hazardous Waste

No

Listed Yes

Hazardous 

Waste

No

No

No Not a 

Hazardous 

Waste

Not a Listed 

Hazardous Waste

Characteristic 

Hazardous 

Waste

Listed 

Hazardous 

Waste

Listed and 

Characteristic 

Hazardous 

Waste

Yes No Yes

Yes

Yes

Is the material 

a solid waste 

under 40 CFR 

§261.2?

* Note exception for mixtures of characteristic wastes and mining/mineral processing wastes in 40 CFR §261.3(a)(2)(1)

Figure A-1 : Hazardous Waste Identification

*Note exception for mixtures of characteristic wastes and mining/mineral processing wastes in 40 CFR 261.3(a)(2)(i).

** Under 268.9(b), a listed hazardous waste exhibiting a characteristic is not identified as characteristically hazardous provided that the treatment standard for 

the listed waste includes a treatment standard for all of the constituents that cause the waste to exhibit the characteristic. (For such listed waste, there is no 

requirement to treat underlying hazardous constituents (UHCs) under Part 268. See Section 1.1.1 of this manual for additional information on UHCs.)

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

APPENDIX A: Hazardous Waste Identification A-4

Characteristics Determination

A solid waste that is not excluded from regulation and does not meet a listing description of 

a hazardous waste must be evaluated by the generator to determine if it exhibits a 

characteristic of a hazardous waste. A generator must evaluate representative samples of 

such wastes to determine if they exhibit any of the four characteristics of a hazardous waste: 

ignitability, corrosivity, reactivity, and toxicity. This evaluation involves testing the waste or 

using acceptable knowledge of the process or materials used to produce the waste.

The characteristic of ignitability is described in 40 CFR 261.21. A waste is ignitable if it is a 

liquid, other than an aqueous solution containing less than 24 percent alcohol by volume 

and has flash point less than 60 °C (140 °F), as determined by a Pensky-Martens Closed Cup 

Tester, using the test method specified in ASTM Standard D 93-79 or D 93-80, or a Setaflash 

Closed Cup Tester, using the test method specified in ASTM Standard D 3278-78. In 

addition, a waste is ignitable if it is not a liquid and is capable, under standard temperature 

and pressure, of causing fire through friction, absorption of moisture or spontaneous 

chemical changes and, when ignited, burns so vigorously and persistently that it creates a 

hazard. Further, a waste is ignitable if it is an ignitable compressed gas meeting the criteria 

at §261.21(a)(3) (e.g., any material or mixture having in the container an absolute pressure 

exceeding 40 p.s.i. at 70 °F or, regardless of the pressure at 70 °F, having an absolute 

pressure exceeding 104 p.s.i. at 130 °F). Finally, a waste is ignitable if it is an oxidizer 

meeting the criteria at §261.21(a)(4). For purposes of the ignitability characteristic, an 

oxidizer is a substance such as a chlorate, permanganate, inorganic peroxide, or a nitrate, 

that yields oxygen readily to stimulate the combustion of organic matter. Wastes that are 

ignitable are classified as EPA Hazardous Code D001. Examples of ignitable wastes are 

certain spent solvents (e.g., mineral spirits), off-specification jet fuels, or perchlorates.

The characteristic of corrosivity is described in §261.22. A waste is corrosive if it is 

aqueous (defined as amenable to pH measurement) and its pH is less than or equal to 2 or 

greater than or equal to 12.5. The test used for this pH determination is EPA Test Method 

9040C in SW-846 (pH Electrometric Measurement). A waste is also corrosive if it is a liquid 

and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test 

temperature of 55 °C (130 °F) as determined by Method 1110A in SW-846 (Corrosivity 

Toward Steel). Corrosive wastes are designated as EPA Hazardous Waste Code D002. 

Corrosive wastes include spent sulfuric acid and concentrated waste sodium hydroxide 

solutions. Note that, under the federal program, corrosive solids are not included in the 

corrosivity definition and so are not hazardous wastes.

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

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

 It reacts violently with water.

 It forms potentially explosive mixtures with water.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX A: Hazardous Waste Identification A-5

 When mixed with water, it generates toxic gases, vapors or fumes in a quantity 

sufficient to present a danger to human health or the environment.

 It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 

2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present 

a danger to human health or the environment.

 It is capable of detonation or explosive reaction if it is subjected to a strong initiating 

source or if heated under confinement.

 It is readily capable of detonation or explosive decomposition or reaction at standard 

temperature and pressure.

 It is a forbidden explosive as defined in 49 CFR 173.54, or is a Division 1.1, 1.2 or 1.3 

explosive as defined in 49 CFR 173.50 and 173.53.

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

Code D003.

The toxicity characteristic (TC) is described at §261.24. To test the waste, generators 

must obtain an extract of the waste using Test Method 1311 (the Toxicity Characteristic 

Leaching Procedure TCLP). The extract is subsequently analyzed using the appropriate test 

methods to determine the level of TC constituents. The results are compared to regulatory 

thresholds for the TC constituents at §261.24. Determinative methods in this step may 

include, but are not limited to, the following:

 EPA Test Methods 3010 and 6010 - for arsenic, barium, cadmium, chromium, lead, 

silver, and selenium.

 EPA Test Method 7470 – mercury.

 EPA Test Methods 3510 and 8080 – pesticides.

 EPA Test Methods 5030 and 8260 - for volatile organics.

 EPA Methods 3510 and 8270 - semivolatile organics.

 EPA Test Method 8151 - herbicides.

Note: Additional options for sample preparation and analysis can be found in the most 

recent version of SW-846 Chapter Two. 

If the extract from the TCLP procedure contains levels of any of the 40 constituents at or 

above regulatory thresholds, the waste is considered a hazardous waste. Wastes that 

exhibit the toxicity characteristic are classified as EPA Hazardous Waste Codes D004 

through D043. Examples of wastes that may exhibit the characteristic of toxicity include 

petroleum wastes, wastes from organic chemical manufacturing, and pesticide and 

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

APPENDIX A: Hazardous Waste Identification A-6

Certain states may also have additional requirements for identifying hazardous wastes, 

which apply only to wastes generated and/or managed within the state. States authorized 

to implement the RCRA hazardous waste programs under Section 3006 of RCRA may 

promulgate regulations that are more stringent or broader in scope than federal regulations. 

For example, certain states have broadened the scope of the hazardous waste listings by 

specifically listing used oil as a hazardous waste. Some states also regulate hazardous 

wastes based on total (versus extract) waste analysis of individual hazardous constituents.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-1

Appendix B: 

Regulatory Summary

This appendix presents a brief summary of some changes to the RCRA hazardous waste 

program that have occurred since the 1994 edition of this manual was issued. For more 

information concerning specific requirements, consult the Federal Registers cited herein 

and the Code of Federal Regulations. These changes include:

 Definition of solid waste final rules.

 Alternative requirements for laboratories owned by eligible academic entities.

 Conditional exemptions for military munitions.

 Conditional exemptions for low-level mixed waste storage, treatment, transportation, 

and disposal.

 Organic air emission standards for tanks, containers and surface impoundments 

(40 CFR Parts 264 and 265, Subpart CC).

 Amendments to the Land Disposal Restrictions (LDR) regulations, including the Phase II 

- IV rules.

 Revisions and updates to the Test Methods for Evaluating Solid Waste, Physical/ Chemical 

Methods (SW-846) and issuance of the Methods Innovation Rule (MIR).

Definition of Solid Waste Final Rules 

In October 2003, EPA proposed a regulatory exclusion from the definition of solid waste 

which would streamline requirements for the recycling of hazardous secondary materials. 

After evaluating public comments and conducting independent analyses, the Agency 

published a supplemental proposal in March 2007. 

On October 30, 2008, EPA published a rule (Federal Register 73:211 (30 October 2008) p. 

64668) establishing conditional exclusions for the following:

 Materials that are generated and legitimately reclaimed under the control of the 

generator (i.e., generated and reclaimed on-site, by the same company, or under 

“tolling” agreements).

 Materials that are generated and transferred to another company for legitimate 

reclamation under specific conditions. Materials that EPA or an authorized state 

determines to be non-wastes through a case-by-case petition process.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-2

The rule also contained a provision to determine which recycling activities are legitimate 

under the new exclusions and non-waste determinations. This provision ensures that 

only authentic recycling, and not treatment or disposal under the guise of recycling, 

receives the benefits of these streamlined regulations. In order to be legitimately recycled 

under these exclusions, the hazardous secondary material (1) must provide a useful 

contribution to the recycling process; and (2) the recycling must make a valuable new 

intermediate or final product. Two additional factors must also be considered: (1) 

whether the recycled material is managed as a valuable product; and (2) whether the 

recycled product contains toxic constituents at significantly greater levels than a nonrecycled product made from virgin materials. These exclusions are not available for 

materials that are: (1) considered inherently waste-like; (2) used in a manner 

constituting disposal; or (3) burned for energy recovery.

On December 10, 2014, the EPA Administrator signed the revisions to the definition of 

solid waste rule. The rule (80 FR 1694; January 13, 2015) modifies the 2008 rule to protect 

human health and the environment from the mismanagement of hazardous secondary 

material, while promoting sustainability through the encouragement of protective and 

environmentally responsible recycling of such materials. It includes several provisions that 

result in both resource conservation and economic benefits by encouraging certain types of 

in-process recycling and remanufacturing:

 The rule addresses significant regulatory gaps in the 2008 rule by requiring off-site 

recycling at a facility with a RCRA permit or verified recycler variance, which will allow 

EPA and the states to verify that a facility has the equipment and trained personnel to 

protectively manage the material, adequate financial assurance, is prepared to respond 

in case of an emergency, and can demonstrate that the recycling is not disposal in the 

guise of recycling. The new verified recycler exclusion also includes a public 

participation requirement for recyclers seeking variances, so that communities are 

notified prior to the start of recycling operations. 

 The rule affirms the legitimacy of the pre-2008 DSW exclusions, such as the scrap metal 

exclusion, and does not change the regulatory status of material legitimately recycled 

under these long-standing exclusions.

 The rule includes a revised definition of legitimate recycling that re-affirms the 

legitimacy of in-process recycling and of commodity-grade recycled products, such as 

metal commodities. The rule retains the exclusion for recycling under the control of the 

generator, including recycling on-site, within the same company and through certain 

types of toll manufacturing agreements, which recognizes those generators who follow 

good business practices by taking responsibility for their recycling and maintaining 

control of their hazardous secondary materials.

 Finally, the rule includes a targeted remanufacturing exclusion for certain higher-value 

hazardous spent solvents, which are being remanufactured into commercial-grade 

products. This allows manufacturers to reduce the use of virgin solvents, resulting in 

both economic and environmental benefits, including energy conservation and reduced 

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

APPENDIX B: Regulatory Summary B-3

Alternative Requirements for Laboratories Owned by Eligible 

Academic Entities

On December 1, 2008, EPA added Subpart K to the generator standards at 40 CFR Part 

262 (Federal Register 73:231 (1 December 2008) p. 72912). The new subpart applies to 

eligible academic entities, which are colleges and universities, and teaching hospitals and 

nonprofit research institutes that are either owned by or formally affiliated with a college 

or university. Subpart K is an alternative, tailored set of regulations that allow eligible 

academic entities the flexibility to make hazardous waste determinations in the 

laboratory; at an on-site central accumulation area; or at an on-site TSDF. The rule also 

provides incentives for eligible academic entities to clean-out old and expired chemicals 

that may pose unnecessary risk. Further, the rule requires eligible academic entities that 

opt into the rule to develop a Laboratory Management Plan (LMP), which is expected to 

result in more protective laboratory practices and increased awareness of hazardous 

waste management. Eligible academic entities may choose not to opt into the new rule 

and remain subject to the pre-existing hazardous waste generator requirements. 

Conditional Exemptions for Military Munitions

On February 12, 1997, EPA published regulations that clarify when conventional and 

chemical military munitions become a hazardous waste under RCRA (Federal Register 

62:29 (12 February 1997) p. 6621). The rule establishes the regulatory definition of solid 

waste as it applies to three specific categories of military munitions: (1) unused munitions; 

(2) munitions being used for their intended purpose; and (3) used or fired munitions. 

The rule conditionally exempts from the RCRA manifest and container marking 

requirements, waste non-chemical military munitions that are shipped from one militaryowned or -operated TSDF to another in accordance with Department of Defense (DOD) 

military munitions shipping controls. The rule also conditionally exempts from the RCRA 

Subtitle C storage regulations waste non-chemical military munitions subject to the 

jurisdiction of the DOD Explosives Safety Board storage standards. 

In addition, the rule identifies four specific circumstances under which unused munitions 

are considered to be a solid waste for regulatory purposes: (1) the unused munition is 

"abandoned by being disposed of, burned, or incinerated, or treated prior to disposal;" (2) 

the unused munition is removed from storage for purposes of disposal or treatment prior 

to disposal; (3) the unused munition is deteriorated, leaking, or damaged to the point that 

it can no longer be put back into serviceable condition, and cannot be reasonably recycled 

or used for other purposes; or (4) the munition has been determined by an authorized 

military official to be a solid waste.

Military munitions are not a solid waste for regulatory purposes (1) when a munition is 

being used for its intended purpose, which includes when a munition is being used for the 

training of military personnel; when a munition is being used for research, development, 

testing, and evaluation; and when a munition is destroyed during range clearance 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-4

operations at active and inactive ranges; and (2) when a munition that has not been used or 

discharged, including components thereof, is repaired, reused, recycled, reclaimed, 

disassembled, reconfigured, or otherwise subjected to materials recovery activities. 

This rule also specifies that used or fired munitions are solid waste when they are removed 

from their landing spot and then either (1) managed off-range (i.e., when transported offrange and stored, reclaimed, treated, or disposed of or (2) disposed of (i.e., buried or 

landfilled) on-range. In both cases, when the used or fired munition is a solid waste, it is 

potentially subject to regulation as a hazardous waste. Also, munitions that land off-range, 

and that are not promptly retrieved, are statutory solid waste. 

Conditional Exemptions for Low-level Mixed Waste Storage, 

Treatment, Transportation, and Disposal

A “mixed waste” contains both radioactive and hazardous waste components. Mixed wastes 

are regulated under RCRA for the hazardous waste component and under the Atomic 

Energy Act (AEA) for the radioactive component. In general, the requirements of RCRA and 

AEA are consistent and compatible. The U.S. Nuclear Regulatory Commission (NRC) and the 

U.S. Department of Energy (DOE) regulate the radioactive portion of mixed waste under 

AEA authority, while EPA regulates the hazardous waste portion of mixed waste under 

RCRA authority.

Low-level mixed waste (LLMW) is waste that contains low-level radioactive waste (LLRW) 

and hazardous waste. LLRW is defined as any radioactive waste that is not high-level 

radioactive waste, spent nuclear fuel, or byproduct material. LLMW is generated at 

industrial and hospital facilities and nuclear power plant facilities in a number of processes 

such as medical diagnostic testing and research, pharmaceutical and biotechnology 

development, pesticide research, and nuclear power plant operations.

On May 16, 2001, EPA published a rule (Federal Register 66:95 (16 May 2001) p. 27218) 

that provides increased flexibility to facilities for managing LLMW and naturally occurring 

and/or accelerator-produced radioactive material (NARM) containing hazardous waste. 

The rule exempts LLMW from RCRA storage and treatment requirements as long as the 

waste is generated under a single NRC license, meets the conditions specified, and is stored 

and treated in a tank or container. In addition, LLMW and NARM, which meet applicable 

treatment standards, may be conditionally exempt from the RCRA transportation and 

disposal requirements. This waste may be disposed of at LLRW disposal facilities, which 

are licensed by NRC. The rule also provides additional flexibility for manifesting these 

wastes when they are destined for disposal at such facilities. Although mixed waste 

meeting the applicable conditions is exempt from certain RCRA requirements, it must still 

be managed as radioactive waste according to NRC regulations. Note that DOE disposal 

facilities are not eligible to accept the exempt waste since they are not subject to NRC 

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

APPENDIX B: Regulatory Summary B-5

Organic Air Emission Standards for Tanks, Containers and Surface 

Impoundments (Subpart CC)

Section 3004(n) of RCRA requires the development of standards to control air emissions 

from TSDFs as necessary to protect human health and the environment. EPA has 

promulgated a series of regulations to implement this requirement. These regulations 

control air emissions from certain process vents and equipment leaks (Parts 264 and 265, 

Subparts AA and BB), as well as air emissions from certain tanks, containers, and surface 

impoundments (Subpart CC). The Subpart AA and BB standards became effective on 

December 21, 1990, while the Subpart CC organic emission control standards became 

effective on November 25, 1996 (Federal Register 61:228 (25 November 1996) p. 59931).

Under Subpart CC, if a hazardous waste has an average volatile organic (VO) concentration 

less than 500 parts per million by weight (ppmw) at the point of waste origination or if the 

hazardous waste organic content has been reduced by a treatment process to the extent 

described in 40 CFR 264.1082 or 265.1083 prior to placement in the waste management 

unit, the unit is exempt from the air emission controls required under the standards. 

Subpart CC applies to the containers and tanks of TSDFs and LQGs, as well as to TSDF 

surface impoundments:

 Containers. Subpart CC standards applicable to containers of hazardous wastes are 

specified in §§264.1086 and 265.1087. There are three levels of air emission controls 

for containers based on container size, organic contents, and whether the container is 

used in a waste stabilization process. Container Level 1 controls require that the 

hazardous waste be stored in an approved Department of Transportation (DOT) 

container, a container equipped with a cover and closure devices for each opening, or 

an open-top container with an organic vapor-suppressing barrier. Container Level 2 

controls require that the hazardous waste be stored in an approved DOT container, a 

container that operates with no detectable organic emissions, or a demonstrated vaportight container. Container Level 3 controls require that the hazardous waste be stored 

in a container that is either vented directly to a control device or is located inside an 

enclosure that is vented through a closed-vent system to a control device. Design and 

operating criteria are specified in the rule for the enclosure, closed-vent system, and 

control device.

 Tanks. Subpart CC standards applicable to tanks containing hazardous wastes are 

specified in §§264.1084 and 265.1085. There are two levels of air emission controls for 

tanks based on the size of the tank, maximum organic vapor pressure of the waste, and 

whether the tank is used in a waste stabilization process. The owner or operator is 

responsible for determining whether Tank Level 1 or Tank Level 2 controls are 

applicable.

 Surface impoundments. Subpart CC standards applicable to surface impoundments 

containing hazardous wastes are found in §§264.1085 and 265.1086.To control air 

emissions from a surface impoundment managing a hazardous waste with a VO 

concentration >500 ppmw, an owner or operator must install and operate either a 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-6

floating membrane cover or a cover that is vented through a closed-vent system to a 

control device. 

Land Disposal Restrictions (LDR) Regulations (Part 268)

The 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA prohibit the land 

disposal of specific groups of hazardous waste, unless it has been determined that there 

will be no migration of the hazardous constituents for as long as the waste remains 

hazardous. The amendments also required EPA to establish treatment standards for all 

listed and characteristic wastes, expressed as concentration levels or methods of treatment 

that will reduce their toxicity and make them protective for land disposal. These treatment 

standards are found in Part 268, Subpart D. LDRs apply to all generators (except 

conditionally exempt small quantity generators) and transporters of hazardous waste, as 

well as to owners and operators of treatment, storage, and disposal facilities (TSDFs).

Generators must determine whether their waste is subject to the LDRs for each hazardous 

waste at the point of generation, or alternatively, ask the treatment facility to do so. HSWA 

requires that both listed and characteristic determinations be made for each waste as 

specified. The generator can make this determination using acceptable knowledge, by 

conducting a total waste analysis, or by testing the waste extract. If a generator determines 

the waste is prohibited from land disposal and elects to treat the waste on site (in 

accumulation tanks, containers, or containment buildings regulated under 40 CFR 262.34), 

a written waste analysis plan (WAP) must be developed to describe the procedures the 

generator will carry out to comply with the treatment standards and the plan must be kept 

on site in the generator’s records. Although no specific criteria are established for 

generators developing a WAP in accordance with §268.7(a)(5), the plan should be written in 

accordance with the procedures prescribed in this manual (i.e., describe the physical and 

chemical analysis that will be conducted on a representative sample of the waste(s) being 

treated, and specifically describe the frequency of testing). WAPs are not required from 

generators who are treating for purposes other than meeting the LDR treatment standards. 

Treatment/storage facilities are responsible for including in their WAP (§§264.13/265.13) 

procedures used to corroborate that correct treatment standards have been selected for 

incoming wastes and provisions for testing the waste to verify that it meets the LDR 

treatment standard(s). These facilities will receive the generators’ certification and any 

available waste analysis data provided by the generator (§§264.73, 265.73). However, 

upon subsequent management of the waste, the treatment/storage facility, like the 

generator who ships directly to a disposal facility, must certify to the disposal facility that 

the waste meets the applicable treatment standards.

The disposal facility receives certifications that the waste meets the LDR treatment 

standards from generators and treatment/storage facilities. The results of waste analysis or 

other information on the waste’s properties should also be provided by generators or 

treaters of the waste. The disposal facility must conduct sampling and analysis of incoming 

wastes to verify that wastes meet the relevant treatment standards for the specific waste. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-7

The procedures for waste sampling and analysis, including the frequency of testing, must 

be documented in the facility’s WAP.

Since the 1994 edition of this manual was issued, there have been many amendments to 

the LDR program. Some key amendments include the following:

 EPA published the Phase II Rule on September 19, 1994 (Federal Register 59:180 (19 

September 1994) p. 47982). This rule consolidated the existing treatment standards 

into §268.40, created the Universal Treatment Standards (UTS), and established

treatment standards for toxicity characteristic organic wastes, and the coke byproducts and chlorotoluenes listed wastes.

 EPA published the Phase III Rule and subsequent partial rescission on April 8, 1996 

(Federal Register 61:68 (8 April 1996) p. 15566 and Federal Register 61:68 (8 April 

1996) p. 15660). These rules modified treatment standards for reactive wastes and 

decharacterized wastewaters, and established new treatment standards for the 

carbamate and spent aluminum potliner listed wastes. Even though Phase III 

established treatment standards for these newly identified carbamate wastes, in the 

case, Dithiocarmbamate Task Force v. EPA, the D.C. Circuit Court of Appeals vacated 

several carbamate hazardous waste listings, thus nullifying their corresponding LDR 

treatment standards. EPA thus amended its regulations to conform with the ruling 

(Federal Register 62:116 (17 June 1997) p. 32973).

 EPA published the first half of the Phase IV Rule on May 12, 1997 (Federal Register 62:91 

(12 May 1997) p. 25997). This rule established treatment standards for the wood 

preserving listed wastes and streamlined the LDR notification requirements. EPA 

promulgated part two of the Phase IV Rule on May 26, 1998 (Federal Register 63:100 (26 

May 1998) p. 28555). This rule established treatment standards for several metalcontaining listed wastes and certain newly identified mineral processing listed wastes, 

and revised the universal treatment standards for twelve metal constituents. The rule 

also created a new treatability group, soil, and established soil specific alternative 

treatment standards.

Further discussion of LDRs is available in:

 Land Disposal Restrictions: Summary of Requirements, EPA530-R-01-007, U.S. 

Environmental Protection Agency, Revised 2001. 

 Introduction to Land Disposal Restrictions (40 CFR Part 268), EPA530-K-05-013, U.S. 

Environmental Protection Agency, September 2005. 

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

Innovation Rule (MIR)

The EPA publication SW-846, Test Methods for Evaluating Solid Waste, Physical/ Chemical 

Methods, is the official compendium of analytical and sampling methods that have been 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX B: Regulatory Summary B-8

evaluated and approved for use in complying with the RCRA regulations. SW-846 functions 

primarily as a guidance document setting forth acceptable, although not required, methods 

for the regulated and regulatory communities to use in responding to RCRA-related sampling 

and analysis requirements. Additionally, SW-846 is periodically updated to incorporate 

advances in analytical instrumentation and techniques, to support changes in the regulatory 

program, and to improve method performance and cost effectiveness.

While SW-846 was originally intended to serve as a guidance manual of generally 

appropriate and reliable analytical methods, some of the regulations required the use of 

SW-846 methods. Therefore, all of the publication had to be incorporated by reference 

in 40 CFR 260.11(a) . To address this, EPA proposed to remove certain required uses of 

SW-846 methods, and to allow more flexibility in test method selection. This amendment 

has come to be known as, “The Methods Innovation Rule” (MIR), which includes the 

following revisions (see MIR Web page):

 Certain SW-846 testing regulations will allow the use of other practical test methods. In 

other instances, some required uses of SW-846 methods, referred to as method-defined 

parameters, remain in the regulations because they involve determinations (e.g., TCLP), 

which can only be made by the method specified. See §260.11 for a complete list of 

required test methods in RCRA.

 Removes requirements to use Chapter Nine, “Sampling Plan,” of SW-846 in certain 

circumstances.

 Amends Sections 7.3.3 and 7.3.4 of SW-846 Chapter Seven to withdraw the:

 Cyanide and sulfide reactivity guidance.

 Required uses of reactive cyanide and sulfide methods.

 Threshold levels from conditional delistings.

For additional information, including the latest method updates, guidance and Federal 

Register notices, visit the SW-846 homepage.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-1

Appendix C:

Regulatory Citations for Conducting Waste 

Analysis

Regulatory Citations Specific to Waste Analysis Plans, Waste Analysis, 

and Waste Determination 

This appendix presents a table identifying many, but not necessarily all, of the federal 

hazardous waste analysis requirements found in 40 CFR Parts 262 through 266, 268 and 

270. The table indicates if the requirements apply to generators, permitted TSDFs, and/or 

interim status TSDFs. The table includes links to these requirements on the Web (CTRL + 

Click to follow link). Go to www.gpo.gov/fdsys for the full regulatory text. Following the 

table is a brief regulatory discussion of remediation waste and wastewaters. 

The information in this appendix is provided solely as guidance for permit applicants, 

permit writers, and others. It is not intended for compliance or enforcement purposes. 

It is current as of 2014. Refer to your state’s regulations to learn the up-to-date 

requirements that apply to you, as they may be more stringent and/or broader in 

scope than the federal program. 

Table of Waste Analysis and WAP Requirements

Regulation Generator

Permitted 

TSDFa

Interim status

TSDFa

Generators (Part 262)

Generator hazardous waste determinations 262.11

University Laboratories XL Project Subpart J of Part 

262

Subpart K—alternative requirements for hazardous 

waste determination and accumulation

of unwanted material for laboratories owned by 

eligible academic entities

Subpart K of 

Part 262

TSDFs (Parts 264 and 265)

Hazardous waste analyses and waste analysis plans 264.13 265.13

Manifest system and operating record requirements Subpart E of 

Part 264 Subpart E of Part 265

Closure of hazardous waste management unit or 

facility 264.113 265.113

Containers: special requirements for incompatible 

wastes

264.177

Tanks: waste analysis and trial tests 265.200

Surface impoundments: waste analysis and trial tests 265.225

Waste piles: waste analysis 265.252

Land treatment: waste analysis 265.273
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-2

Regulation Generator

Permitted 

TSDFa

Interim status

TSDFa

Landfills: design and operation 265.301

Incinerators: waste analysis 264.341 265.341

Thermal treatment: waste analysis and trial tests 265.375

Chemical, physical and biological treatment: waste 

analysis and trial tests 265.402

Test methods and procedures for organic air 

emissions for process vents under Subpart AA 265.1034b

264.1034 265.1034

Test methods and procedures for organic air

emissions for equipment leaks under Subpart BB 265.1063b

264.1063 265.1063

Waste determination procedures for organic air 

emissions from containers, tanks and surface 

impoundments under Subpart CC

265.1084b264.1083 265.1084

Boilers and Industrial Furnaces (Part 266)

Boilers and industrial furnaces (BIFs): analysis of Part 

261 Appendix VIII constituents for trial burn, etc. 266.102(b)

Boilers and industrial furnaces (BIFs): stack emissions 

testing 266.103(c)(3)(ii)(B)

Methods manual for compliance with the BIF 

regulations Appendix IX to Part 266

Land Disposal Restrictions (Part 268)

Analysis of wastes treated in surface impoundments 268.4

Analysis of wastes to be placed in landfills under Land 

Disposal Restrictions (LDR) petition 268.6

LDR requirements for generators, treaters and 

disposers to determine if their waste meets LDR 

treatment standards and to comply with related 

requirements

268.7(a), (b), and (c)

LDR requirement for generators and TSDFs to test 

their wastes that are subject to a variance from a 

treatment standard

268.44

Permitting Requirements (Part 270)

Requirements to include waste analysis data and 

WAP in Part B permit application 270.14

Incinerators: submittal of waste analysis data in Part 

B permit application 270.19

Land treatment facilities: submittal of waste data in 

Part B permit application 270.20

Incinerators: submittal of waste analysis data for trial 

burn 270.62

Boilers and industrial furnaces: submittal of waste 

analysis data for trial burn 270.66

Requirement for submittal of WAP by applicant of 

standardized permit for tanks and containers 270.275

a. TSDFs that generate hazardous waste are subject to the Part 262 generator standards (i.e., the “Generator” column in this table), as 

applicable.

b. Large quantity generators are subject to the organic air emission standards at Subparts AA, BB, and CC of Part 265. Small quantity generators 

are not subject.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-3

Other Regulatory Resources

1. Remediation Waste Identification

Many facilities will generate some type of remediation waste whether it is from 

incidental spills or from historical contamination. These wastes also need to be 

properly identified. Note that not all remediation wastes are subject to the RCRA 

Subtitle C hazardous waste requirements. As with any other solid waste, remediation 

wastes are subject to RCRA Subtitle C only if they are listed hazardous wastes, derived 

from a listed waste or identified as characteristically hazardous waste. Environmental 

media are likewise subject to RCRA Subtitle C only if they contain listed hazardous 

waste, are derived from a listed waste or are identified as characteristically hazardous 

waste. These distinctions are discussed more completely in the guidance document,

Management of Remediation Waste under RCRA (530-F-98-026, 1998).

2. Wastewater Treatment Sludge Disposal 

Almost every business or industry generates wastewater. If you generate an industrial 

wastewater, you may have to treat it before you can sewer it, discharge it into a stream or 

lake, or do something else with it. If you treat your wastewater, you may generate 

industrial wastewater treatment sludge. Wastewater treatment sludge is a solid waste and 

may also be a hazardous waste. Both require special management.

A. What is Wastewater Treatment Sludge?

The treatment of wastewaters frequently produces sludge. 40 CFR 260.10 defines 

wastewater treatment sludge as “any solid, semi-solid or liquid waste generated from a 

municipal, commercial, or industrial waste water treatment plant, water supply treatment 

plant, or air pollution control facility exclusive of the treated effluent from a wastewater 

treatment plant.” 

Any sludge that is not domestic wastewater sludge is industrial sludge. This includes 

wastewater sludge from manufacturing or processing of raw materials, intermediate 

products, final products or other activities that include pollutants from non-domestic 

wastewater sources.

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

The treatment of wastewaters is generally exempt from hazardous waste regulation if 

done in a “Waste Water Treatment Unit” (WWTU) that meets the definition noted below. 

Sludges, while they remain in an active WWTU, are not normally regulated as hazardous 

wastes. If the wastewaters in the WWTU go directly from that unit into a municipal sewer, 

and travel through that sewer to a “Publicly Owned Treatment Works” (POTW) after 

mixing with sanitary wastes as outlined below, the wastewaters are not subject to a 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-4

hazardous waste determination or otherwise regulated as hazardous waste unless they 

leak from the sewer prior to reaching the POTW.

Prior to entering the sewer system and meeting the criteria outlined below, the waste may 

be a solid and a hazardous waste subject to hazardous waste regulation during generation, 

storage, and treatment.

Once the waste has been discharged to the POTW, it is subject to Clean Water Act (CWA) 

and local restrictions. However, sludges generated from a POTW are solid and may be 

hazardous wastes. Note that the CWA may prohibit discharges of certain chemicals and 

wastes into a sewer system. 

In summary, mixtures of sanitary wastes and other wastes (including hazardous industrial 

wastes) that pass through a municipal sewer system to a POTW may be excluded from 

hazardous waste regulations. The exclusion applies to a waste at the point where it first 

mixes with sanitary wastes in the municipal sewer system if this mixing occurs prior to 

reaching the POTW property boundary. This exclusion does not apply to any waste directly 

transported to the POTW by truck or rail shipments. This exclusion also presumes that the 

mixture actually arrives at the POTW. In addition, the exemption is lost for any mixture in 

the municipal sewer system that leaks from the system prior to arrival at the POTW.

C. When is Wastewater Treatment Sludge a Hazardous Waste?

If industrial or processing wastes are removed from the wastewater treatment unit prior to 

being discharged into the sewer or do not pass through a municipal sewer to a POTW, they 

are subject to a hazardous waste determination. Unless they have mixed with sanitary 

wastes in a municipal sewer, these sludges may be listed or characteristic hazardous 

wastes. If the wastewaters going into the WWTU are listed hazardous waste, the sludges 

from the WWTU will also be listed hazardous waste.

D. How Do You Manage a Hazardous Waste Sludge?

Several hazardous waste codes may apply to your sludge depending on your industrial 

processes. Depending on what hazardous waste codes would apply to your sludge, and its 

physical and chemical nature, you might have a number of management options. You 

might have to dispose of it as hazardous waste at a permitted hazardous waste landfill or 

incinerator. You might be able to manage it under different requirements through some 

form of reclamation or recycling. You may be able to reuse the material if the use is 

legitimate according to U.S. Environmental Protection Agency or authorized state 

regulatory authority (i.e., the proposed use is not a subterfuge to avoid regulation of the 

material as hazardous waste). 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX C: Regulatory Citations for Conducting Waste Analysis C-5

E. Definitions

Publicly Owned Treatment Works (POTW) means a treatment works, as defined by 

Section 212 of the Clean Water Act (CWA) that is owned by the state or municipality. This 

definition includes any devices and systems used in the storage, treatment, recycling, and 

reclamation of municipal sewage or industrial wastes of a liquid nature. It also includes 

sewers, pipes, and other conveyances only if they convey wastewater to a POTW treatment 

plant [40 CFR 403.3]. Privately-owned treatment works, Federally-owned treatment 

works, and other treatment plants not owned by municipalities are not considered POTWs.

Tank means a stationary device, designed to contain an accumulation of hazardous waste, 

which is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic) 

which provide structural support. (From 40 CFR 260.10). 

Tank system means a hazardous waste storage or treatment tank and its associated 

ancillary equipment and containment system. (From 40 CFR 260.10). 

Wastewater treatment unit means a device which: 

(1) Is part of a wastewater treatment facility that is subject to regulation under either 

section 402 or 307(b) of the CWA; and 

(2) Receives and treats or stores an influent wastewater that is a hazardous waste as 

defined in §261.3 of this chapter, or that generates and accumulates a wastewater 

treatment sludge that is a hazardous waste as defined in Sec. 261.3 of this chapter, or 

treats or stores a wastewater treatment sludge which is a hazardous waste as defined 

in Sec. 261.3 of this Chapter; and 

(3) Meets the definition of tank or tank system §260.10 of this chapter. (From 40 CFR 

260.10) 

The Agency has never defined “wastewater” in the Subtitle C regulations, except for the 

wastewater definition in Part 268 for the Land Disposal Restrictions (LDR) Program (the 

definition in Part 268 applies only to the LDR program). Typically, EPA has used a very 

broad interpretation of “wastewater” in other regulatory programs (e.g., the Effluent 

Guidelines Division's Development Document for Electroplating Pretreatment Standards 

defines wastewater as “any water that has been released from the purpose for which it was 

intended to be used”). (See RCRA Online No. 11551.) 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX D: Overview of Major Hazardous Waste Management Units D-1

Appendix D: 

Overview of Major Hazardous Waste 

Management Units

Containers—Parts 264 and 265, Subpart I

Containers are portable devices used to treat, store, transport, and handle waste materials. 

They include metal drums and pails, polyfiber bags, plastic drums and carboys, or durable 

fiberboard paper drums or pails. They do not include tanks, which are regulated separately, 

as discussed below. Metal and plastic drums and pails are the most commonly used 

containers; however, durable fiber drums (used most often to store and transport solids 

designated for incineration) and drums constructed of other materials are also used. Before 

selecting a container for storage or treatment of the waste, you should identify its physical 

and chemical characteristics to ensure that it is compatible with the waste. The selection of 

waste analysis parameters will be dependent upon the specific characteristics of the wastes 

you manage and the construction materials of the container used at your facility. You 

should consider performing laboratory analysis on a sample of your wastes for parameters 

such as flash point, pH, reactivity, and moisture content.

Tanks— Parts 264/265, Subpart J

Tanks are stationary devices constructed primarily of non-earthen materials designed to 

contain an accumulation of hazardous waste(s). They do not have to be totally enclosed and 

they are generally distinguished from surface impoundments because they are selfsupporting (i.e., they do not need external support materials, such as earth). They are 

generally constructed of metal, fiberglass, or rugged plastics.

Surface Impoundments—Parts 264/265, Subpart K

Surface impoundments are natural depressions, man-made excavations, or diked areas, 

formed primarily of earthen materials, used to contain an accumulation of liquids or wastes 

containing free liquids. Examples of surface impoundments are ponds, lagoons, and 

holding, storage, settling and aeration pits. Surface impoundments can be used for 

treatment (as provided by 268.4 for managing prohibited waste), or for storage or disposal 

as long as the wastes already meet the LDR treatment standards.

Although surface impoundments are constructed primarily of earthen materials, they often 

can have components made of synthetic materials, such as liners and leak detection 

systems. Synthetic materials that are most often used in the construction of liners include 

high-density polyethylene, chlorinated polyethylene, and polyvinyl chloride. Leak detection 

and leachate collection systems can be constructed from a number of geosynthetic textile 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX D: Overview of Major Hazardous Waste Management Units D-2

materials, including polyethylene, polypropylene, and polyester. Surface impoundments 

may be equipped with a variety of high-strength polymer plastic piping (e.g., polyvinyl 

chloride) to aid in the removal of liquids that have accumulated in leachate collection 

systems, a component of the leak detection system.

Landfills—Parts 264/265, Subpart N

Landfills are disposal units where hazardous wastes are placed in or directly on land. In the 

RCRA regulations, waste piles, surface impoundments, land treatment units, underground 

injection wells, salt dome formations, mines, or caves are not regulated as landfills. 

Landfills are usually man-made excavations, but their designs invariably include the use of 

synthetic materials for liners, caps, and leachate collection systems. These synthetic 

materials may include high-density polyethylene, chlorinated and sulfurated polyethylene, 

polyvinyl chloride (PVC), and other geosynthetic textiles.

Containment Buildings— Parts 264/265, Subpart DD

Containment buildings are enclosed structures used to store or treat hazardous waste. 

They must be completely enclosed to prevent exposure to precipitation and wind, and be 

constructed of man-made materials of sufficient strength and thickness to support 

themselves, the waste contents, and any personnel and heavy equipment that operate 

within the unit.

Wastes managed in containment buildings cannot be in liquid form (i.e., flow under their 

own weight to fill the vessel in which they are placed, or be readily pumpable). However, 

containment buildings can be used to manage hazardous wastes containing free liquids, 

but must include a primary barrier to prevent migration of hazardous constituents into 

the barrier and a liquid collection and removal system that will minimize the 

accumulation of liquid on the primary barrier; and be equipped with secondary 

containment including (1) a secondary barrier and (2) a leak detection, collection, and 

removal system. Containment buildings must have a primary barrier designed and 

constructed of materials to prevent hazardous wastes from being accidentally or 

deliberately placed on the land beneath or outside the unit. They must also have controls 

to prevent fugitive dust emissions and the tracking of materials from the unit by 

personnel or equipment. Under certain conditions, containment buildings may serve as 

secondary containment for tanks placed within the containment building.

As with tanks and containers, generators may accumulate and treat their hazardous wastes 

within these containment buildings without obtaining a RCRA Subtitle C permit. Generators 

treating hazardous wastes in order to comply with the applicable land disposal restrictions 

treatment standards must develop and follow a written waste analysis plan.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX D: Overview of Major Hazardous Waste Management Units D-3

Waste Piles— Parts 264/265, Subpart L

Waste piles are areas used for non-containerized storage or treatment of solid, non-flowing 

wastes on the land. Waste piles are normally underlain by liners constructed of concrete or 

other materials, which act as barriers to prevent direct contact of the waste with the soil 

below the unit. Waste piles that are protected from wind, precipitation, and surface water 

run-on, and that are not containment buildings, are subject to reduced regulations. Waste 

piles and their associated liners and leak detection systems can be constructed of synthetic 

materials, including high-density polyethylene and PVC for liners, and a number of 

different geosynthetic textiles (e.g., polyester polypropylene) for leak detection apparatus. 

Waste piles also use a variety of high-strength polymer plastic pipes for the removal of 

leachate and other liquids that have accumulated in leachate collection systems; these are 

often made of polyvinyl chloride. Because of the impact of the Land Disposal Restriction 

program, most hazardous wastes cannot be placed on a waste pile until they meet the 

applicable LDR treatment standards in Part 268, Subpart D.

Land Treatment Units—Parts 264/265, Subpart M

Land treatment units are units where hazardous waste is applied or incorporated into the 

soil surface. Land treatment units are typically units consisting of natural soils where 

natural biological and chemical degradation and attenuation processes immobilize, 

transform, or degrade hazardous constituents over time. These soils are normally prepared 

in a manner that maximizes these reactions in the upper layers of soil (the treatment zone), 

and minimizes processes that might inhibit beneficial reactions or result in the release of 

hazardous constituents (such as surface water run-off). Because of the impact of the LDR 

program, most hazardous wastes cannot be placed in a land treatment unit until they meet 

the applicable LDR treatment standards, unless a no migration exemption has been granted 

under §268.6.

Miscellaneous Units—Part 264, Subpart X

Miscellaneous units (e.g., salt domes, burn pans, open burning or detonation grounds) 

include a variety of types of units that are not covered by any other permit standards under 

RCRA. A miscellaneous unit is a hazardous waste management unit where hazardous 

waste is treated, stored, or disposed of and that is not a container, tank, surface 

impoundment, pile, land treatment unit, landfill, incinerator, boiler, industrial furnace, 

underground injection well with appropriate technical standards under 40 CFR Part 146, 

containment building, corrective action management unit, unit eligible for a research, 

development, and demonstration permit under §270.65, or staging pile. Permits for 

miscellaneous units are to contain such terms and provisions as necessary to protect 

human health and the environment, including, but not limited to, as appropriate, design 

and operating requirements, detection and monitoring requirements, and requirements for 

responses to releases of hazardous waste or hazardous constituents from the unit. Permit 

terms and provisions must include those requirements of Subparts I through O and 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX D: Overview of Major Hazardous Waste Management Units D-4

Subparts AA through CC of Part 264, Part 270, Part 63 Subpart EEE, and Part 146 that are 

appropriate for the miscellaneous unit being permitted. 

Hazardous Waste Combustors

Hazardous waste combustors (HWCs) are differentiated based on how the CAA defines 

source categories and how the combustion unit is designed and operated. Certain types 

of boilers and industrial furnaces (BIFs) and incinerators that burn hazardous waste are

examples of hazardous waste combustors. Hazardous waste combustors are subject to 

applicable regulatory requirements pursuant to both the RCRA Subtitle C program and 

the Clean Air Act (CAA) National Emission Standards for Hazardous Air Pollutants 

(NESHAP) program.

Prior to the adoption of the CAA Hazardous Waste Combustor (or HWC) NESHAP standards, 

emissions from RCRA hazardous waste combustion units were regulated according to 40 

CFR Parts 264 and 265 (for incinerators) and Part 266 (for BIFs). Thus, for BIFs and 

incinerators, the RCRA emission standards/limitations and related operating requirements 

resided in the RCRA permit or interim status regulations, and all waste analysis 

requirements to comply with the requirements were located in the waste analysis plan 

(WAP). Between 1999 and 2005, EPA established new CAA HWC NESHAP emission 

standards, testing and operating requirements for incinerators, cement kilns, lightweight 

aggregate kilns, boilers, and hydrochloric acid (HCl) production furnaces burning hazardous 

waste. The CAA HWC NESHAP is codified in Part 63, Subpart EEE. 

In order to avoid (to the extent practicable) having duplicative emission standards and 

operating requirements in the RCRA permit and the CAA notification of compliance and 

Title V permit, EPA established a regulatory approach allowing a facility to modify its RCRA 

permit to remove most or all emission standards and emission related operating 

requirements that are covered by the CAA HWC NESHAP once the source demonstrated 

compliance with Part 63, Subpart EEE. Under this approach, the CAA HWC NESHAP 

emission standards and emission related operating requirements reside in the CAA 

notification of compliance and Title V permit, while the other RCRA requirements 

associated with the combustion unit and the facility remain in the RCRA permit. Examples 

of requirements that continue to be part of the RCRA permit for HWCs include general 

facility standards, WAPs, closure plans, contingency plans, financial assurance, corrective 

action, and RCRA omnibus provisions. 

The table below crosswalks some of the requirements for CAA feedstream analysis plans 

(FAPs) at §63.1209(c) to similar requirements for RCRA WAPs and waste analyses at 

§264.13 and elsewhere in RCRA. It also identifies sections of this manual that may provide 

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

APPENDIX D: Overview of Major Hazardous Waste Management Units D-5

Crosswalk of FAP-WAP Requirements to Sections of this Manual

CAA FAP Requirements at 40 CFR 63.1209(c) RCRA WAP Requirements at 40 CFR 264.13 (and Related Requirements) Sections of this Manual 

Relevant to FAPs 

(c) Analysis of feedstreams—(1) General. Prior to feeding the material, you 

must obtain an analysis of each feedstream that is sufficient to document 

compliance with the applicable feedrate limits provided by this section.

40 CFR 264.13 (a)(1) Before an owner or operator treats, stores, or disposes of 

any hazardous wastes, or non-hazardous wastes if applicable under § 

264.113(d), he must obtain a detailed chemical and physical analysis of a 

representative sample of the wastes. At a minimum, the analysis must contain 

all the information which must be known to treat, store, or dispose of the 

waste in accordance with this part and Part 268 of this chapter.

1.1.2 TSDF Waste Analysis 

Requirements

1.2.1 Sampling and Analysis for 

TSDFs

(2) Feedstream analysis plan. You must develop and implement a 

feedstream analysis plan and record it in the operating record. The plan 

must specify at a minimum:

40 CFR 264.13 (b) The owner or operator must develop and follow a written 

waste analysis plan which describes the procedures which he will carry out to 

comply with paragraph (a) of this section. He must keep this plan at the facility. 

At a minimum, the plan must specify:

1.1.2 TSDF Waste Analysis 

Requirements

Part Two: Documenting and 

Conducting Waste Analysis

(i) The parameters for which you will analyze each feedstream to ensure 

compliance with the operating parameter limits of this section;

40 CFR 264.13 (b)(1) The parameters for which each hazardous waste, or nonhazardous waste if applicable under § 264.113(d), will be analyzed and the 

rationale for the selection of these parameters (i.e., how analysis for these 

parameters will provide sufficient information on the waste's properties to 

comply with paragraph (a) of this section);

2.4 Analysis Parameters

(ii) Whether you will obtain the analysis by performing sampling and 

analysis or by other methods, such as using analytical information obtained 

from others or using other published or documented data or information;

40 CFR 264.13 (a)(2) The analysis may include data developed under Part 261 of 

this chapter, and existing published or documented data on the hazardous 

waste or on hazardous waste generated from similar processes.

1.2 How Can You Meet the Waste 

Analysis Requirements for Your 

Facility?

1.2.2 Acceptable Knowledge and 

TSDFs

(iii) How you will use the analysis to document compliance with applicable 

feedrate limits (e.g., if you blend hazardous wastes and obtain analyses of 

the wastes prior to blending but not of the blended, as-fired, waste, the 

plan must describe how you will determine the pertinent parameters of 

the blended waste);

See 40 CFR 264.13 (b)(1) above. 2.4 Analysis Parameters

(iv) The test methods which you will use to obtain the analyses; 40 CFR 264.13 (b)(2) The test methods which will be used to test for these 

parameters;

40 CFR 264.13 (b) (3) The sampling method which will be used to obtain a 

representative sample of the waste to be analyzed.

40 CFR 264.13 (b) (4) The frequency with which the initial analysis of the waste 

will be reviewed or repeated to ensure that the analysis is accurate and up to 

date

2.4 Analysis Parameters

2.5 Selecting Sampling 

Procedures

2.6 Selecting a Laboratory and 

Laboratory Analytical Methods

2.7 Quantifying Data uncertainty

2.8 Determining Re-Evaluation 

Frequencies

(3) Review and approval of analysis plan. You must submit the feedstream 

analysis plan to the Administrator for review and approval, if requested.

40 CFR 270.14 Contents of Part B [Permit Application]: General Requirements. 

(b)(3) A copy of the waste analysis plan required by 264.13(b) and, if applicable, 

264.13(c).

The need for TSDFs to submit a 

WAP as part of a permit 

application is discussed generally 

in this manual. 

(4) Compliance with feedrate limits. To comply with the applicable feedrate

limits of this section, you must monitor and record feedrates as follows:

(i) Determine and record the value of the parameter for each feedstream 

by sampling and analysis or other method;

(ii) Determine and record the mass or volume flowrate of each feedstream 

by a CMS. If you determine flowrate of a feedstream by volume, you must 

determine and record the density of the feedstream by sampling and 

analysis (unless you report the constituent concentration in units of weight 

per unit volume (e.g., mg/l)); and

(iii) Calculate and record the mass feedrate of the parameter per unit time.

40 CFR 264.341 (b) Throughout normal operation the owner or operator must 

conduct sufficient waste analysis to verify that waste feed to the incinerator is 

within the physical and chemical composition limits specified in his permit 

(under 264.345(b)).

40 CFR 266.102 Permit standards for burners. (b) Hazardous Waste Analysis (2) 

Throughout normal operation, the owner or operator must conduct sampling 

and analysis as necessary to ensure that the hazardous waste, other fuels, and 

industrial furnace feedstocks fired into the boiler or industrial furnace are 

within the physical and chemical composition limits specified in the permit.

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

APPENDIX E: Glossary of Terms E-1

Appendix E:

Glossary of Key Terms

Captive TSDF: A TSDF that receives hazardous wastes only from generators within its 

own corporation. Such generators could be located on the same site as the captive TSDF 

or off-site.

Certification: A written statement of professional opinion and intent signed by an 

authorized representative that acknowledges an owner’s or operator’s compliance with the 

applicable LDR requirements. Certifications are required for, among other things, waste 

analysis and recordkeeping provisions applicable to any person who generates, treats, 

stores, or disposes of hazardous wastes (excluding generators that do not treat on site and 

send waste off site to be treated). The information referenced by the certification must be 

true, accurate, and complete. There may be significant penalties for submitting false 

information, including fines and imprisonment.

Commercial TSDF: A TSDF engaged in the conduct of commercial (i.e., for-profit) waste 

management that receives hazardous wastes generated by other companies. 

Disposal Facility: A facility or part of a facility at which hazardous waste is intentionally 

placed into or on any land or water, and at which waste will remain after closure. The term 

disposal facility does not include a corrective action management unit into which

remediation wastes are placed.

Facility: All contiguous land, structures, or other appurtenances, and improvements on the 

land, used for treating, storing, or disposing of hazardous waste. A facility may consist of 

one or several treatment, storage, or disposal operational units (e.g., one or more landfills, 

surface impoundments, or combinations of them).

Fingerprint Analysis: Sampling and analysis of several key chemical and physical 

parameters of a waste to substantiate or verify the composition of a waste as determined 

previously during a full-scale waste characterization. Fingerprint analysis is typically used 

by generators and off-site TSDFs to expedite waste characterization of frequently 

generated or received wastes. Parameters for analysis may be a subset of the parameters 

used during full-scale characterization, or they may be parameters that are not normally 

present in the waste to verify the absence of certain constituents.

Generator: Any person, by site, whose act or process produces hazardous waste identified 

or listed in Part 261 of RCRA or whose act first causes a hazardous waste to become subject 

to regulation.

Hazardous and Solid Waste Amendments (HSWA): Amendments to RCRA in 1984, that 

minimize the nation’s reliance on land disposal of hazardous waste by, among other things, 

requiring EPA to evaluate all listed and characteristic hazardous wastes according to a 

strict schedule to determine which wastes should be restricted from land disposal.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX E: Glossary of Terms E-2

Hazardous Waste: Per RCRA Section 1004, waste that, because of its quantity, 

concentration, or physical, chemical, or infectious characteristics, may cause or 

significantly contribute to an increase in mortality or an increase in serious irreversible, or 

incapacitating reversible, illness, or pose a substantial present or potential hazard to 

human health or the environment when improperly treated, stored, transported, or 

disposed of, or otherwise managed. Per 40 CFR Part 260.10, hazardous wastes are defined 

in §261.3, which includes listed wastes and/or wastes that exhibit one of the four 

characteristics (i.e., ignitability, corrosivity, reactivity, and toxicity).

Hazardous Waste Code: The number assigned by EPA to each hazardous waste listed in 

40 CFR Part 261, Subpart D, and characteristic waste identified in 40 CFR Part 261, 

Subpart C.

Interim Status: A facility that can operate without a RCRA Subtitle C permit provided 1) 

the facility was in existence on November 19, 1980; 2) the facility is in existence on the 

effective date of a new regulation that lists a waste as a hazardous waste or establishes a 

new characteristic of hazardous waste; or 3) the facility is in existence on the effective date 

of a new regulation that regulates a hazardous waste management unit for the first time. In 

both circumstances, Part A of the permit application must be submitted to EPA by a 

specified date (with Part B submitted voluntarily or “called in ” by EPA at a subsequent 

date). The intent of interim status is to allow a facility to continue to operate for an interim 

period pending approval of their permit application.

Lab Pack: A lab pack is an over packed container, usually a steel, fiber, or polyethylene 

drum, containing small containers of chemicals of the same hazardous class packed in nonbiodegradable absorbent materials.

Land Disposal Restrictions: Provision of HSWA that prohibits the land disposal of 

hazardous wastes, unless EPA finds that it will not endanger human health and the 

environment. EPA must develop levels or methods of treatment that substantially diminish 

the toxicity of the waste or the likelihood that hazardous constituents will migrate from the 

waste that must be met before the waste is land disposed. Strict statutory deadlines were 

imposed on EPA to regulate the land disposal of specific hazardous wastes, concentrating 

first on the most harmful. 

Lower Limit of Quantitation: The lowest concentration at which the laboratory has 

demonstrated target analytes can be reliably measured and reported with a certain degree 

of confidence, which must be ≥ the lowest point in the calibration curve. Laboratories may 

use alternative terms, such as “reporting limit.” Regulated entities should consult their 

state agency for the appropriate use of terms because it can depend on the context in which 

the term is used. For more information, see Update V to SW-846.

Notification: In the context of the LDR program, when restricted wastes are being shipped 

off-site for treatment, storage, disposal, or are managed on-site, EPA has established a 

tracking system that requires that notifications and certifications be sent to the receiving 

facility or if applicable to EPA or the appropriate EPA representative. These requirements 

are outlined in 40 CFR 268.7. For example, notification requirements include the EPA 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX E: Glossary of Terms E-3

Hazardous Waste Number, corresponding treatment standards or prohibition levels, the 

manifest number, and waste analysis data.

Off-Site Facility: A facility that receives and manages hazardous waste from another 

facility that is not geographically on site.

On-Site Facility: A facility that manages only those hazardous wastes that are generated 

on its own geographic site.

Prohibited Wastes: Prohibited wastes are a subset of restricted wastes (under the LDR 

regulations) that have established treatment standards but do not meet the respective 

treatment standards, nor have a variance or waiver in effect and are, therefore, ineligible 

for land disposal.

RCRA Subtitle C Permit: An authorization via a permit from EPA that allows a facility to 

treat, store, and/or dispose of hazardous wastes. The permit includes administrative 

requirements and facility operating and technical standards for each type of waste 

management unit that is being permitted. [Facility owners/operators must submit a twopart (Part A and Part B) permit application to obtain a RCRA Subtitle C permit.]

Reporting Limit: The lowest reported concentration of analytes provided on a laboratory 

report after adjustments have been made for sample dilution, sample weight and amount of 

moisture. Laboratories may use alternative terms, such as “lower limit of quantitation.” 

Regulated entities should consult their state agency for the appropriate use of terms 

because it can depend on the context in which the term is used. For more information, see 

Update V to SW-846.

Resource Conservation and Recovery Act (RCRA): The Resource Conservation and 

Recovery Act of 1976 (which amended the Solid Waste Disposal Act of 1965) regulates 

both hazardous wastes and non-hazardous wastes. RCRA has been amended three times, 

most significantly, on November 8, 1984. The 1984 amendments known as the Hazardous 

and Solid Waste Amendments (HSWA) significantly expanded the scope and requirements 

of RCRA.

Restricted Wastes: Restricted wastes are those RCRA hazardous wastes that are subject to 

the LDR program. A waste is restricted if EPA has established a treatment standard for it, or 

if it has been specifically designated by Congress as ineligible for land disposal. While some 

restricted wastes may be eligible for land disposal without meeting treatment standards, all 

restricted wastes are, at a minimum, subject to the waste analysis, notification, and 

recordkeeping requirements of 40 CFR 268.7.

State Director: A term used in the RCRA regulations to denote the state hazardous waste 

agency.

Storage Facility: A facility that holds hazardous waste for a temporary period, at the end of 

which the hazardous waste is treated, disposed of, or stored elsewhere.

Subtitle C Facility: A facility that manages hazardous wastes as defined by RCRA. These 

facilities may include, disposal facilities (e.g., landfills, surface impoundments), treatment 

facilities, (e.g., incinerators) and storage facilities.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX E: Glossary of Terms E-4

Subtitle D Facility: A facility that manages non-hazardous wastes as defined by RCRA. 

These facilities may include disposal facilities (e.g., landfills), treatment facilities (e.g., 

incinerators), and storage facilities.

Toxicity Characteristic Leaching Procedure (TCLP): A method to determine the mobility 

of both organic and inorganic contaminants in liquids, solids, and multiphasic wastes. 

Transporter: A person engaged in the off-site transportation of hazardous waste by air, 

rail, highway, or water.

Treatment Facility: A facility that uses any method, technique, or process, including 

neutralization, designed to change the physical, chemical, or biological character or 

composition of any hazardous waste so as to neutralize such waste, or to render such waste 

either non-hazardous or less hazardous; appropriate to transport, store, or dispose of; or 

amenable for recovery, amenable for storage, or reduced in volume.

Waste Analysis: Obtaining a detailed chemical and physical analysis of a representative 

sample of a waste. The analysis may include data developed using sampling and analysis, as 

well as existing published or documented data on the waste or waste generated from 

similar processes. Use of the phrase “waste analysis” refers to both waste testing and 

applying acceptable knowledge

Waste Analysis Plan (WAP): Document describing the procedures that will be carried out 

at a facility to meet waste analysis requirements.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX F: Key Considerations and Tips F-1

Appendix F: 

Key Considerations and Tips

Key Considerations for Waste Analysis Plans

 WAPs are not one-size-fits-all; a WAP that is appropriate for a commercial treatment/

storage/disposal facility may not be appropriate for treatment/disposal facilities, or even 

captive storage facilities.

 Do not clutter up the WAP by repeating information that exists elsewhere in the permit 

(e.g., basic facility description, process descriptions).

 Prepare procedures for subjecting all wastes to the same level of analysis, not just 

hazardous wastes.

 Focus on up-front waste profiling; this is especially important for “back-end”

treatment/disposal facilities.

 Include some amount of off-site independent laboratory analysis. It is important to 

conduct waste testing as opposed to relying solely on just generator acceptable 

knowledge. Procure a laboratory with a state laboratory certification program or other 

reputable third-party accreditation. It is very difficult for a TSDF to maintain an 

adequate on-site lab.

 Include electronic records management tools used by the facility, [e.g., Excel 

spreadsheets and custom software programs].

 Recommend that all wastes received are subject to some level of waste analysis not just 

those received as “hazardous waste.”

 Specify the test methods (SW-846, ASTM, or other) to be used to test for each 

parameter, in accordance with 40 CFR 264.13(b)(2).

 Include sampling protocols for different containers and transport vehicles (e.g., drums 

and tankers) and different materials or phase-separated wastestreams.

 Recommend the facility perform a “discrepancy review” when the waste acceptance 

testing shows a certain percentage variance (trigger level to be negotiated with the 

permit writer) from the waste profile data (e.g., for Btu value discrepancy, require a 

discrepancy review if the Btu value varies by more than 15%).

 Provide documentation for discrepancies and resolution (e.g., rejected load or modified 

profile) in the facility operating record. Provide documentation of any unusual 

conditions that occur after the waste has passed acceptance criteria and waste is 

accepted into the facility (e.g., a tank farm).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX F: Key Considerations and Tips F-2

Key Considerations for the Permitting Agency and Inspectors

 Become familiar with the facility; schedule a visit.

 Use clear, enforceable language when preparing permit conditions and require the 

same from the facility in their permit application (e.g., use “must” and “shall” as 

opposed to “may” or “should”).

 Include a permit condition requiring notification of any changes to the WAP or deviation 

from a test method.

 Maintain a generic permit template that includes all federal/state conditions. Keep it 

up-to-date.

 During inspections or compliance evaluations, consider using someone on-staff (Agency 

or Agency contractor) with a chemistry or laboratory background to evaluate WAP 

compliance.

Key Considerations for Generators

 Learn your legal responsibilities under RCRA and your state’s hazardous waste program 

by reviewing your state’s generator standards and guidance.

 Speak with the personnel at your site and compile paperwork to develop a collective 

knowledge of your generating processes, potential wastes, regulatory requirements, and 

opportunities for waste minimization.

 Contact your state agency, or the agency in the TSDF’s state, if you have questions (e.g., 

should the analyses be performed by certified laboratory?).

 If you do not have the expertise at your facility, consider using a qualified consultant or 

TSDF for assistance in identifying, collecting, and characterizing your waste, but note that, 

as the generator, you are ultimately responsible for the proper identification and 

characterization of your waste.

 Ensure that the implementation of the WAP will avoid mixing of incompatible wastes and 

placing wastes in incompatible accumulation tanks/containers.

 Obtain representative samples for unlisted wastes; that is, a sample of a universal or 

whole (e.g., waste pile, lagoon) waste which can be expected to exhibit the average 

properties’ of the universe or whole. 

 Include procedures for obtaining/maintaining documentation sufficient to support 

waste/acceptable knowledge determinations in lieu of testing (i.e., process knowledge, 

records of analyses or combination of these with actual chemical analysis of the waste).

 Support any claims that secondary materials are NOT solid and/or hazardous waste 

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

APPENDIX F: Key Considerations and Tips F-3

 It is important to not rely on a single analysis to characterize subsequent wastestreams. 

Waste-derived residues should be sampled as often as necessary for the owner/operator 

to determine whether the residue is excluded or fully regulated hazardous waste. All 

waste-derived residue generated since the previous successful analysis could be viewed 

as fully regulated absent documentation demonstrating otherwise.

 Make sure you determine what constitutes a new point of generation especially 

considering applicability of new underlying hazardous constituents (UHCs).

 Use appropriate methods and avoid undocumented methods. 

 Be aware of what happens if the waste contains Appendix VIII constituents but does not 

meet the definition of a hazardous waste (e.g., if UHCs are present in de-characterized 

waste, the LDRs still attach to the waste. See Section 1.1.1 of this manual for additional 

information). 

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

generates the waste changes. 

 Remember that thermal treatment by generators is prohibited except in select units.

 Make sure you adequately address your process description in the WAP when using 

acceptable knowledge especially if it relates to characterizing F- and K- listed wastes. 

Tips for RCRA Inspectors to Evaluate Facility Compliance with Waste

Analysis Plans

 Before inspecting the TSDF, familiarize yourself with the facility’s permit and 

operations generally, including the WAP. Develop a facility-specific inspection plan and 

questions to ask the facility when on-site. Perform database searches and review 

available facility records, such as Biennial Reporting data on the types and quantities of 

wastes received on-site. Reviewing these reporting data may indicate particular 

challenges that the facility may encounter when implementing their WAP (e.g., you may 

notice that some generators are submitting highly variable wastes that could require 

frequent re-characterization). During your inspections, be sure to ask questions about 

these challenges.

 During the inspection, speak with the individual(s) authorized by the TSDF to be 

responsible for ensuring compliance with the WAP (e.g., facility manager or designee) 

to get an overview of the facility’s experiences using the WAP (e.g., problems, concerns, 

questions). This conversation could occur, for example, during the opening meeting. 

Follow up on possible violations, problems, and questions raised. Ask questions about 

key processes and procedures in the WAP to ensure the procedures are correctly 

followed and that the WAP is up-to-date. 

 Ask questions about the pre-qualification process to ensure the facility is evaluating 

new wastestreams adequately. For example, if generic profiles are being used, are they 

used only in appropriate situations (e.g., generic profiles are not appropriate for wastes 

that must meet numerical limits, such as feed streams into combustion units).
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX F: Key Considerations and Tips F-4

 Request the SOPs for some of the sampling analysis being performed by the facility (e.g., 

pH tests) and determine if they are being followed. This can be accomplished, for 

example, by observing facility personnel in the conduct of their job responsibilities (e.g., 

during sampling of drums of an incoming shipment) or by briefly interviewing 

laboratory personnel to evaluate their understanding of these procedures. (See below 

for additional tips on laboratories). 

 Ask the facility how often it has found discrepancies between incoming shipments and 

waste profiles, and review relevant records. In these cases, did the TSDF identify the 

causes and implement appropriate corrective actions to prevent recurrence? Were new 

or revised waste profiles developed in all cases? Ask treaters and disposers how often 

they test their treated wastes for LDR compliance (e.g., each batch)? For wastes that 

have failed to meet applicable LDR standards, what were the causes (e.g., is there a 

pattern of failures suggesting a common cause?) and what corrective actions were 

taken to prevent their recurrence? 

 Review the facility's training records of key personnel (e.g., environmental 

technicians) to verify that they are given frequent training on relevant knowledge 

and skills related to waste sampling and analysis. Interview facility personnel and 

observe them performing their job functions to evaluate their knowledge and skills 

(e.g., ask for facility workers to demonstrate how to properly sample a drum using a 

coliwasa; ask him when a grab vs. composite sample is required for wastes managed 

under this authority).

 For on-site laboratories at a generator or TSDF:

– Ask for a split sample of waste (e.g., a waste that has been treated to meet LDR 

standards) to be sent to an independent laboratory that is trusted by EPA to verify 

the on-site laboratory’s results.

– Make certain that it has the required instrumentation (e.g., does it have a PenskyMartin flashpoint apparatus if that method is how it reports flashpoint and is it 

maintained?) and a trained operator can explain its use. pH is often not correctly 

understood or performed for solid and semisolid waste, so reviewing those 

procedures can be enlightening regarding the actual level of understanding of the 

technicians assigned to these tasks.

– Review the laboratory’s certificate of accreditation (if the state requires laboratory 

accreditation) to make certain that it has achieved and maintained accreditation in 

the parameters it is testing. State accreditation programs universally require that 

accredited laboratories participate in external performance evaluation programs. 

Ask to see records of the evaluations. 

 Consider bringing a chemist or related expert to the inspection to review laboratory 

results (or otherwise, copy analytical records and take them for later review). For 

example, the chemist could review a sample of laboratory results to verify that the 

analytical methods used were appropriate and the detection limits were sensitive 

enough to evaluate compliance with applicable numerical limits.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX G: References G-1

Appendix G: 

References

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

Environmental Protection Agency, 1980. 

Burning of Hazardous Waste in Burners and Industrial Furnaces. Federal Register 56:166 

(27 August 1991). p. 42509. See Discussion on Retroactive Hazardous Waste Designation.

Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous Waste 

Sites, OSWER 9285.6-10, U.S. Environmental Protection Agency, December 2002. 

Characterizing Heterogeneous Wastes: Methods and Recommendations, EPA 600-R-92-033, 

U.S. Environmental Protection Agency and U.S. Department of Energy, February 1992. 

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

Washington, D.C. 

Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s 

Compliance With the Disposal Regulations. Federal Register 67:154 (9 August 2002) p. 

51942. See Discussion on Acceptable Knowledge Definition. 

Design and Development of a Hazardous Waste Reactivity Testing Protocol, EPA-600/52- 84-

057, U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, 

Cincinnati, Ohio, 1984. 

EPA Observational Economy Series, Volume 1: Composite Sampling, EPA 230-R-95-005, U.S. 

Environmental Protection Agency, Washington, D.C., 1995. 

Guidance for Obtaining Representative Laboratory Analytical Subsamples from Particulate 

Laboratory Samples, EPA/600/R-03/027, U.S. Environmental Protection Agency, 2003. 

Guidance Manual for Hazardous Waste Incinerator Permits, SW-966, U.S. Environmental 

Protection Agency, Washington, D.C., 1983. 

Guidance of Systematic Planning Using the Data Quality Objectives Process, EPA240-B-06-

001, U.S. Environmental Protection Agency, Washington, D.C., February 2006. 

Guidance on Choosing a Sampling Design for Environmental Data Collection for Use in 

Developing a Quality Assurance Project Plan, EPA/240/R-02/005, U.S. Environmental 

Protection Agency, Washington D.C., December 2002. 

Hazardous Waste Management System: Petroleum Refining Process Wastes; Identification of 

Characteristically Hazardous Self-Heating Solids; Land Disposal Restrictions: Treatment 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX G: References G-2

Standards for Spent Hydrorefining Catalyst (K172) Hazardous Waste. Federal Register 

68:202 (20 October 2003) p. 59935.

Hazardous Waste Management System; Testing and Monitoring Activities. Federal Register 

55:27 (8 February 1990) pps. 4443-4444. See Discussion on Representative Sample 

Definition. 

Hazardous Waste Treatment, Storage, and Disposal Facilities and Hazardous Waste 

Generators; Organic Air Emission Standards for Tanks, Surface Impoundments, and 

Containers. Federal Register 59:233 (6 December 1994) p. 62916. See Examples of 

Acceptable Knowledge. 

Hot Spots: Incremental Sampling Methodology (ISM) FAQs, Interstate Technology & 

Regulatory Council (ITRC), 2014.

Identification and Listing of Hazardous Waste (40 CFR 261.31 and 261.32), Background 

Document, U.S. Environmental Protection Agency, Washington, D.C., 1980. 

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

Environmental Protection Agency, September 2005. 

Joint NRC/EPA Guidance on Testing Requirements for Mixed Radioactive and Hazardous 

Waste. Federal Register 62:224 (20 November 1997) pps. 62079-62082. See Discussion on 

Mixed Radioactive and Hazardous Waste Testing and Use of Waste Knowledge for 

Hazardous Waste Determinations. 

Land Disposal Restriction (LDR) Requirements Memorandum from Barnes Johnson, Director, 

Office of Resource Conservation and Recovery, U.S. Environmental Protection Agency (RCRA

Online No. 14843), dated April 11, 2014.

Land Disposal Restrictions for Newly Identified and Listed Hazardous Wastes and Hazardous 

Soil. Federal Register 58:176 (14 September 1993) pps. 48111-48112. See Discussion on 

Demonstrating Acceptable Knowledge. 

Land Disposal Restrictions for Second Third Scheduled Wastes. Federal Register 54:120 (23 

June 1989). pps. 26605-26606. See Discussion on Treatment Standards Based on Single 

Facility Data and Grab Samples Versus Composite Samples.

Land Disposal Restrictions for Third Third Scheduled Wastes. Federal Register 55:106 (1 

June 1990). p. 22539. See Discussion on Treatment Standards Based on Single Facility Data, 

Grab Samples Versus Composite Samples, and Waste Analysis Plans.

Land Disposal Restrictions Phase II--Universal Treatment Standards, and Treatment 

Standards for Organic Toxicity Characteristic Wastes and Newly Listed Wastes. Federal 

Register 59:180 (19 September 1994) pps. 48003-48004. See Discussion on LDR Lab Packs

under Phase II Rule.
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX G: References G-3

Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment Standards for Metal 

Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill 

Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood 

Preserving Wastewaters. Federal Register 63:100 (26 May 1998) p. 28561. See Discussion 

on Treatment Standards for Hazardous Wastes Containing Metals: Measuring Compliance 

by Grab or Composite Sampling.

Land Disposal Restrictions Phase IV: Second Supplemental Proposal on Treatment Standards 

for Metal Wastes and Mineral Processing Wastes, Mineral Processing and Bevill Exclusion 

Issues, and the Use of Hazardous Waste as Fill. Federal Register 62:91 (12 May 1997) p. 

26047. See Discussion on Demonstrating Compliance by Grab or Composite Sampling.

Land Disposal Restrictions Phase IV: Treatment Standards for Wood Preserving Wastes, 

Treatment Standards for Metal Wastes, Zinc Micronutrient Fertilizers, Carbamate Treatment 

Standards, and K088 Treatment Standards. Federal Register 64:90 (11 May 1999) pps. 

25411-25412. See Discussion on Treatment Residuals, New Point of Generation, and UHCs.

Management of Remediation Waste under RCRA, 530-F-98-026, U.S. Environmental 

Protection Agency, Washington, D.C., 1998.

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

Washington, D.C. 

National Emission Standards for Hazardous Air Pollutants: Final Standards for Hazardous Air 

Pollutants for Hazardous Waste Combustors (Phase I Final Replacement Standards and Phase 

II). Federal Register 70:196 (12 October 2005) pps. 59433-59434. 

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, U.S. 

Department of Health and Human Services, October 1985. 

Permit Applicants’ Guidance Manual for the General Facility Standards of 40 CFR Part 264, 

SW-968, U.S. Environmental Protection Agency, Washington, D.C., 1983. 

Permit Applicants’ Guidance Manual for Hazardous Waste Land Treatment, Storage, and 

Disposal Facilities, EPA 530 SW-84-004, U.S. Environmental Protection Agency, 

Washington, D.C., 1984. 

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

Washington, D.C., 2011.

RCRA Waste Management: Planning, Implementation, and Assessment of Sampling Activities, 

Manual 42, American Society of Testing and Materials, 2000. 

RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation and Assessment, 

EPA 530-D-02-002, U.S. Environmental Protection Agency, Washington, D.C., August 2002. 
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes

APPENDIX G: References G-4

Revision of Wastewater Treatment Exemptions for Hazardous Waste Mixtures (‘‘Headworks 

Exemptions’’). Federal Register 70:191 (4 October 2005) pps. 57769-57771. See Discussion 

on Headworks Exemptions.

Standard Methods for the Examination of Water and Wastewater, 22nd Edition, American 

Public Health Association (APHA), the American Water Works Association (AWWA), and 

the Water Environment Federation (WEF), S82210, 2012. 

Superfund Program Representative Sampling Guidance, Volume 4: Waste, EPA 540-R-95-141, 

U.S. Environmental Protection Agency, Washington, D.C., 1995. 

Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, Third Edition, 

Through Final Update IVB, U.S. Environmental Protection Agency, Washington, D.C., 2008. 

Waste Analysis Guidance for Facilities that Burn Hazardous Wastes, Draft, EPA 530-R-94-

019, U.S. Environmental Protection Agency, 1994.