Model WAP - Impoundment: Page 2 of 16

2. Identification of Impounded Sludge

Table 1 lists the pertinent characteristics of the sludge to be impounded
onsite. The data in Table 1 are based on three sets of samples collected and
analyzed over the past year. Sludge characterizations were performed by the
analysts on our wastewater treatment plant staff and by ABC Labs. Analytical
results from ABC Labs are found in Appendix I. These data are consistent with
the background information document (BID) data published for this industrial
waste stream (F006), The quality assurance and quality control procedures
used to characterize the sludge are described in Appendix II of this waste
analysis plan.

Based on sludge analysis data collected in the past 5 years, we plan to
use the following sludge characteristics as boundary conditions:

. free and complexed cyanide < 100 ppm

. cadmium < 25,000 ppm

. total chromium < 67,0900 ppm

. pH 5.5 to ll

. total organic carbon <0.5%
(Supporting sludge data are available upon request.) Setting these boundary
conditions helps alert us if a disturbance in the waste generating process
and, in turn, waste characteristic changes have occurred. Meeting these

conditions will help maintain the integrity of the surface impoundment
structure.


Model WAP - Incineration: Page 18 of 20

Collector YW. Mune Sample No. f- 2-FT- /

Place of Collection Viatesd Litiok= teceisting farvas charge takes)

Log (ET) Dont.
late Sampled Cseyesact AI, 1922? Time Sampled 9:00 g,m.

Field Information dongs pppeasid aa fleaeriteid sci ited.

Miny wurtath ps).

Figure I-1. Sample container label.

Source: “Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


TABLE 4-3, (continued)

- Reanalysis procedures for a . Weather constraints
waste shipment when test
results are inconsistent with

characterization data

. Storage instruction

. Sample life
notifying generator of in-
consistency Diagrams of sampling points
Detection limits of analytical
method

agreement to reject or
reanalyze waste shipment
(document )

method if more than one method is
available

analysis of an unused
original sample's replicate
or a new sample

|
|
| Rationale for selecting a test
|
|
|
notifying generator or waste|
acceptance or rejection |
|
- Rejection procedures for an
unacceptable waste

|
- Agreements with generator if a|
waste is unacceptable |

|

- Temporary storage plans before

unacceptable waste is shipped
offsite for other management

III. WASTE SAMPLING, ANALYSIS, AND
QA/QC PROCEDURES

Comments on sampling

- Protective gear required

+ Sample container

lthis information is not required by 40 CFR 264.13; however, it may contribute
to a more complete and useful waste analysis plan.

2Used primarily by offsite hazardous waste management facilities.

23


Model WAP - Landfill: Page 9 of 21

. a manifest document number;

. the generator's name, address, and EPA identification number;

. each transporter's name and EPA identification number;

. the destination of the waste shipment, i.e., hazardous waste
management facility, address, and EPA identification number;

. an alternative hazardous waste management facility, address, and
EPA identification number;

. a Department of Transportation shipping name and number;

. the quantity/volume of waste in the shipment;

. the number and type of containers in the shipment (if applicable);
an

. a signed, dated certification of the shipment's content.

We then visually inspect the shipment, noting --

. if the number and type of containers match the manifest;

. if the shipment labels/placards match the manifest;

. if the waste's appearance matches any previously noted
descriptions;

. any irregularities with the shipment, e.g., leaks;

. if any restricted wastes are visibly present; and

. if each container is 90 percent full.

If any complications arise as a result of this inspection, we contact the
generator to resolve the problem.

We gample and analyze each waste shipment (excluding off-spec commercial
products*) that passes our initial inspection. The sampling procedures for
each shipment depend on its means of containment, e.g., drums, when it arrives
at our facility. Our analysis of waste shipments does not always include

We do not sample and analyze off-spec products as part of our screening
procedures. The wastes are only off-spec and have never been contaminated by
generator use. We rely on visual examination of off-spec products to identify
them.


Model WAP - Landfill: Page 4 of 21

5.

6.

7.

Date
Generator

a. Name

b. Address
c. EPA ID Number

Waste Identification

a. Facility Waste Number Sample Number
b. RCRA Waste Number

c. DOT Waste Number

d. Name of Waste

e. General Description of Waste Generation Process

Sampling
a. Date Sampled b. Sampling Method

c. Name and Affiliation of Sampler

d. Was sample taken during normal process operation? Yes No

Physical State at 21° C (70° F) Solid Sludge Liquid

Water Content (percent) Test Method

Corrosive Yes No pH (regardless of corrosivity)

Ignitable Yes No Flash Point °C °F

Test Method

Figure 1. Waste characterization form,


This report has been reviewed by the Offfice of Solid Waste,
U.S. Environmental Protection Agency, and approved for publication.

Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.


TABLE 2.

WASTE ANALYSIS INFORMATION

Stream!

Parameters2

Analytical Methods3

Rationale for Parameters

All

All

All

Al

AY

All

Al

Streams

Streams

Streams

Streams

Streams

Streams

streams

*Specific gravity

Viscosity

*Water content

Total organic carbon
*

Heat of combustion

Ash content

Corrosivity

ASTM D891, Method C
(Specific Gravity
Balance)

ASTM 02170 (Kinematic
Viscometer)

ASTM 095 (Distillation)

APHA 505 (Combustion-
Infrared - Detection
Limit = 1 mg/L)

ASTM D240 (Bomb Calor-
imeter)(or 2015 (Adia-
batic Calorimeter) )

APHA 209E (Total Volatile
and Fixed Residue at 550°C)

SW-846, Method 1110
(Corrosivity Toward
Steel)

Waste verification.

Waste verification and assessment
of waste delivery system's
adequacy.

Assess burning efficiency and,
in turn, air requirements.

Burning efficiency. Waste
verfication.

Assess burning efficiency.

Maintain compliance with
particulate emissions standards;
evaluate slag formation, and
assess if system's ash handling
capacity is sufficient.

Identification of corrosives for
safe handling.

TUOLPeABULOUT - d¥M L2POW

02 40 pT abed


Model WAP - Impoundment: Page 11 of 16

APPENDIX I
ABC LABORATORIES
Date: July 13, 1983

Client: The Jones Company
Sample Number: 13-1
Collected: July 12, 1983
Received: July 14, 1983

Process Area Test
Stream Parameter Results Methods!
Electroplating Total 57,500 ppm 3050/7190
Wastewater chromium

Treatment

Plant Sludge
Cadmium 18,200 ppm 3050/7130

ln test Methods for Evaluating Solid Waste," SW-846, July 1982.
(Atomic Absorption Methods)

Signature of Certification:

I. Johnson, Office Branch Manager


Model WAP - Landfill: Page 7 of 21
4. Waste Parameters to be Monitored

The wastes managed at the facility must have characteristics that fall
within the chemical or physical retention capabilities of the landfill, i.e.,
those characteristics to be specified in the RCRA permit. To select our
analytical parameters, we 1) reviewed existing information on the waste
properties including the EPA background information document (BID‘s) on each
waste (including a search for ignitability, reactivity, and incompatibility),
2) noted what properties best indicate any change in a waste, and 3) compared
this information to our landfill facility's design criteria.

Except for the off-spec lead acetate, waste streams are tested for a
variety of parameters depending on their potential effects on the landfill and
basis for hazard designation. These include free liquids, pH, cyanide,
sulfide, oxidizing agents, reactivity, radioactivity, PCBs, and flash point,
which are measured to detect restricted wastes. Analysis for water content,
EP toxic metals, phenol, PAH, and a GC/MS scan for volatile and semivolatile
organic constituents are conducted to verify waste characteristics and
identify any potential liner-damaging organics that are present.

We decided how often to recharacterize the waste with these tests by
considering --

. the potential for restricted wastes being combined in a shipment,

. the landfill's limitations,

. the variability of a waste's composition from one shipment to
another,

. the likelihood of a waste undergoing changes that adversely affect

its manageability, and

. the prior history of the waste generator performance and
reliability.

Section 5, “Waste Sampling and Analysis," contains a description of
these analysis procedures and identifies the frequencies of waste
recharacterization for each stream.

We screen all incoming shipments to assure that the wastes we receive
meet the permitted boundary conditions. The procedures followed during a
shipment screening are presented in Figure 2.

We check each waste shipment manifest for completeness and correctness,
looking for the following information on each manifest:


Model WAP - Waste Pile: Page 6 of 15

The hazardous constituents, chromium and lead, are consistently present
in the filter cake; only their concentration, the volume of water, and perhaps
the pH may vary. The offsite hazardous waste management facility that accepts
the waste pile material also analyzes it for their own purposes. For these
reasons and the low probability that unscheduled wastes will be inadvertently
mixed with the filter cake, we have decided to perform routine
recharacterization annually. If there is any indication that an unusual
quantity of leachate is heing generated hy the filter cake in the waste pile,
an unscheduled sample will be taken and analyzed.

When the waste piles are emptied for offsite management, their bases are
not decontaminated because they will be covered again with the same type of
filter cake; therefore, no incompatihilities would exist. The transport
vehicles are decontaminated by their owners before receiving the filter cake,
and they are constructed of materials compatible with the sludge.

The filter cake from wastewater treatment is the only waste stored in the
piles. However, if we ever suspect or are notified by one of our process area
personnel that the pigment producing process or wastewater treatment process
or their means of operation have changed, measures will he taken to determine
if the filter cake has changed in character. We will obtain as much
information about the change as our personnel can provide and take an
unscheduled sample of the filter cake from the wastewater treatment plant.

The sample will be split and one portion will be forwarded immediately to XYZ
Labs, Inc. for analyses for chromium, lead, trichloroethylene, and ethyl
benzene, and we will inform them of any suspected property changes in the
sample. We will request results of the analyses within 72 hours, Should
their analyses indicate a significant change in lead or chromium concentration
or the presence of trichloroethylene or ethyl benzene, every effort will be
made to characterize the waste so that we can 1) inform our offsite contractor
of the change, 2) take measures to protect the waste pile liner, and 3) be
prepared should a spill occur onsite.

Qur personnel will analyze the unscheduled sample for pH and percent
water. If the filter cake contains greater than 70 percent water, it will be
returned to the plant for additional vacuum filtration. If the pH is outside
the boundary conditions (i.e., pH 9.2 to 11.5), an additional characterization
will be required to determine if waste components are present that could
influence waste pile performance. Any analyses for nonroutine parameters that
are required will he performed either in-house or by XYZ Labs.

The offsite hazardous waste management facility contractor who normally
receives the waste pile material will be notified of any change in filter cake
characteristics so that it can be determined if the waste is still acceptable
at the facility. If it is not acceptable, The Color Company will make every
effort to find another hazardous waste management facility to receive the
filter cake. In the interim, the filter cake will remain stored onsite ina
tanker truck.


Waste Sampling, Analysis, and Quality Assurance/Quality Control Procedures

This section of the plan includes--

. waste sampling procedures,

. waste analysis methods, and

. their related quality assurance/quality control procedures.

Appendix I of 40 CFR Part 261, Representative Sampling Methods, describes
standard sampling methods developed by the American Society for Testing and
Materials (ASTM) and others that can be used when sampling hazardous waste.
Discussions on representative sampling and descriptions of sampling devices
are also available in the EPA document “Test Methods for Evaluating Solid
Waste" (SW-846). Appendix C of this manual addresses random sampling and
demonstrates how to use a random numbers table for waste sampling. Appendix D
contains the ASTM method for estimating the number of containers to sample.
The permit applicant should contact the application reviewer if he or she is
uncertain about how to estimate the number of samples to take. If wastes
cannot be sampled by the standardized methods and approved devices, the
applicant must develop a suitable sampling method and include a detailed
description and rationale for the method in the waste analysis plan.

Test methods for selected waste characterization parameters have been
standardized by EPA. These EPA-approved methods are described in detail in
EPA's “Test Methods for Evaluating Solid Waste" (SW-846). This document is a
compilation of analytical methods that have been approved by EPA for use in
the RCRA program. SW-846 methods for determining various parameters are
accepted by EPA without further justification by the generator or facility
owner/operator.

EPA continually updates SW-846 to provide additional or improved test
methods. Sometimes, however, it may be appropriate to employ a special test
method that has not been approved by EPA. If such a method is proposed for a
particular analysis, approval must be received from EPA prior to its inclusion
in the waste analysis plans.

40 CFR Part 261, Appendix III, Chemical Analysis Test Methods, is another
useful source of methods. This appendix lists analytical procedures for
determining if a waste contains a specific toxic element or compound. It
contains three tables of information on analyzing for toxic waste
constituents - Tables 1 and 2 list analytical methods for specific organic and
inorganic constituents, respectively, and Table 3 lists ways to prepare
samples and introduce them into a system for analysis.

40 CFR 270.30, "Conditions applicable to all permits," addresses quality
assurance in paragraph (e), “Proper operation and maintenance." It states--

13


TABLE 1. WASTE CHARACTERISTICS!
Chemical
Basis for Physical Composition
Stream Hazard Listing Properties (or % by volume)

1. Segregated Cadmium Cadmium, Specific pH: 7.0 to 9.5
Wastewater Treat- Hexavalent Chromium, gravity:4 Complexed cyanide:
ment Sludge (RCRA and Complexed negligible
No.2 F006) Cyanide Cadmium: 17,000 to 22,000 ppm

(Toxic [T]) Total Chromium: 50,000 to
62,000 ppm

2. Pigment Filter K002- Hexavalent Chromium and Lead (T) Specific pH: 9.0 to 12.0

Cake (RCRA Nos.3) KOO3- Hexavalent Chromium and Lead (T) gravity:4 Total Chromium: 50 to 100 ppm
K004- Hexavalent Chromium (T) lead: 20 to 70 ppm
KOO5- Hexavalent Chromium and Lead (T)

3. Emission Control Hexavalent Chromium, Specific pH:4 :

Dust/Sludge from Cadmium, and Lead (T) gravity: Cadmium: 300 to 520 ppm
Secondary Lead Lead: 45,000 to 60,000 ppm
Smelting (RCRA No.3 Total Chromium: 25 to 40 ppm
K069)

4, Emission Control Hexavalent Chromium, Specific pH:4
Dust/Sludge from Cadmium, and Lead (T) gravity :4 Cadmium: 600 to 700 ppm
the Primary Lead: 1,250 to 1,400 ppm
Production of Steel Total Chromium: 10,300 to
in Electric Furnaces 17,600
(RCRA No.3 K061)

5. Cumene Distilla- Phenol and Tars (polycyclic Flash Points: Phenol: 0.7 to 1.5% by weight
tation Bottom Tars aromatic hydrocarbons [PAH]) (T) 90 to 100° c PAH: 0.8 to 1.7% by weight
(RCRA No.3 K022) Specific

gravity:4

process code for all streams is T01, chemical treatment.

Refer to 40 CFR 261.31.
3Refer to 40 CFR 261.32.
Author's note:

Insufficient information available for these specific wastes for this model.1

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Model WAP - Chemical Treatment: Page 9 of 20

When a waste shipment arrives at our facility, we check its manifest for
completeness and correctness. At a minimum, we will look for the following
information on each manifest:

. a manifest document number;

. the generator's name, address, and EPA identification number;

. each transporter's name and EPA identification number;

. the destination of the waste shipment, i.e., hazardous waste
management facility, address, and EPA identification number;

. an alternative hazardous waste management facility, address, and
EPA identification number;

. a Department of Transportation shipping name and number;

. the quantity or volume of waste in the shipment;

. the number and type of containers in the shipment (if applicable);
an

. a signed, dated certification of the shipment's content.

We will then visually inspect the shipment, noting --

. if the number and type of containers match the manifest;

. if the shipment labels/placards match the manifest;

. the presence of free liquids and the consistency with the manifest;
. any irregularities with the shipment, e.g., leaks;

. if any restricted wastes are visibly present; and

. if the waste appearance matches any previously noted description.

Each waste shipment that passes initial inspection will be sampled and
analyzed. We sample all waste shipments as described in Section 5, "Waste
Sampling and Analysis," but the analysis of waste shipments does not always
include measuring all the parameters used in our initial waste
characterization. Rather, we select a subset of these to measure known as
“key parameters," so we can 1) obtain the best indication of waste
treatability within given time and labor constraints, and 2) identify any
ignitable, reactive, or incompatible wastes that may be present. The key
parameters are selected based on --

. the need to identify any restricted wastes,


Model WAP - Waste Pile: Page 1 of 15

MODEL WASTE ANALYSIS PLAN
WASTE PILE

1. Facility Description

The Color Company manufactures four inorganic chrome pigments: chrome
yellow and orange, molybdate orange, and zinc yellow. These pigments are
produced in simultaneous processes, and the resulting wastewaters are routed
to the company's treatment plant. The sludge from the treatment plant
contains hexavalent chromium and lead that cause it to be classified as a RCRA
hazardous waste.

A vacuum filtration unit removes approximately 30 percent of the water
from the sludge. The filter cake from this device is stored onsite in two
sheltered waste piles that are filled sequentially. The filter cake dries for
several months in the piles until enough is accumulated for transportation to
an offsite hazardous waste management facility to he economical.

The waste piles are constructed with leachate collection systems and
polyvinyl chloride (PVC) membrane liners. They were designed specifically to
hold the wet filter cake produced by vacuum filtration of the wastewater
treatment pigment sludges. All materials of construction were selected in
keeping with their compatibility with the filter cake. Another chapter of
this Part B application provides a detailed description of the waste pile
design.

The Color Company is requesting a RCRA permit to store the pigment filter
sludge cake in the waste piles. The waste piles would be permitted to hold
only the filter cake.


Model WAP - Container: Page 2 of 15
2. Identification of the Spent Solvent

Table 1 lists the characteristics of each hazardous waste stream
generated onsite that we consider pertinent to the proper operation of the
storage facility. The three waste streams we manage range in composition from
80 to 95 percent trichloroethylene by volume, with the remainder being oi] and
grease and an immeasurable amount of dirt. The data listed reflect analysis
results from three samples taken at 4-month intervals at each generation
process area. The waste characterization was performed by an offsite
commercial laboratory, Smith Labs. The Lab's analytical results are found in
Appendix I. Quality assurance and quality control programs associated with
this lab are described in Appendix II.

The following boundary conditions have been established for the spent
solvent characteristics:

. + 15 percent of the specific gravities listed in Table 1, and
. flash point less than 60° C,

Not meeting these conditions will alert us that the waste is not typical and
may require special handling or analysis before shipment offsite. Any wastes
that exceed the boundary conditions will he handled according to the
procedures described in Section 4, "Parameters to be Monitored." Our
experience with this waste has led us to establish these conditions, and we do
not expect the waste to vary outside these boundaries. Supporting analytical
data are available upon request.


Model WAP - Land Treatment: Page 14 of 16

APPENDIX

Quality Assurance/Quality Control Program

Program Goal

The program's goal is to collect accurate and precise waste
characteristic information so that we can assure that the wastes treated at
our faciity reflect those waste characteristics that the process is permitted
to treat. This can be accomplished by making sure that the waste maintains
the permitted characteristics of DAF float and API sludge. We generate a
great deal of data at our facility, and the success of the treatment process
is especially dependent on the quality of these analytical data. Thus, this
quality assurance/quality control program is carried out to the fullest to
assure that accurate and precise data are obtained.

Sampling Program

Two of our personnel will be trained to sample wastes as described in
this application's training program section. Their sampling skills are
observed quarterly during sampling events by our operations manager. Sampling
equipment is inspected for decontamination and operability before each
shipment is sampled, and each inspection is documented. We make note of any
problems encountered and the corrective actions taken.

All sample containers are labeled (see Figure A-1), and vital sampling
information is logged in the field before the sampler drives the samples to
the laboratory (see Figure A-2).

Analysis Program

Our lab personnel have been trained to perform the analytical procedures
discussed in Section 5 of this waste analysis plan, and their training program
is described in this Part B application. Analytical skills are checked with
the blanks or standards that are included with each analysis. Lab personnel
document receipt of each sample and assign sample identification numbers to
replicates. The quality assurance/quality control procedures for analysis
follow those outlined in each EPA-approved test method. Upon receipt of the
sample, a lab employee logs it into the daily lab record. Tests are completed
at least 24 hours before land application to identify any anomalies in time.
All test results are documented on the characterization form shown in Figure
l.

Analytical equipment is inspected and serviced semiannually in addition
to routine checks before each analysis. Leftover samples are returned to the
containment devices from which they were sampled.


Model WAP - Container: Page 9 of 15

TABLE 2, WASTE ANALYSIS PARAMETERS AND METHODS FOR STREAMS A, B,
AND C OF SPENT SOLVENT DEGREASER (TCE)?

Parameters Analytical Methods Rationale for Parameters
Specific gravity ASTM D891, Method A Identification of spent TCE
(Hydrometer )
Flash point SW-8462, Method 1010 Identification of spent TCE
(Pensky-Martens)
Halogenated volatile SW-846, Method 8010 Identification of spent TCE
organics (Gas chromatography--
measure retention time
for TCE)

Ithese wastes are recharacterized annually.
2sw-846 “Test Methods for Evaluating Solid Waste”

duly 1982.


Mode] WAP - Landfill: Page 19 of 21

Collector ox Liuadell Sample No. f-2-/
Place of Collection Druck ALL. fant, Aria

Figure A-1. Sample container label.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


Model WAP - Impoundment: Page 7 of 16

5. Waste Sampling and Analysis

Sampling

The sampling procedures were developed by first identifying the sludge
physical/chemical properties and means of containment, i.e., surface
impoundment. We selected an appropriate sampling device and sample container
after reviewing "Test Methods for Evaluating Solid Wastes" (SW-846). Since
the equipment selected is listed for material of the same physical form as the
sludge, we believe that the equipment is suitable. We reviewed the scientific
literature and our previous work history to identify any needs for special
sludge handling procedures. This helps us to be certain that our employees
are protected and our samples remain representative during storage.

It is practically impossible to sample all areas within the surface
impoundment. Since accessible areas are primarily around the periphery of the
impoundment, our samples are somewhat limited in their representativeness of
the entire impoundment.

We randomly sample impoundment areas within reach. The sample areas
selected are based on a three-dimensional grid. We divide the accessible
areas into imaginary, sequentially numbered cells based on length, width, and
depth of the sludge and then use the random numbers table to select the
numbered cells to sample [See Appendix C of this manual]. A grab sample is
taken from one randomly chosen cell at each depth level. One sample per depth
level should be sufficient since there is little likelihood of damaging levels
of cyanide being present in the sludge.

Weighted glass bottles are used for sampling sludge because 1) the bottles
help isolate samples taken at different depths (SW-846, 1.2.1.2), and 2) we
have found in previous efforts that the water content of the sludge is
sufficient for it to flow into the bottle. The samples remain stored in these
same weighted bottles until analyses are performed.

The waste characterization, recharacterizations, and any unscheduled
sampling will follow the sampling procedures described in this section.

The following information summarizes the sampling procedures described
above:


TABLE 1.

WASTE CHARACTERISTICS

Stream! s2

Basis for Hazard
Classification

Physical
State

Chemical Composition

A-2

B-1

D-1

Of f-spec lead acetate
(RCRA No. U144)3

Pigment filter gake
(RCRA No. K003)4

Pigment filter gake
(RCRA No. KO04)

Dust/sludge from
secondary lead
smelting

(RCRA No. K069)4

Bottom tars from
phenol yprodaceya”
(RCRA No. K022)

Lead acetate (Toxic)

Lead, hexavalent
chromium (Toxic)

Hexavalent chromium
(Toxic)

Hexavalent chromium,
lead, cadmium (Toxic)

Phenol, Tars
(polycyclic aromatic
hydrocarbons [PAH})

Solid, single layer
Density = 3.25 g/ml

Sludge, single layer

Sludge, single layer

Sludge, single layer

Tarry solid, single
layer

Lead acetate:
by weight

up to 95%

Lead: 50 to 200 ppm

Total chromium: 20 to 80 ppm
Water: 40 to 70% by weight
pH: 8.5 to 11.0

Total chromium: 50 to
100 ppm
Water: 50 to 70% by weight

pH: 9,5 to 11.0

Cadmium: 200 to 300 ppm
Lead: 35,000 to 50,000 ppm
pH: 5.0 to 7.0

Water: 30% by weight

Total chromium: 10 to 30 ppm

Phenol: 0.7 to 1.5% by
weight
PAH: 0.8 to 1.7% by weight

Flash point: 90 to 100 %
Water: 0.5 to 2.0% by
weight

\stream numbers indicate generator (A, B, C, and D) as well as separate streams from each
waste generator.
“Process code for aii streams is 080, Landfill.

LLEsPURT - dY¥M LePOW

T2 #0 € abeq


Model WAP - Container: Page 5 of 15
4, Parameters to be Monitored

The spent trichloroethylene must be capable of safe storage in 55-gallon
drums for up to 6 months. We believe that the spent solvent degreaser we
generate meets this criterion because 1) the storage drums were selected for
their chemical compatibility to the waste and 2) our parts cleaning process is
routine and produces wastes of relatively consistent composition.

We have reviewed existing information on the waste properties (including
a search for ignitability/reactivity), noted what properties best indicate any
change in a waste, and compared this information to our storage facility's
design criteria. Since the only facility limitations are waste storage and
spill containment capacity, the waste analysis parameters to be measured were
selected to verify the nature of the waste.

Review of our operating records indicates that the characteristics of the
spent solvent probably will change only in the proportion of oi] and grease
dissolved in the solvent. Only one hazardous (toxic) constituent,
trichloroethylene, is generated onsite; therefore, it has been selected as a
Parameter to be determined. Specific gravity was selected as a parameter to
provide an indication of the spent solvent's variation in contaminants.

Since no other hazardous wastes are stored onsite, no potential exists
for hazardous waste incompatibilities. The drums are purchased new and
uncontaminated; therefore, no potentially incompatible wastes have been held
in these drums before the spent solvent is placed in them. When the filled
drums are shipped offsite, they are not returned to us for reuse; however, we
are credited by the reclaimer for empty drums.

We decided how often we felt it necessary to characterize the spent
solvent with these tests by considering --

. the potential for other materials onsite being mistakenly
Placed in these drums,

. the variability of the spent solvent composition, and

. the likelihood of the spent solvent undergoing changes that alter
its permitted characteristics.

Our trichloroethylene wastes seldom change since 1) only one type of
hazardous waste is generated onsite, and 2) the generating process is routine.
Therefore, we believe that annual characterization is sufficient to maintain
our file of chemical information should a waste spill occur onsite. The
characterization will be performed by Smith Labs. The offsite solvent
reclamation facility that receives our waste takes samples and analyzes them
for its own needs.


Model WAP - Impoundment: Page 10 of 16

APPENDIX I
ABC LABORATORIES
Date: May 10, 1983

Client: The Jones Company
Sample Number: 3-1
Collected: May 9, 1983
Received: May 10, 1983

Process Area Test
Stream Parameter Results Methods!
Electroplating Total 62,000 ppm 3050/7190
Wastewater chromium

Treatment

Plant Sludge
Cadmium 22,000 ppm 3050/7130

l'Test Methods for Evaluating Solid Waste," SW-846, July 1982.
(Atomic Absorption Methods)

Signature of Certification: ub Dobra

I. Johnson, Office Branch Manager


Model WAP - Land Treatment: Page 15 of 16

Collector z£ Catia) Sample No. A-2
Place of Collection DAE Siont Sank)

Date Sampled Aucyussde ‘3 19 83 Time Sampled /9-00 g ‘m-

Feld Information float Oamysts in) unr) than nirmat
t Z btm pling :
T / a

Figure A-1. Sample container label.

Source: "Test Methods for Evaluating Solid Waste” SW-846, July, 1982.


APPENDIX B
REFERENCES

1. Identification and Listing of Hazardous Waste Under RCRA, Subtitle C,
Section 3001. Listing of Hazardous Waste (40 CFR 261.31 and 261.32). NTIS
PB81-190035, U.S. Environmental Protection Agency, Washington, D.C. 1980. 853

pp.

2. Test Methods for Evaluating Solid Waste. Physical/Chemical Methods.
SW-846, 2nd Edition, U.S. Environmental Protection Agency, Washington, D.C.
1982.

3. Standard Methods for the Examination of Water and Wastewater, 15th
edition. American Public Health Association, Washington, D.C. 1980.

4. A Method for Determining the Compatibility of Hazardous Wastes,
EPA~600/2-80-076, U.S. Environmental Protection Agency, Cincinnati, Ohio,
1980. 149 pp. Available from Superintendent of Documents, U.S. Government
Printing Office, Washington, D.C.

5. Toxic and Hazardous Industrial Chemicals Safety Manual for Handling and
Disposal with Toxicity and Hazard Data. The International Technical
Information Institute, Tokyo, Japan, 1976. 591 pp.

6. Hazardous Waste Land Treatment. SW-874, U.S. Environmental Protection
Agency, Washington, D.C. 1983. 671 pp.

7. EPA Memorandum. “Guidance on Petroleum Refinery Waste Analyses for Land
Treatment Permit Application." April 3, 1984.

8. Permit Applicants' Guidance Manual for Hazardous Waste Land Treatment,
Storage, and Disposal Facilities. SW-84-004, U.S. Environmental Protection
Agency, Washington, D.C. 1983. Available from Superintendent of
Documents, U.S. Government Printing Office, Washington, D.C.

9. Guidance Manual for Hazardous Waste Incinerator Permits. SW-966, U.S.
Environmental Protection Agency, Washington, D.C. 1983. Available from
Superintendent of Documents, U.S. Government Printing Office, Washington, D.C.

10. Design and Development of a Hazardous Waste Reactivity Testing Protocol.
EPA-600/52-84-057, U.S. Environmental Protection Agency, Municipal
Environmental Research Laboratory, Cincinati, Ohio. Available from the
National Technical Information Service (NTIS No. PB84-158807).


Model WAP - Chemical Treatment: Page 1 of 20

MODEL WASTE ANALYSIS PLAN
CHEMICAL TREATMENT

1. Facility Description

The Chemical Treatment Company is requesting a RCRA permit to operate a
commercial treatment facility that chemically stabilizes hazardous wastes
received from offsite generators, This permit would allow us to treat
hazardous wastes consisting of solid organics, oxidizers, and metals, We
specifically plan to treat--

. segregated cadmium wastewater treatment sludge,

. pigment wastewater treatment sludge,

. emission control dust/sludge from secondary lead smelting,

. emission control dust/sludge from the primary production of steel

in electric furnaces, and
. cumene distillation bottom tars.

All of the wastes we treat must have the characteristics of one of these
wastes.

The treatment process entails chemically fixing the wastes in cement.
This will produce a stable, solidified waste that is sent offsite for
disposal. The process is designed specfically to treat solid organics,
oxidizers, and metal-based wastes safely and effectively. Another portion of
this Part B application contains a detailed description of our facility's
design and the results of the trial treatment test.

la facility such as this may have onsite hazardous waste storage, This model
will not address storage since it is addressed in another model. A real waste
analysis plan would be required to describe the facility's storage practices.


Model WAP - Container: Page 15 of 15

Collector 4 . Goohmacn. Date Sampled _/| f l@ | 23 Time F:0b,mhours
Affiliation of Sampler epi a - henapt Lost Lig Le

Address *h : 7~ =

number stree city state Zip
Telephone (cco) 5§5 -(ala Company Contact mM. Lo waar)
LABORATORY
SAMPLE COLLECTOR'S TYPE OF
NUMBER SAMPLE NO. SAMPLE! FIELD INFORMATION

Aem I2-| higuic Prarttsd ntow Aiea) B- |.

spec{a1 Hendling and/or Storage wie pedis cult glee, ata

Ss

PART II: LABORATORY SECTION2

Received by . Title ) Date /
4 dete) —_ Pak gts B Lk ups fa
Analysis Required Ame ga “Aanaliyaie eg uitacts “

lindicate whether sample is soil, sludge, etc.
Use back of page for additional information relative to sample location.

Figure II-2. Sampling analysis request.

Source: "Test Methods for Evaluating Solid Waste" SW-846. July 1982,


Model WAP - Waste Pile: Page 13 of 15

Collector Q. Harn Sample No.  [-]
Place of Collection WasTtiurrTin J rtatmank Plant - Vict /

aliens Apwas (Lempura nd

BAAN MAA A A A 4 a 4 d
Date Sampled (GAiphed 6. /927 Time Sampled _/: 3% p.m.
7

Figure II-1. Sample container label.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


How will incoming shipments be
screened to ensure that they are as
manifested and are ones that we have
agreed to accept?

Water content

Ash content

Reactivity

Ignitability (flash point)

Corrosivity

Acidity or alkalinity

EP metals concentrations

Major inorganic constituents

Total organic carbon

Major organic constituents
and their heats of combustion

PCB

Dioxin

Instability properties

If any of the properties fall
outside of the acceptable
characteristics described under
“Wastes To Be Managed,"
the waste would be refused.

For those wastes provisionally
accepted, the client would be
required to submit and certify a
representative sample of the
waste(s). This sample will be
analyzed by XYZ Laboratory to
confirm the data submitted by the
client.

If the properties are within our
specifications, the waste would be
deemed acceptable for treatment.

[Applicant should indicate frequency
of recharacterizing generator's
wastes. ]

A series of fingerprint properties
characteristic of each waste would
be selected, and used to screen
each incoming shipment before the
waste is accepted at the facility.

If the fingerprint analysis finds an
unacceptable discrepancy, the waste
will be analyzed further and either
returned to the client or sent to a
facility permitted to accept such
wastes,


TABLES

Number Page
4-1 Waste Analysis Plan Checklist - General Information. .... 16
4-2 Waste Analysis Plan Checklist - Specific Hazardous

Waste Management Process 2.6 ee eee ee eee eee ee 19

4-3 Optional Items to Consider When Preparing a Waste
Analysis Plan. 2. eee ee wee eee eee eee wee we 22

ii


Model WAP - Landfill: Page 5 of 21

8. Reactive Yes No Test Method

Description of Results
9. EP Toxic Metals Yes No

Contaminant Concentration Method of Analysis
10. Other Restricted Wastes Test Methods

Free Liquids Yes No

Gaseous Wastes Yes No

Oxidizers Yes No

Cyanides Yes No

Sulfides Yes No

Radioactives Yes No

Polychlorinated

biphenyls Yes No

ll. Organic Components (Indicate percent by weight or mg/L including phenol

and polycyclic aromatic hydrobarbons (PAH) for organic waste streams

Test Methods

I certify the accuracy of these data and the representativeness of the

waste sample.

Signature and Title

Date

Figure 1.

Waste characterization form (continued).


Model WAP - Container: Page 12 of 15

SMITH LABORATORIES
Date: September 19, 1983

Sample Number: Drums 05-1 Client: Aircraft Parts Mfg. Co.
14-1 Address
25-1

Collected: January 18, 1983
Received: January 18, 1983

Sample Process

Orum Area

Number Stream Parameter Results Test Method

05-1 A Specific 1.45 asTut
gravity
Flash point 74,2° C 10102
%Trichloroethylene 87% 30102
(by volume)

14-1 B Specific 1.40 astul
gravity
Flash point 80.0° C 10102
“Trichloroethylene 86% 80102
(by volume)

25-1 c Specific 1.42 astml
gravity
Flash point 78,4° C 10102
4Trichloroethylene 89% 80102

(by volume)

1 ASTM American Society for Testing and Materials
2 “Test Methods for Evaluating Solid Waste" SW-846 July 1982,

Signature of Certification:
ly mith, President


TABLE 3.

(continued)

Stream

Parameter

Test Method

Detection
Limit
(ug/L)

Rationale for
Parameter Selection

A-2, B-1, C-1, D-1
L-1

A-2, Bel, C-1, D-1

A-2, B-1, C-1

EP toxic metals
Arsenic

Barium

Cadmium

Total Chromium
Lead

Mercury
Selenium

Silver

*Oxidizing agents

*cyanide

SW-846, Methods 3050/
7060 (AA, Furnace)
SW-846, Methods 3050/
7081 (AA, Furnace)
SW-846, Methods 3050/
7131 (AA, Furnace)
SW-846, Methods 3050/
7191 (AA, Furnace)
SW-846, Methods 3050/
7421 (AA, Furnace)
SW-846, Method

7471 (AA, Furnace)
SH-846, Methods 3050/
7740 (AA, Furnace)
SW-846, Methods 3050/
7761 (AA, Furnace)

Iodide, Starch Paper
Test6

SW-846, Method 9010
(Titration)

0.2

0.2

Waste verification.

Identify restricted
oxidizing wastes.

Identify restricted
cyanide wastes in
aqueous-based media.

LLE3PURT - d¥M LePOW

T2 40 91 abed


Model WAP - Impoundment: Page 16 of 16

Analysis Program

Our sampling personnel are also trained as analysts. Their training
program is described later in this application. The analysts are monitored by
the environmental manager during sludge analysis. The test for measuring
cyanide follows quality assurance/quality control procedures outlined in the
SW-846 method description. The analytical data we generate are documented and
kept on file in our environmental manager's office. The lab equipment used is
inspected and serviced semiannually and as needed on a nonroutine basis. Any
leftover sample from our analysis is returned to the surface impoundment.

All atomic absorption analysis procedures that our company requires have
been specified in our contract with ABC Labs. ABC is a commercial laboratory
with trained analysts who are retrained annually. They maintain a rigorous
quality assurance/quality control program that is available for review by EPA
upon request. All of their hazardous waste analyses are conducted for The
Jones Company within 72 hours and comply with SW-846 quality assurance/quality
control procedures for specific test methods. Analytical data are documented
and returned to us for evaluation by our environmental manager and then filed.


TABLE 3.

WASTE ANALYSIS PARAMETERS AND METHODS

Detection Limit

Stream Parameters Analytical Methods! (mg/L) Rationale for Parameters
1. Moist filter cake Total AA Methods 3050/7190 0.05 Verification of waste.
from wastewater chromium (SW-846)
treatment plant
Lead AA Methods 3050/7420 0.1 Verification of waste.
(SW-846)
Moisture ASTM D095 - Distillation, - No more than 70% water
or 01796 - Centrifuge allowed in waste.
pH pH Meter Method 9040 - Identification of
(SW-846) corrosion threats.
Trichloroethylene GC Method 8010 1.2 X 10-4 Identify the presence of
(SW-846) liner-damaging organics.
Ethyl benzene GC/MS Method 8240 7.2 X 10-3 Identify the presence of
(SH-S46 ) liner-damaging organics.
2. Waste pile Total AA Methods 3010/7190 0.05 Toxic parameter; reflects
leachate chromium (SW-846 ) presence of filter cake

constituents.

SBLLd BISeM - dyM Lepow

GT 40 6 abeq


United States Office of EPA/S308W-84-012
Environmental Protection Solid Waste October 1984
Agency

Solid Waste

SEPA Waste Analysis Plans

A Guidance Manual



TABLE 1. WASTE CHARACTERISTICS!
Basis for
— RCRA Hazard Physical Chemical
Stream? >3 Number4 Listing Properties Composition
A-1 Recovery Still FOOL Methylene Specific gravity: Methylene chloride:
Bottoms of Spent chloride 0.95 to 1.15 18 to 224 by volume
Halogenated Solvent (Toxic) Heat of combustion: Vil: 76 to 80% by volume
7.49 to 9.16 kcal/g Water: 1 to 3% by weight
(13,500 to 16,500 Btu/1b)
Ash: 5 to 7% by weight
Viscosity: 19 to 22
Centipoise
A-2 Recovery Stil] FOOL Trichloroethy] ene Specific gravity: Trichloroethylene:

Bottoms of Spent
Halogenated Solvent

(Toxic)

1,02 to 1.24

Heat of combustion:

5.99 to 7.33 kcal/g
(10,800 to 13,200 Btu/1b)
Flash point: >32° C
(pure TCE, closed cup)
Ash: 3 to 6% by weight
Viscosity: 16 to 19
Centipoise

28 to 32% by volume
Oil: 66 to 70% by volume
Water: 1 to 3% by weight

uoLzeuaULOUT - dyM Lapow

02 30 «¢ abe


Model WAP - Chemical Treatment: Page 6 of 20
3. Chemical Treatment Tolerance Limits

The treatment process is limited in that it cannot stabilize as
effectively wastes that may contain 1) soluble salts of zinc, copper, or lead;
2) sodium salts or other salts of arsenate, borate, phosphate, iodate, or
sulfide; or 3) large quantities of sulfates because these constituents retard
cement setting time.

The process requires that the influent waste or waste mixture have a pH
between 8 and 12. If necessary, additives will be blended in to achieve this

pH.

We do plan to accept wastes that may be incompatible with other wastes we
manage. Since the process cannot treat incompatible wastes together, they are
treated in separate batches and the structure is decontaminated between
batches.


Model WAP - Landfill: Page 14 of 21

Analysis

Table 3 identifies the analytical methods chosen for periodic waste
characterizations and waste shipment screening. The table also provides a
rationale for selecting each parameter and the frequency at which each stream
is recharacterized. The recharacterization frequencies selected are based on
a ranking exercise that considers the criteria discussed in Section 4. [See
Appendix — of this manual for an explanation of this ranking exercise.] The
details of the ranking exercise are not included since they take the waste
generator's history of performance into consideration. The details are
available upon request. Should recharacterization analyses prove that the
waste is not safely manageable onsite, we will reject it.

All analyses are performed in-house. QA/QC procedures for sample
analysis are discussed in the appendix.


1, Introduction to Manual... 2. ee eee eee

2. Regulatory Requirements ......40-0020e

3. Preparing a Waste Analysis Plan .......0.

4. Checklists for Writing or Reviewing Waste Analysis Plans
References «6 6 ee ee eee ee ee ee ew eee
Appendices

A. 40 CFR 264,13 General Waste Analysis ......

B. Example Waste Analysis Plans... .. 2.2. eee

Container Storage
Tank Storage
Surface Impoundment
Waste Pile

Land Treatment
Incineration
Chemical Treatment
landfit)
References

C. How to Use a Random Numbers Table for Waste Sampling. .....

D. Drummed Wastes - Estimating Sampling Size

E. A Ranking Exercise to Select Frequency of Waste

CONTENTS

Recharacterizations 2... eee eee eee ee ee ee ee

1
2
3
15
24
A- 1
B- 1
C- 1
o- 1
E- 1


Page 4 of 20

Model WAP - Incineration

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These tests are not a part of waste analysis plans. Such tests should
he addressed in other portions of Part B applications.

These models are not intended to be inflexible formats for writing vaste
analysis plans; rather, they are examples furnished to vrovide guidance to both
the permit applicant and the permit writer. The numerical values for physical
properties and chemical analyses in this Appendix have been selected
arbitrarily and do not necessarily reflect actual levels in the types of
streams deseribed. Where possible, however, the industry descriptions and
stream compositions were based on information provided in the RCRA background
information document, "Identification and Listing of Hazardous Waste" (EPA
1980), Comments regarding safety precautions for sampling were taken from
Toxic _and Hazardous Industrial Chemicals Safety Manual prepared by the
International Information Institute (Japan 1976)¢,

1y.S. Environmental Protection Agency. (Identification and Listing of
Hazardous Waste Under RCRA, Subtitle C, Section 3001: Listing of Hazardous
Waste (40 CFR 261.31 and 261.32). PB81-190035, National Technical Information
Service, Springfield, Virginia, 1981.

2The International Technical Information Institute. Toxic and Hazardous

Industrial Chemicals Safety Manual. The International Technical Information
Institute, Japan, 1976,

B-2


Model WAP - Waste Pile: Page 15 of 15

follow quality assurance/quality control procedures outlined in each
EPA-approved method. The analysts register the receipt of each sample in the
lab log before analysis begins.

The analytical data we generate are documented and kept on-file in the
environmental manager's office. The lab equipment used is inspected and
serviced semiannually and as required on a nonroutine basis. Any leftover
sample from the analysis is returned to the waste pile.

All atomic absorption analysis procedures have been specified in the
Color Company's contract with XYZ Labs. XYZ is a commercial laboratory with
trained analysts who are retrained annually. They maintain a rigorous quality
assurance/quality control program that is available for review by EPA upon
request. All of the hazardous waste analyses are performed within 72 hours of
receiving the sample. The analyses comply with SW-846 quality assurance/
quality control procedures for specific test methods. XYZ Lahs document their
analytical data and return them to us for evaluation and filing in the
environmental manager's office.


TABLE 3. (continued)

Detection Limit

Rationale for Parameters

Stream Parameters Analytical Methods!
Lead AA Methods 3010/7420
(SW-846)
pH pH Meter Method 9040
(SW-846)
Trichloroethylene GC Method 8010
(SW-846)
Ethyl benzene GC/MA Method 8240
( SW-846)

1.2 x 1074

7.2 X 10-3

Toxic parameter; reflects
presence of filter cake
constituents,

Assure effective waste-
water treatment.

Identify the presence of
liner-damaging organics.

Identify the presence of
liner-damaging organics.

laSTM - American Society for Testing and Materials.
SW-846, “Test Methods for Evaluating Solid Waste," July 1982.
2annual waste recharacterization is planned.

Sump checked weekly for leachate collection. Will analyze as necessary.

ZL td 2ISeM - dyM LapOW

SI 40 OT abeg


. How much lime needs to be added for proper neutralization?

. What storage tank construction materials are compatible with
the waste?

. What pretreatment if any is needed before waste management
processing?

Waste Parameters to be Monitored

This section addresses--

. waste parameters to be analyzed for characterization and the
rationales for parameters selected,

. frequency of recharacterization, and

. waste shipment screening and key ("fingerprint") parameters for
screening.

Waste Characterization

Waste parameters must be selected to represent those characteristics
necessary to manage the waste in compliance with permit conditions. The
rationale for selecting each parameter, addressing how well the parameter
represents the information needed for compliance, should be described in the
waste analysis plan.

Waste analysis parameters should be selected after 1) reviewing existing
information on the waste properties (e.g., 40 CFR 261 Appendix VII, EPA listing
and delisting background documents, process engineering studies, industry
association waste characterization studies), 2) noting what properties best
indicate any change in a waste's composition, and 3) comparing this information
to the facility's design criteria and, if appropriate, trial treatment test
results,

Waste analysis plans need to include procedures for complying with the
specific waste management requirements described in 40 CFR 264.17 and 264,341,
40 CFR 264.17 addresses three waste parameters: ignitability, reactivity, and
incompatibility. Incompatible wastes, if brought together, could result in heat
generation, toxic gas generation, and/or explosions. A waste analysis plan
must therefore address measures to identify potentially ignitable, reactive,
and incompatible wastes. Standard tests to identify ignitable wastes can be
found in Section 2.1.1 of "Test Methods for Evaluating Solid Waste" (SW-846).
Reactive wastes are also defined in this document, although standard tests are
not yet available to measure the reactivity of all wastes. Waste compatibility

10


Model WAP - Tank: Page 9 of 12

TABLE 2, WASTE CHARACTERIZATION/RECHARACTERIZATION FOR WASTEWATER
TREATMENT PLANT SLUDGE!» 2

Rationale for

Parameters Analytical Method Parameter Selection
Reactivity U.S. Gap Test or U.S. Assure storage safety
Internal Ignition Test
% Water ASTM 095 - Distillation, or Value used to assess
reactivity

ASTM D1796 - Centrifuge

pH pH Meter Method 9040 (SwW-8464) Verification of waste

lapplicable to both sludge streams (1 and 2).

Semiannual recharacterization is planned.

3fAuthor's note: These explosivity tests are currently under development by
the Bureau of Mines for EPA. ]

4sw-846 "Test Methods for Evaluating Solid Waste" July 1982.




Model WAP - Land Treatment Page 7 of 16

. the potential for other materials onsite to be combined with the
wastes by mistake,

. the variability of waste composition, and

. the likelihood of the sludge undergoing changes that alter its
permitted characteristics.

Experience has shown that the concentrations of chromium and lead in the
wastes are relatively consistent over time. However, we plan to analyze the
wastes quarterly for these and other key parameters because the potential
exists for environmental contamination if untypical wastes cause the treatment
process to perform poorly. Complete waste characterizations will be performed
annually to provide an accurate profile of the wastes. All analyses will be
performed in-house, and results will be recorded on the characterization form
shown in Figure 1. Should the quarterly analyses or annual
recharacterizations indicate that one or more of the waste parameters are
outside the permit conditions, we will handle the waste as described below.

If we are ever notified by one of the process area personnel that the
refining or wastewater treatment process or the means of operation have
changed, we will check the wastes for changes in character. After obtaining
as much information about the change as our personnel can provide, we will
take an unscheduled sample from the tanks and completely characterize it in
the onsite labs. The characterization results will be evaluated to decide if
the waste characteristics are within the permitted ranges. If the waste
characteristics do not comply, we will make every effort to find an offsite
commercial hazardous waste management facility to receive the waste. In the
interim, the waste will remain stored onsite in mobile tanks or open bed
trucks.


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Model WAP - Waste Pile: Page 2 of 15
2. Identification of Wastes Piled

Listed in Table 1 are the filter cake characteristics that are important
in operating the waste piles in compliance with RCRA permit conditions. This
characterization was performed by the analysts on our wastewater treatment
plant staff and by XYZ Labs. (An example XYZ lab report is found in Appendix
I.) The characteristics in Table 1 reflect the analysis results from eight
samples of the filter cake taken at 6 to 8 week intervals over a period of 1
year. These results are supported by operating data collected over the past 10
years and by data presented in EPA's background information document (BID) on
these waste streams (K002, KOU3, and KO04). Quality assurance and quality
control procedures used to characterize the filter cake are described in
Appendix II of this waste analysis plan.

The filter cake must meet the following boundary conditions:

* total chromium < 350 ppm + pH 9.2 to 11.5
+ lead < 100 ppm . ltrichloroethylene < 0.25%
+ water < 70% . lethyl benzene < 0.25%

These boundary conditions have been established so as to identify significant
changes in waste characteristics and any anomalies in waste generation
processes.

l\trichloroethylene and ethyl benzene are used as solvents onsite, but they are
not normally released to the wastewater treatment system.

(Note: This model waste analysis plan will not address the management of
these spent solvents. A real waste analysis plan would be required to do so.
A separate model plan in this manual (container storage) addresses this issue.]


Model WAP - Container: Page 6 of 15

If characterization analyses ever indicate that the waste is either
unacceptable by the reclaimer or incompatible with our wastes stored onsite,
we will follow the procedures described in the following paragraphs.

Should one of our process area personnel ever notify us that the solvent
degreasing process or its means of operation has changed, we will check to see
if the spent trichloroethylene has changed in character. As much information
about the change will be obtained as our personnel can provide. We will
obtain an unscheduled sample (according to our sampling procedures) and submit
it to Smith Labs for analysis. We will inform Smith personnel of any known
property changes and they will analyze the waste according to the agreed
analysis procedures. As per our standard agreement with Smith, should they
detect any change of greater than 15 percent in specific gravity, a flash
point below 60° C, or an unexpected constituent in the gas chromatogram, Smith
Labs will notify us.

We will notify the commercial reclamation contractor of any change, so
that the contractor can decide if the waste is still acceptable at his
facility. If the waste is not acceptable, we will make every effort to find
another reclaimer to receive the waste. In the interim, the waste will remain
stored onsite.

The storage pad is already designed to comply with RCRA regulations for
storing ignitable waste if the waste flash point ever becomes less than 60° C.
Should any wastes be incompatible with the wastes currently in storage, we
will contact our reclaimer and, if acceptable, load and ship the wastes to him
in order to avoid common storage with the typical wastes.


TABLE 1.

Model WAP - Tank: Page 3 of 12

SLUDGE CHARACTERISTICS

Stream)

Chemical Composition

1. Sludge entering tank

2. Sludge leaving tank

Nitrocellulose: not more than 5% by
volume
at least 95% by volume

negligible

Water:
Other constituents:
pH: 8.0 to 10.0
Nitrocellulose: not more than 25% by
volume

Water: at least 75% by volume

Other constituents: negligible

pH: 8.0 to 10.0

RCRA number: K044 (40 CFR 264.32).
Process code is S02, tank storage.


Model WAP - Incineration: Page 12 of 20

recharacterization, analyzing for all the parameters previously selected and
any additional parameters that may he necessary. Based on these results, we
will accept or reject the waste shipment.

If we are notified hy one of our generators or we suspect that a waste
yenerating process or its operation has changed, we will analyze the waste to
see if its character has changed. We will obtain as much information about
the change as the generator can provide, receive the generator's approval to
take an unscheduled sample, and then completely characterize it. We will
evaluate the characterization results to decide if the waste meets the permit
envelope of parameter limits when blended for waste feed. If it does not, we
will reject the waste.


Model WAP - Tank: Page 8 of 12

The following information summarizes the previously described sampling
procedures:

Containment Device Lines leading to and exiting tank
Sampling Technique Grab samples

Sampling Device Dipper

Number of Samples Taken Stream 1. - one

Stream 2. - three, at beginning, midway,
and end of tank drainage

Comments 1. Wear rubber gloves, face shield, and

self-contained breathing apparatus.

2, Make sure ventilation is adequate.

3. Place sample in linear polyethylene
container.

4. Do not Tet sample dry out.

5. Protect sample from excessive heat
and direct sunlight.

6. Potentially REACTIVE,

References Technique: su-8461, Section 1.4.2
Device: SW-846, Section 1.2.1.3

lsw-846 "Test Methods for Evaluating Solid Waste" July 1982,

Quality assurance and quality control procedures for waste sampling are
described in the appendix.

Analysis

The wastewater treatment sludge has been characterized to confirm its
compliance with anticipated permit conditions. Section 4 describes how we
selected the waste characterization parameters. Table 2 identifies the test
method selected for each parameter and the rationale for selecting the
parameter. All analytical methods listed in Table 2 are from EPA's "Test
Methods for Evaluating Solid Waste" (SW-846) or the American Society for
Testing and Materials (ASTM) compendium of test methods. Quality assurance and
quality control procedures for waste analysis are discussed in the appendix.


TABLE 2, (continued)

Stream Containment Sampling Number of Samples

Numbers Device Technique

Taken

Comment s References

5. 55-gallon Simple random
drums sampling.
Grab sample
with trier.

3/ No. of dru
in shipment

3

Store in a cool, Technique: SW-846,
well-ventilated Section 1.1.3.1
area. Device: SW-846,
Wear goggles, Section 1.2.1.5
breathing mask,

gloves, apron, and

boots.

Place sample in

linear polyethylene

container.

Use Teflon® cap.

Get sample through bung

across depth of drum.

TOXIC WASTE.

lsw-846 “Test Methods for Evaluating Solid Waste" July 1982.
2source of cube root equation: American Society for Testing and Materials, Method D 140-70.

Juawzes4y [PdLWey) - dyM LePoW

02 40 €T abe


Model WAP - Tank: Page 4 of 12
3. Tank Storage Process Tolerance Limits

In addition to the sludge boundary conditions described previously, the
tank storage process is limited by the volume of sludge the tanks can hold
safely. (Tank design information is in another chapter of this Part B
application.) The tank should also not be allowed to receive wastes that may
be incompatible with the sludge due to the potential for reaction. The tanked
sludges must never be exposed to any sources of reaction because they may
contain concentrations of reactive nitrocellulose that could be triggered.

These tolerance limits represent those qualitative and quantitative waste
characteristics that the tank structure can manage within the RCRA permit
conditions.


Model WAP - Waste Pile: Page 5 of 15

4, Filter Cake Parameters to be Monitored

To select the appropriate waste parameters to monitor, The Color Company
1) reviewed existing information on the waste properties, 2) noted what
properties best indicate any change in the filter cake, and 3) compared this
information to the waste pile design criteria so that we can prevent any
noncompliance with RCRA permit conditions.

Our operating experience has shown that the filter cake characteristics
are only expected to vary in lead and chromium concentrations, the percent
volume of water, and the pH. (See Appendix C of this Part B application for
sample operating data.) The waste pile limitations in Section 3 confirm the
need for measuring percent moisture and pH. It has heen determined that the
filter cake is neither ignitable nor reactive; therefore, it is unnecessary to
test for these characteristics. (Test results are available upon request.)

The metal concentrations in the cake will vary depending on pigment
production rates. Since the waste pile PVC liners are not sensitive to the
concentrations of these metals, any changes would not influence the waste pile
performance. However, chromium and lead are measured 1) to ensure compliance
with the RCRA permit waste description, 2) to assure waste composition
consistency, and 3) to be prepared should a spill occur onsite.

The percent volume of water in the filter cake is a factor that needs
monitoring. Liquids should not be allowed to accumulate at the base of the
waste pile; therefore, the filter cake must be sufficiently dewatered to
minimize liquids. A vacuum filter cake should be able to retain 70 percent
water. Any volumes greater than this may create liquids that could
potentially leak and transport metals into the environment if the waste pile
liner were damaged. The pH of the typical alkaline filter cake is measured to
indicate a change in the filter cake's characteristics, Unusual filter cake
pH values could damage the pile liner and cause leakage.

Tne Color Company has considered the potential for liner-damaging organic
constituents to he present in the filter cake. Based on our knowledge that
the pigment producing processes use no organics directly, we have no reason to
suspect that liner-damaging organics would be present in the filter cake,
However, trichloroethylene and ethyl benzene are used as cleaning solvents but
are normally Kept separate from the wastewater streams. We will analyze for
these solvents to assure they are not present in the sludge.

We decided how often to characterize the filter cake hy considering --

. the potential for other materials onsite to he mistakenly
combined with the waste pile filter cake,

. the variability of the filter cake composition, and

. the likelihood of the filter cake undergoing changes that would
alter its permitted characteristics.


Model WAP - Waste Pile: Page 14 of 15

Collector bo. Harm) Date Sampled Loft [23 Time {: 3% o.m. Hours

Affiliation of Sampler «gm jplbipen. he oto pats

Address _ HOO dmuth dé. HarIaaale - - DQQNAQO

number street “city state Zip
Telephone (00) sa 5-/2/2 Company Contact J. Godunarn)
LABORATORY
SAMPLE COLLECTOR'S TYPE OF
NUMBER SAMPLE NO. SAMPLE! FIELD INFORMATION2

Tee -! fea fui tow. ample appears Dyucal

Analysis Requested oaure Liat Chasmtm, bead. Lrichlorp-

Special Handling and/or Storage Urears hudebitad aorta, tart, jabarta,—

PART II: LABORATORY SECTION2

Received by «J. Paaul Title ha Ligh fiilate vate fo/z /g3

Analysis Required

1 Indicate whether sample is soil, sludge, etc.
Use back of page for additional information relative to sample location.

Figure II-2, Sampling analysis request.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


Model WAP - Container: Page 13 of 15
APPENDIX IT

Quality Assurance/Quality Control Program

Program Goal

Our program's goal is to obtain accurate and precise data on waste
characteristics and to maintain an up-to-date log of those data. The
analytical data we obtain are available --

. should a spill occur onsite, or

. so we can notify our solvent reclamation contractor if a process
or operation change occurs.

Since the only hazardous waste constituent we store onsite is
trichloroethylene, our data need to center around their properties. We
measure only three parameters in our waste, so the quantity of data we need is
minimal.

Sampling Program

We sample our own waste. One person is the sampler. He has been
properly trained to sample the waste using the equipment described in Section
5. A description of his training is found in our "Training Program" chapter
of Part B. His sampling skills are evaluated semiannually by our
environmental manager; we feel this is a sufficient frequency since
characterization sampling routinely occurs annually.

Once a sample is taken, the Coliwasa is decontaminated as directed by the
device's manufacturer, When samples are taken, our employee logs vital data
in a field book, labels the containers (See Figure II-1), and hand carries
them to a designated room for cool storage until Smith Labs picks the samples
up (within 24 hours). The employee prepares a request for analysis (see
Figure II-2), which accompanies the samples to Smith Labs to specify waste
samples and analytical data needed.

Analysis Program

All analytical procedures required by our company have been specified in
a contract with Smith Labs. Smith is a commercial laboratory with trained
analysts who are retrained annually. They maintain a rigorous quality
assurance/quality control program which is available for review by EPA upon
request. All of the hazardous waste analyses they conduct are performed
within 48 hours of receipt and comply with SW-846 quality assurance/quality
control procedures for specific test methods.

Analytical data are documented, returned to us for evaluation by our
environmental manager, and then filed.


Model WAP - Chemical Treatment: Page 4 of 20

Date
1. Generator
a. Name
hb. Address

c. EPA ID Number

2. Waste Identification
a. Facility Waste Number Sample Number
b. RCRA Waste Number
c. DOT Waste Number
d. Name of Waste

e. General Description of Waste Generation Process

3. Sampling
a. Date Sampled b. Sampling Method

c. Name and Affiliation of Sampler

d. Was sample taken during normal process operation? Yes No
4, Physical State (21° C (70° F)) Solid Sludge Liquid

5. Specific Gravity

6. Corrosive Yes No pH (regardless of corrosivity)

7. Ignitable Yes No Flash Point °C oF

Test Method

Figure 1. Waste characterization form.


Model WAP - Incineration: Page 8 of 20
3. Incinerator Tolerance Limits

The waste feed to the incinerator must be semisolid or liquid and have a
heating value that meets the temperature requirements of the incinerator. The
total feed rate to the incinerator must range from 7.56 X 106 keal/nr (30 X 196
Btu/hr) to 1.26 X 107 kcal/hr (50 X 10 Btu/hr). The heating value of each
organic constituent in the waste feed must be » eates than the heating value for
the pure indicator POHC designated at trial burn - methylene chloride (1.7
kcal/g (3,067 Btu/1b)). Methylene chloride attained a 99.99 percent destruction
and removal efficiency during the trial burn. The chloride content of the waste
feed must not exceed 5 percent. This Timit, leads to optimum scrubber removal of
chloride emissions, This value is the maximum concentration for which compliance
with incinerator performance standards was demonstrated during the trial burn.
The waste feed must not have a water content greater than 5 percent, because
water reduces heating value and, in turn, burning efficiency. Also, two types
of problems can arise if sufficient water is present to cause phase separation:
1) the potential for equipment damage if freezing occurred, and 2) perturbation
of the combustion process if a slug of water were introduced into the feed.
Complying with these limits helps ensure that 99.99 percent of the POHCs will be
destroyed and removed. Ash content of the waste feed must be less than 30
percent in order to comply with particulate emissions standards.


Model WAP - Incineration: Page 17 of 20

APPENDIX I

Quality Assurance/Quality Control Program

Program Goal

Our program's goal is to obtain accurate and precise waste data so that we
can assure that the wastes we incinerate possess the chemical/physical properti
specified in our permit. We accomplish this by making sure that --

. the wastes meet the predetermined characteristics, and
. no restricted wastes are accepted.

We generate a great deal of data at the facility. Therefore, we carry out the
quality assurance/quality control program to the fullest to assure that accurat
and precise data are obtained.

Sampling Program

Designated personnel have been trained to sample waste shipments. This Pz
B application contains a chapter on their training program. Our operations
manager evaluates the employees’ sampling skills quarterly. Sampling equipment
inspected for decontamination and operability before each shipment is sampled.
Each inspection is documented, noting any problems and corrective actions take:

Since our facility handles more than one waste and one generator, all samj
containers are labeled (see Figure I-1), and vital sampling information is log:
in the field (see Figure I-2) before another employee drives the samples and ai
accompanying list of those samples to the laboratory for analysis.

Analysis Program

Our laboratory personnel have been trained to perform the analytical
Procedures outlined in Table 2. This Part B application contains a descriptio:
of their training program. The employees’ analytical skills are checked with
blanks or standards that are included in each analysis.

Lab personnel document the receipt of each sample. Waste samples are stort
according to their expected content until analysis. Screening samples are
analyzed as soon as possible to avoid delays in shipment processing.
Characterization/recharacterization samples are analyzed depending on their
storage life. Sample identification numbers are assigned to the replicates th.
are analyzed. The quality assurance/quality control procedures for analysis
follow those outlined in each test method of SW-846, "Test Methods for Evaluat
Solid Waste," or other EPA-approved methods.


Model WAP = Chemical Treatment: Page 2 of 20
2. Identification of Wastes to be Treated

Table 1 contains all the pertinent characteristics of each waste stream
to be treated onsite. Any other waste types will be restricted from the
facility.

Our staff sampled and analyzed each waste for its initial
characterization. This entailed collecting four sets of samples at 3-week
intervals. The results of the sample analyses are summarized in Table 1.
Specific data sheets are available upon request. (Quality assurance and
quality control programs for sampling and analysis are described in the
appendix.) This characterization was intended to determine that the wastes
fell within the categories planned for treatment. Figure 1 is an example of
the waste characterization form completed for each waste. Four generators
provided their waste analysis data from past years to support our results.
The fifth facility is relatively new, so they obtained data from a similar
facility with 14 years of operating experience to support their waste data.

The waste stream boundary conditions are the maximum and minimum values
of waste characteristics that the facility can treat properly. We have
selected boundary conditions of plus or minus the following percentages of the
limits found in Table 1:

. segregated cadmium wastewater treatment sludge + 10%,
. pigment filter cake + 5%,
. emission control dust/sludge from secondary lead smelting + 15%,

* emission control dust/sludge from the primary production of steel
in electric furnaces + 10%, and

. cumene distillation bottom tars + 20%.

For example, pigment filter cake boundary conditions for pH would be 5 percent
less than 7.0 (i.e., 6.65) and 5 percent more than 9.5 (i.e., 9.98). These
conditions were set following our waste analyses and talks with generators
about the consistency of their wastes. The wastes are not expected to fall
outside these limits; however, if they do, we will follow the contingency
procedures described in Section 4, “Parameters to be Monitored."


Model WAP - Landfill: Page 6 of 21
3. Landfill Tolerance Limits

Sludges to be landfilled must not contain more than 70 percent water.
[Note: This is an arbitrary value selected for this model.] The remainder of
the sludge must be solids to assure minimal leachate generation. Also, the
wastes must not contain any free liquids.

Tolerance limits are established to assure optimum landfill performance.
They reflect those waste properties beyond which the landfill cannot safely
contain each waste. In this case, water content and the presence of free
liquids are the central factors in establishing tolerance limits.


Model WAP - Landfill: Page 10 of 21

testing for all the parameters included in the initial waste characterization.
Rather, we select a subset of these, designated "key parameters," so we can
obtain the best indication of waste manageability within the given time and
labor constraints. We consider four criteria when selecting key parameters.
These are--

. the need to identify restricted wastes;

. waste characteristics that might affect the landfill's performance;

. the ignitability, reactivity, and/or incompatibility of the wastes;
and

. those parameters that best indicate any changes in important waste
characteristics.

A more detailed description of these procedures is found in Section 5, "Waste
Sampling and Analysis."

If a shipment screening indicates that a waste has characteristics that
are inconsistent with our acceptance criteria, we contact the generator and,
if requested, perform a complete recharacterization, analyzing for all of the
Parameters previously selected and any additional parameters that may be
necessary. Based on these results, we accept or reject the waste shipment.

If we are ever notified by one of the generators or suspect that the
waste generating process or its means of operation has changed, we check to
see if the waste has changed in character. We obtain as much information
about the change as the generator can provide, and with the generator's
approval, take an unscheduled sample and completely characterize it. We then
evaluate the characterization results and decide if the landfill facility can
continue to manage the waste safely within permit conditions. If not, we will
reject it.


WASTE ANALYSIS PLANS

A Guidance Manual

This publication (EPA/530-SW-84-012) was prepared for
the Office of Solid under contract no. 68-03-3149-1-3 and
is reproduced as received from the contractor.

U.S. ENVIRONMENTAL PROTECTION AGENCY
1984


Model WAP - Chemical Treatment: Page 20 of 20

Lab personnel document the receipt of each sample. Waste samples are
stored until analysis according to their expected content. Screening samples
are analyzed as soon as possible (less than 24 hours) to avoid delays in
shipment processing. Characterization/recharacterization samples are analyzed
depending on their storage life. Sample identification numbers are assigned to
the replicates analyzed. The quality assurance/quality control procedures for
analysis follow those outlined in each test method of SWi-846, "Test Methods
for Evaluating Solid Waste," or other EPA-approved methods.

All test results are documented on the characterization form shown in
Figure 1 and kept on file in the facility office.

Analytical equipment is inspected and serviced semiannually in addition
to routine checks before each analysis. Leftover waste samples will be
returned to the appropriate storage container for later treatment.


Model WAP - Incineration: Page 1 of 20

MODEL WASTE ANALYSIS PLAN
INCINERATION!

1. Facility Description

The Controlled Combustion Company operates a commercial hazardous waste
incinerator, receiving wastes transported in tankers from offsite generators.

We are requesting a RCRA permit to incinerate halogenated and
nonhalogenated solvent distillation recovery bottoms, in particular, from the
spent solvents methylene chloride, trichloroethylene, and acetone. These
wastes are designated RCRA hazardous hecatse the first two contain toxic
compounds and the third contains an ignitable compound. These wastes do not
exhibit any reactive or corrosive characteristics. It is anticipated that we
will accept additional wastes for incineration in the future,

The wastes described above require no treatment before incineration.
They are documented as mutually compatible by "A Method for Determining the
Compatibility of Hazardous Wastes" (EPA-600/2-80-076) and can be stored ina
common area before incineration.

The incinerator is designed to destroy and remove 99.99 percent of the
wastes' principal organic hazardous constituents (POHCs) so that little or no
emissions to the environment will occur. Trial burns have been conducted for
EPA using methylene chloride as the indicator POHC. The trial burns destroyed
and removed more than 99,99% of the methylene chloride and maintained
performance standards (40 CFR 264,343) in which the trial burn material
contained 5 percent chloride, 5 percent water, and 30 percent ash.

lthis model waste analysis plan will not address the container and tank
storage of the wastes onsite since storage is addressed in other model plans.
A real waste analysis plan would be required to detail the storage aspects of
the facility.


TABLE 2. WASTE CHARACTERIZATION/RECHARACTERIZATION FOR ELECTROPLATING
WASTEWATER TREATMENT PLANT SLUDGE!

Rationale for Detection
Parameters Analytical Method Parameter Selection Limit
(ug/L)
Cadmium AA Direct Aspiration, Methods Verification of waste 5
3050/7130. (SW-8462)
Total AA Direct Aspiration, Methods Verification of waste 50
chromium 3050/7190 (SW-846)
Cyanide Total and Amendable Cyanide, Method Identify potential reactivity -
9010 (SW-846)
pH pH Meter, Method 9040 (SW-846) Identify potential corrosivity -
Total organic Combustion - Infrared Method, Method Identify liner damaging organics 1,000
carbon 505 (APHA3)

Jannual recharacterization is planned.

2sW-846 "Test Methods for Evaluating Solid Waste," July 1982.

3APHA American Public Health Association Standard Methods for the Examination of Water and
Wastewater 15th edition, 1980.

quawpunodwt - gym Lapow

9T $0 6 Abed


Model WAP - Tank: Page 7 of 12

5. Waste Sampling and Analysis

Sampling

The wastewater treatment sludge is sampled semiannually at two locations:
1) the inlet pipe directly at the storage tanks, and 2) the effluent pipe that
drains the tanks. These sampling points were chosen because limited access to
areas within the tanks limits the sample representativeness. The inlet pipe
sludge is grab sampled during normal operations. The effluent is sampled as a
tank is emptied for offsite shipment. It typically takes 1 hour to drain each
tank, so we grab sample the initial effluent from the tank outlet pipe and
continue to sample the effluent at 30-minute intervals. Each sample is
containerized separately for analysis, giving us data on one sludge sample
before it enters the tank and on effluent samples from three depths in the
tank as it is drained. We do not composite these samples because the true
reactivity of the sludge may be diluted.

We sample the flowing sludge with a dipper made of a glass heaker and
fiberglass pole, both of which are not reactive to the sludge (SW-846,
1.2.1.3). The samples are stored in nonreactive glass containers.

Sampling for semiannual sludge recharacterizations and any unscheduled
sampling follows the procedures described above.

We reviewed the scientific literature and our previous work history to
identify any needs for special sludge handling procedures during sampling.
This enables us to be certain that our employees are protected and our samples
remain representative during storage.


APPENDIX D
DRUMMED WASTES - ESTIMATING SAMPLING SIZE

qh Designation: 0 140 - 70

AMERICAN SOCIETY FOR TESTING AND MATERIALS

1916 Race St., Philadelphia, Pa., 19103
Reprimed from the Annual Book uf ASTM Standards Cupynghe ASTM.

Standard Methads of

SAMPLING BITUMINOUS MATERIALS’

‘Then Standard 1 maued under the fixed dengnatwon U 140: the aumber immediately follusing the dexugnauun indicates
the year of oneinal adoption or. in the cise if reviwm, the sear wf lank fevmuon. A’ number ta patentbnees mehcaee tee

year of last reapproval.

12. Sampling Semisolid or Uncrushed Solid
Materials

12.1 Drums, Barrels, Cartons, and Bags—
Where the lot of material to be sampled is
obviously from a single run or batch of the
producer, one package shall be selected at
random. and sampled as described below.
Where the lot of material to be sampied is
not obviously from 2 single run or batch of
the producer, or where the single samples
selected as described above fuils on test to
conform to the requirements of the specifi-
cations, 2 number of packages shail be se-
lected at random equivaient to the cube rout
of the total number of packages in the lot.
The following table is given, showing the
number of samples to be selected for ship-
ments of various sizes.

Packages in Shipment Packages Selected

3

B

&

$3,

a
SSonssweun

730 to 1000, 1
1008 ta 1331 1

Samples shail be taken from at least 3 in.
(76 mm) below the surface and at least 3 in.

from the side of the container. A clean hatchet
may be used if the muterial is hard enough to
shatter and a broad. iff putty knife if the
material is soft, When more than one package
in a lot is sampled. each individual sample
shail be not less than 7. [b (0.1 kg) in weight.
When the lot of material is obviously from a
single run or batch of the producer. ail sam-
ples from the lot shall be melted and thor-
oughly mixed. und an average |-gul (4-dm’)
sample taken from the combined material for
examination, In case more than a single run
or batch of the producer is present and the
batches can be clearly differentiated, a com-
Posite |-gai sample shall be prepared for ex-
amination from each batch. Where it is not
possible to differentiate between the various
batches, each sample shull be examined
separately,


TABLE 4, WASTE ANALYSIS INFORMATION FOR API SEPARATOR SLUDGE AND DAF FLOAT!
Detection
Parameters Analytical Methods Limit Rationale for Parameters
(ug/L)
Specific gravity ASTM 01429, Method C Verification of waste.
(Erlenmeyer Flask) -
*2Percent water ASTM D95 - Distillation, or Treatment performance affected
01796 - Centrifuge by percent water in waste.
*Electrical Method 9045 - Treatment performance affected
conductivity (SW~846)3 by conductivity of waste.
*DH pH Meter Method 9040 - Treatment performance affected
(SW-846 ) by pH of waste.
Flash Point Method 1010-Closed cup - Check for ignitability to assure
(SW-846) safe handling.
Reactivity U.S. Gap Test or U.S. - Check for explosivity to assure
Internal Ignition Test4 safe handling
Arsenic AA Method 7061 2 Identify unexpected constituents.
(SW-846)
Barium AA Methods 3030/7080 100 Identify unexpected constituents.
(SW-846)
Cadmium AA Methods 3030/7130 5 Identify unexpected constituents.
(SW-846)
*Total chromium AA Methods 3030/7190 50 Verification of waste and
(SW-846) reference to assess treatment
. performance.
Lead AA Methods 3030/7420 100

(SW-846)

zquauyee4) puel - d¥M Lapow

9T 30 21 abeg


REFERENCES

1. Permit Applicants' Guidance Manual for the General Facility Standards of
40 CFR 264. SW-968, U.S. Environmental Protection Agency, Washington, D.C.
1983. Available from Superintendent of Documents, U.S. Government Printing
Office, Washington, D.C.

2. Hatayama, H. K., J. Jd. Chen, E. R. de Vera, R. D. Stephens, and D. L.
Storm. A Method for Determining the Compatibility of Hazardous Wastes.
EPA-600/2-80-076, U.S. Environmental Protection Agency, Cincinnati, Ohio,
1980. 149 pp. Available from Superintendent of Documents, U.S. Government
Printing Office, Washington, D.C.

3. Test Methods for Evaluating Solid Waste. Physical/Chemical Methods.
SW-846, 2nd Edition, U.S. Environmental Protection Agency, Washington, 0.C.
1982. Available from Superintendent of Documents, U.S. Government Printing
Office, Washington, D.C.

4, 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. Available from the
National Technical Information Service (NTIS No. PB84-158807).

5. Permit Applicants' Guidance Manual for Hazardous Waste Land Treatment,
Storage, and Disposal Facilities. SW-84-004, U.S. Environmental Protection
Agency, Washington, D.C. 1983. Available from Superintendent of Documents,
U.S. Government Printing Office, Washington, D.C.

6. Guidance Manual for Hazardous Waste Incinerator Permits. SW-966, U.S.

Environmental Protection Agency, Washington, D.C. 1983. Available from
Superintendent of Documents, U.S. Government Printing Office, Washington, D.C.

24


TABLE 4-2. (continued)

|
WASTE PILES (cont'd.) | INCINERATION (cont'd.)

2. Determining the compat- \2. Sampling and analysis

ibility of a waste to other [procedures for item 1.

wastes potentially held in |parameters? yes no
the same pile, other piles, | ~~
container, open tanks, or | THERMAL TREATMENT

surface impoundments |

onsite? __yes___no|Does the waste analysis plan include

{the following information:
3. Determining the compat-

ibility of a waste to 1. Additional waste
wastes previously held on |characteristic parameters
the pile base if it was not required:

decontaminated (unless it

can be proven the wastes + Heat value
are the same)? __yes___no|+ Halogen content and
~~ | sulfur content

4. Analyzing ignitable/ {* Concentrations of
reactive wastes managed in | mercury and lead,
waste piles? yes _noj| unless documented data

—_ show the elements
5. a) Sampling and aren't present? yes__no
analyzing leachate | —_
collected beneath the pile, {2. Sampling and analysis
and b) managing the {procedures for these
leachate if hazardous? ___yes___no|parameters? __yes__ no

|

INCINERATION |PHYSICAL, CHEMICAL, AND BIOLOGICAL

| TREATMENT

Does the waste analysis plan include |

the following information: {Does the waste analysis plan include
|the following:

1. Additional waste

characteristic parameters {1. Any additional waste

required as a result of an [characteristic parameters

EPA-approved trial burn: [required as a result of an

{EPA-approved trial test? _ yes no

+ Heat value

+ Viscosity (if applicable) |2. Sampling and analysis

+ Appendix VIII constituents |procedures for these

+ POHCs! designated from |specific parameters? ___yes__no
Appendix VIII con- |
stituents? yes _no|

20


Model WAP - Land Treatment: Page 16 of 16

Date ¥ 83
Sample Identification Number aA. Q Time :0O0a.m.

1.

6.

7.

Waste Identification
Purpose of Sampling

a. Sampling poing Location

be. eh
iach Beiens hi es Mies nt tank)

a. Number of ee Taken ane Volume per Sample
One One Aten)
Any Field Measurements Taken /0o”

Parameter Measurement

Observations During Sampling Pleat domple diem

than novmal. Roinag wntather) uty, arpling

a. Sample Destination b. Means of Transport

Un- Asuse Ladrorolbey Druck’
Signature of Sampling Person: ZL. tes

Figure A-2. Field log.
Source: "Test Methods for Evaluating Solid Wastes", SW-846, July 1982.


TABLE 3. (continued)
Detection Rationale for
Stream Parameter Test Method Limit Parameter Selection
(ug/L)
A-2, B-1, C-1, *sulfide SW-846, Method 9010 1,000 Identify restricted
(Titration) sulfide wastes in
aqueous-based media.
A-2, B-1, C-1, D-1 *Radioactivity Radiation Detector - Identify restricted
radioactive wastes.
D-1, L-1 Phenol SW-846, Method 8040 - Verification of waste.
(GC/FID)
D-1, L+-1 PAH SW-846, Method 8100 - Verification of waste.
(GC/FID) :
D-1 *PCB SW-846, Method 8080 0.065 Identify restricted PCBs
(GC/ECD) (for one in an organic media.
isomer)
A-2, B-1, C-1, Volatile and SW-846, Methods 8240 Based Identify any hazardous
D-1, L-1 semivolatile and 8250, respectively on organic constituents
organic (GC/MS) constituent that are present.
constituents.

lRecharacterization Frequency: A-l-none; B-l-quarterly; A-2 and D-1-semiannual; C-1-annual.

2asterisk denotes key parameter measured with each shipment.

3sW-846 "Test Methods for Evaluating Solid Waste" July 1982.
ASTM - American Society for Testing and Materials.

4fauthor's note:

This test method will be included in the next edition of SW-846.]
S[Author's note: These explosivity tests are currently under development by the Bureau of Mines for EPA.]

LLEspueT = d¥M LePOW

TZ 30 LT abeg


Model WAP - Landfill: Page 20 of 21

FIELD LOG
pate 7/22/93
Sample Identification Number A-2-l Time jO¢/5a.m.
1. Waste ste tyne Don imemt
a. Waste Type Pig
b. Facility Waste amen A sludog
c. Suspected Composition y Wh UtacLancd Oren
2. a. Waste Generator Afpha Cole Une. 6. Generation Process .
Address ? mM pragracal
Qiphavith, USA - woosmivdle opeateder
3. Purpose of Sampling plat Aludng.
4, a. Sampling Point Location Closed -Lded ould
b. Description
Gruard Occ prt - vole Cow ample
5. a. Number of Samples Taken b. Volume per Sample
Ore One Liev
6. Any Field Measurements Taken Iw
Parameter Measurement
7. Observations During Sampling bh pt Rp £ ‘ )
8. a. Sample Destination b. Means of Transport

Um -Arvae AebersTouy Irueke

Signature of Sampling Person: & Lursaell

Figure A-2. Field log.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


TABLE 1. RANDOM NUMBERS

Day 1(21)  2(22) 3(23) 4(24) 5(25) 6(26) 7(27) 8(28) 9(29) 10(30)
6 19087 e40 12008 23092 34608 Tse08 4
Month 1 aiiie Huns HGH boone ose Stor Heat Sosee Biset ste Hee Sone Stes) tt SRae &
21666 44190 (21423 46281 92238 96306 72606 20601 nos 3367) 1? 92739 94519 39473
67 30779 14 16183 06:01 90386 80292 $4355 47371 ‘16746 26190 21287 1769833490 6033 3 OR134
V6A42 3879 47486 19838 32252 39560 95851 36758 36141 $2253 69293 2938) 59965 14258 54530 47274 66EG 55087 3873T
$096u 28728 $3525 16031 771589 65578 B79 51367 32835 1904 16055 87089
HOUSE dares. Se0l? Sino Joe Sas6 45395 22847 iin Hes me Sas 2ees te BS Be mv sos
2 yeas G03s9 each 29684 ta fon ole Ha 1ON9 495th 1540 61781 32769 31662 55606
HaUSe GS Ge Be ie is TG iat SUR TU ek ies ate ie ae ae
SiSOD 93521 106BL 44126 BE34S 84969 381 9 229k 41233 ‘E'VUS 1979 02979 $4002 ules T9EI3 33999 10ST Ouhed GeaeE
40389 76282 37506 6OG6t 23295 67357 ‘37833 09152
$9244 54664 63426 97899 4415) 69251 2912 21658 i at $aMz s6002 26596 EATS E4039 97570 e4asy 55592
3 99876 17075 40934 09912 96196 58503 6361 9 3 Guoas 14933, 92188 $3767 $6148 $6261 79920 FasI4
06457 $0072 18060 71023 4349 40984 $9487 77782 32107 $3770 SRESS B53 Sonag SZET” Sones 32500 24106 e054 7O372 71063
14297 07687 05817 10962 3378) 62236 63764 43542 64249 O3E62 204 26212 37325 $1470 $6108 23141 16121 53925
‘95032 14283 20642 1531) 36298 12079 67596 OOD17 $1789 1T
‘$1661 $7190 97442 29590 21634 RR ‘Tye Ry (46467 47152
5543” 1788 16117 09698 24409 05079 76503 3461 46791 Prost staso Jonas onsse sa716 svmis 2579 334 62025 3255
4 4608 P1512 62819 27689 63744 he we ep ‘M28 7019 18355 24630 15077 47256 03529 34837 24163 93621 33483
491€ preoz 96950 41536 39976 a8 45519 79263 zz ODte7 ayeog 1209) ites SUSTS Stag SANE} 9924) 15090
39008 IS 5878S 29179 oar jas SOU 38538 1800 $6180 S513 Sree bazek PRE TOE 38500 Femmr 99546 74590
ss AS deus mets ae ne ie aa fm epee tte cence txts see
SS  a2147 17127 01682 30774 04970 33300 O56 635 Soeoe ances fesse $c05s Seats 34585 tacmm S7gs SENS S4sze
‘VS96R 18986 31874 52249 D085 20365 3a iat 58268 75739 2479 29610 03235 51050 15855 $6528 OB1IS 616s 32854 THOS
01983 38093 $9960 91307 99654 74279 $0145 5: 11370 50485 40252 S2H4O QUSLE 99258 9927 33073 BeanD 29933 Gosze Grass
saa vet mam amma ema ay wang em ome sa
eg aH i aaee E  dete seat te Ue Yn mee maa ny aes oe 9 ee exe ane
22241 41501 07993 99340 91044 67268 31088 1275) 74008 33773 ‘33676 20333 17622 93718 $7253 097 2 9 45691
11906 20043 HO4tS 44425 31752 54831 85591 62297 28797 14332 01383 85677 96572 16401 31379 83519 exe assay
SGGz sv, ne ee ance ee rn ah ae ee deg so aes own 39 sn sonia
7 iam ie V4360 12435 33636 63996 Do4ze Got Geatd D8s0R $6863 Sasa fees cian asp7e green ass 13x23
40597 4atee 29433 98278 22543 16155. 2107 22066 6190 99803 6439 94235 48360 62912 S708) $9708
GHEY sin os $9880 79667 66256 72797 67117 44699 73690 79726 96492 7431 Booms Shee
‘72064 2102 82973 02638 00302 79476 72656 8400) '%6222 20006 95660 $2690 01190 05588 76651 6461 11987 30756
i227 Sse2t iat Hon 02600 45564 72h44 71044 49370 96826 12436 21393 20472 19499. 404
8B 44763 56504 13993 48238 92483 09497 66058 36651 37927 BS HB az ees ma358 5
pea gag ae ae 64099 46305 49677 76215 66950 30728 Tos 47003 TaOKy i id 0548 95128
01800 39913 57130 84410 47637 91369 51830 43336 51997 91901 476 5038 Shee Sate 7 Janno arad 36995 S379
I An, Ue Ges ADs aes oe BPR th SE ah Sa A
Q —baoss 99172 GATI 39168 A2OL2 10447 45993 DEBe4 Sones S7684 2142 so9n2 92106 62859 39755 42550. 9103 712 78632
12648 27948 ie 1995 66815 34015 43081 27350 306 agsig ‘74802 $9354 91219 26293 18112 93531 ar itn Tae 18682
6254 87661 G618t 68609 54626 $2428 75051 27538 SEs eek SESS TURE esto Meso ae Be Saas satis
69682 19109 a 94626 09299 10649 55408734371 iS $4920 ‘TOOSS 98685 10244 11764 21982 73983 BH
October 10 — 61936 6663 13010 4002 50139 30769 13048 61407 pit gosto
$5125 Geaab [dace Toot gynze Seted das7e 43108. 96002 08 34552 76373 40928 93696 97711 15818 31006 61263 05676 07460
$5103 Seats Sout0 32635 42986 40981 91750 27431 O514? 19950, 45253 $6947 42417 28778 14936 94099 90775 42008 46675 62770
95402 51746 98184 38830 35390 00066 82770 42323 28778 83574 ay BH toe dase Bus Sot HH bid HH 92302
‘TORI 94510. STILE 64366 29040 43278 69072 22009 a9455 61423 20 3903 5232 2a
eee ee Tee ee usage aa nee iso wee. sem ese
‘TT GRU Heas ite ise Hake Howat Wass Seat doesk $3 Tae cas rns suis Tem. 9436 eams
37208 22741 41946 74109 40210 76617 52317 50643 33043 31433 47833 15234 Sits soay 7339 4626
@o1st 92927 85150 1813 47667 66078 03628 140 03 ‘99957 $459) 21688 64216 85938 51742 12898 O9TIT 61504 13946
2 Se Ee me ¢ ua Se San fae gt sis seit 01072 31679 bo96i 34029 56463 09394 11939 StTI7 64796 57452
23677 64950 97061 43088 20143 Sane 90330 78391 38518 Sonay ares C7537 2098 $9222 24060 Sem02 oscos 8136
ESE S02 SOU GSS ARAL SG MGS HR sR RUE Ga eee et at

5653
Sonny assy Wows bets 28383 Suen Ses
37499 50362 44171 12493 57370 T7691 aoe Err] 313 Bass

Source: Statistics with Applications to the Biological and Health Sciences. R. D, Remington and M. A. Schork, 1970.

C-2


Model WAP - Container: Page 4 of 15
3. Drum Storage Tolerance Limits

The storage process is limited by the amount of space available for
holding drums and the spill containment capacity of the area. The type of
storage drum selected to hold the spent trichloroethylene is compatible with
the waste and approved by the Department of Transportation (49 CFR 172.101).
These drums are not affected by the concentration of trichloroethylene in the
waste.


@-3

FIGURE 1, RECHARACTERIZATION DECISION CHART

Weight

Probability

Product

Restricted Waste Combined
in Shipment

Actual (Max.)

Process Design Limitations

Variability of Waste
Composition

Chemical/Physical Instability
of Waste
1

Generator's Performance
History

TOTAL ACTUAL (MAXIMUM)
Weight = 1 to 5 with 5 being the most important

Probability = 0 to 4 with 4 being the most probable

TOTAL acTUAL
ween nee eens x 100=X

TOTAL MAXIMUM



Model WAP - Incineration: Page 10 of 20

Waste Shipment Arrives
Compare Shipment
Externally to
Its Manifest p— Discrepancy
Visually Inspect. y
Shipment
pen Contact
i Generator
‘Sample Waste
y
Analyze Waste for
Key Parameters
Evaluate Analytical Data Reject
Waste
Shipment
Discrepancy
Y
Contact jp!
Generator
Recharacterize
Waste
Evaluate Analytical Data

Accept Waste
Shipment

Figure 2, Shipment screening procedures.


Model WAP - Chemical Treatment: Page 11 of 20

5. Waste Sampling and Analysis

Sampling

Table 2 lists representative sampling techniques selected for each waste
we plan to manage. Specific waste streams are listed because their means of
containment varies from one generator to another.

The sampling procedures were developed by first identifying the wastes‘
physical/chemical properties and means of containment, e.g., tanker truck. We
selected the appropriate representative sampling techniques, sampling devices,
and sample containers following a review of “Test Methods for Evaluating Solid
Waste" (SW-846). Since the equipment selected is listed for handling
materials of the same physical forms as our wastes, we believe that the
equipment is suitable.

We reviewed the scientific literature and work history volunteered by the
generators to identify any needs for special waste handling during sampling.
Such information helps protect our personnel and keeps our samples
representative.

We will use simple random sampling for wastes arriving in 55-gallon
drums. These wastes are homogeneous and can be grab sampled at mid-level in
the drum through the bung opening. Simple random sampling entails using a
random numbers table to select drums to sample [see Appendix C of this
manual]. The number of drums sampled is based on the American Society for
Testing and Materials (ASTM) cube root equation for barrels [see Appendix D of
this manual].

Tanker trucks will be sampled through access ports in the tanks. Since
our access is limited to ports, which may limit the representativeness of the
sample, we will take samples at three discrete vertical depths to provide the
best representation of waste possible.

We sample closed-bed trucks through access ports in the trailer. A
vertical sample that covers the depth of the bed is taken. Thus, our access
is limited and the representativeness of the waste sample may also be limited.

The sampling approaches described above pertain to characterization and
recharacterization sampling as well as unscheduled sampling of the wastes.

Quality assurance and quality control procedures for sampling wastes are
described in the appendix.

Analysis

Table 3 identifies the parameters and their analytical methods chosen to
characterize wastes periodically as well as a subset of key parameters chosen
to screen the wastes in each shipment. Table 3 also provides our rationale


Jete=t9r0 WO6T + SOLLO OMIZMNYE INOONIZAOD ‘5°

73

FIGURE 2.

EXAMPLE RECHARACTERIZATION DECISION CHART

Weight Probability Product
0 1 2 3 4 Actual (Max.)

Restricted Waste Combined
in Shipment 5 XxX 10 (20)
Process Design Limitations 5 Xx 5 (20)
Variability of Waste
Composition 3 Xx 9 (12)
Chemical/Physical Instability
of Waste 2 X Q ( 8)
Generator's Performance
History 2 Xx 8 ( 8)
TOTAL ACTUAL (MAXIMUM) 32_(68)

Weight = 1 to 5 with 5 being the most important

Probability = 0 to 4 with 4 being the most probable

TOTAL ACTUAL
ene e none ee ee x 100 = xX

TOTAL MAXIMUM

32
-- x 100 = 47

"
>

{As seen in the table on page E-2, the value of "47" falls within the
“25 to 50" range; therefore, 25% of the number of shipments would be

sa cbanaatanigad Auninn tha vaar 7



Model WAP - Impoundment: Page 1 of 16

MODEL WASTE ANALYSIS PLAN
SURFACE IMPOUNDMENT

1. Facility Description

The Jones Company manufactures automobile parts. One area of our
manufacturing involves electroplating. Our primary electroplating process is
segregated cadmium, which uses the metals cadmium and chromium. The spent
plating/coating solution and rinse water generated by this process are sent to
our wastewater treatment plant, where chromium and cadmium are precipitated
out of solution as a sludge. Cyanide is destroyed to a negligible complexed
concentration. This sludge category is designated RCRA toxic due to its
potential to contain cadmium, chromium, and complexed cyanide.

The wastewater treatment sludge is transferred to the onsite surface
impoundment for storage and some dewatering. Any wastewater that separates
from the sludges is decanted and piped to the wastewater treatment plant. The
impoundment usually reaches sludge containment capacity after 4 months of
normal operation. As the impoundment approaches capacity, the sludge is
removed and transported to an offsite hazardous waste management facility.

The surface impoundment was designed specifically to store and partially
dewater the toxic wastewater treatment sludges from the electroplating
process. It is equipped with a butyl rubber liner that was selected because
it is compatible with the electroplating sludges. All other materials of
construction of the impoundment were also selected to be compatible with the
sludge. Another chapter of this Part 8 application provides a detailed
description of the impoundment design.

The Jones Company is requesting a RCRA surface impoundment storage permit
for wastewater treatment sludges generated by the electroplating process. The
impoundment would be permitted to hold only these sludges.


Model WAP - Incineration: Page 7 of 20

14. Other Inorganic Components (Indicate percent by weight or mg/L) Test Methc

15. Organic Chloride Test Method

16. Organic Components (Indicate percent by weight or mg/L and if a
designated Appendix VIII POHC) Test Method

I certify the accuracy of this data and the representativeness of the

waste sample.

Signature and Title

Date

Figure 1. Waste characterization form (continued).


TABLE 1. CHARACTERISTICS OF MOIST FILTER CAKE FROM WASTEWATER TREATMENT PLANT!
RCRAZ Associated Physical
Number Hazard State Chemical Composition?
Koo2, Hexavalent chromium, Solid, single-layer Total chromium: 50 to 200 ppm
K003, lead (toxic)
Kuo4 Lead: 20 to 70 ppm
Water: 55 to 65% by weight

pH: 9.7 to 11.0
Trichloroethylene: Not detectable

Ethyl benzene: Not detectable

Management of the filter cake falls under Process Code $03, storage in waste piles.
2These streams are listed in 40 CFR 261.32.
3Refers to composition of filter cake as it leaves vacuum filtration unit.

Blld B3S2M - d¥M LaPOW

ST 30 ¢ abed


(5) For off-site facilities, the waste analyses that hazardous waste
generators have agreed to supply.

(6) Where applicable, the methods which will be used to meet the
additional waste analysis requirements for specific waste management
methods as specified in §264.17 and 264.341.

(c) For off-site facilities, the waste analysis plan required in
paragraph (b) of this section must also specify the 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 identity of
the waste designated on the accompanying manifest or shipping paper. At
a minimum, the plan must describe:

(1) The procedures which will be used to determine the identity of
each movement of waste managed at the facility; and

(2) The sampling method which will be used to obtain a
representative sample of the waste to be identified, if the
identification method includes sampling."

A-2


Model WAP - Land Treatment Page 5 of 16
3. Land Treatment Process Tolerance Limits

Tolerance limits represent those characteristics of a waste or waste
mixture that a management process, e.g., land treatment, can handle within the
facility's permit conditions. For this land treatment facility, the process
is limited in that we will be permitted to treat only those wastes with
characteristics designated in the permit, i.e., DAF float and API sludge. We
plan to apply these wastes separately to different land treatment plots.

A treatment demonstration will be conducted to prove that each waste can
be land treated at the proposed facility without pretreatment. The design and
management parameters for the proposed land treatment facility will be
established in the permit based on this demonstration. Because the
demonstration will be made using waste typical for the Refinery Company, the
waste stream boundary conditions, as defined in Table 2, can also serve as the
tolerance limits. The design and management conditions employed to
successfully manage these wastes at the land treatment facility are defined in
the facility Operating Plan of this Part B application. Any deviation from
these typical waste characteristics would require a modification to the
Operating Plan.

The primary boundary condition parameters that can also serve as
tolerance limits are--

. pH values (Note: The pH of the waste (2.5-4) is not favorable
regarding mobility; the permit conditions will require liming to
raise the pH),

. electrical conductivity to estimate the soluble salts that may limit
treatment efficiency, and

water content and metals and organics concentrations to assure that
the appropriate application rate is selected based on constituent
concentrations that do not hinder treatment performance.

Numerical values for these parameters are found in Section 2.


Waste Sampling, Analysis, and Quality Assurance/Quality Control Procedures

How will the wastes be sampled to
ensure representativeness of
samples tested?

What specific test methods will be
used to measure each parameter?

Since only liquid wastes are to
be accepted, drums will be sampled
using a Coliwasa device.

Drums will be sampled depending on
the number of drums in each lot
received. The number of drums
sampled will be based on the
cubed root equation. [See
Appendices C and D of this manual
for further information. ]

If out of specification drums are
found, all remaining drums in that
shipment will be sampled prior to
acceptance.

Each tank truck will be sampled
using a Coliwasa if a suitable
sampling port is available. If
such a port is unavailable, the
waste will be pumped into a
holding tank and a composite
sample collected during pumping.

Heat of combustion - ASTM! 0240
Viscosity - ASTM 01824
Water content - ASTM D95
Ash Content - APHA2 209
Reactivity - SW-8463 Section 2.1.3
Ignitability - SW-846 1010/1020
Corrosivity - SW-846 1110 and/or 9040
EP metals - SW-846

Arsenic - 7060

Barium - 7081

Cadmium - 7131

Chromium (VI) - 7195

Lead - 7421

Mercury - 7470

Selenium - 7740

Silver - 7761
Major inorganic constituents - SW-846

6010

lasTM American Society for Testing and Materials.

2APHA American Public Health Association

of Water and Wastewater 1980.

Standard Methods for the Examination

SSW-846 est Methods for Evaluating Solid Waste" July 1982.


Model WAP - Waste Pile: Page 4 of 15
3. Waste Pile Tolerance Limits

The waste piles have the following limitations:

. The volume of filter cake in the waste pile must not exceed the
design capacity in order to prevent spills.

. The waste pile should not receive any filter cake that contains
greater than 70 percent water, so as to prevent the generation of
liquids.

. The filter cake should not be waste piled if its pH falls outside
the 9.0 to 12.0 range because this could potentially damage the
liner.

. The waste pile should not receive any wastes that are incompatible
with the filter cake or waste pile materials of construction (e.g.,
the PVC membrane liner) such as the trichloroethylene and ethy]
benzene solvents used onsite. This avoids reactions that may lead
to contamination of the area.

These tolerance limits represent those qualitative and quantitative waste
characteristics that the waste pile structures can manage within the RCRA
permit conditions.


TABLE 3. (continued)

Detection Limit

Stream Parameters Analytical Methods! (mg/L) Rationale for Parameters
Lead AA Methods 3010/7420 0.1 Toxic parameter; reflects

(SW-846) presence of filter cake

constituents.
pH pl Meter Method 9940 - Assure effective waste-
(SW-846) water treatment.

Trichloroethylene GC Method 8010 1.2 X 19-4 Identify the presence of

(SW-846 ) liner-damaging organics.

Ethyl benzene GC/MS Method 8240 7.2 X 1073 Identify the presence of

(SW-846) liner-damaging organics.

1ASTM - Anerican Society for Testing and Materials.
SW-846, "Test Methods for Evaluating Solid Waste," July 1982.
2annual waste recharacterization is planned.

3sump checked weekly for leachate collection. Will analyze as necessary.

SBLtd BFSEM - dYM LEPOW

ST $0 OT abeg


3, PREPARING A WASTE ANALYSIS PLAN

3.1 OBJECTIVE AND PURPOSE OF PLAN

The objective of a waste analysis plan is to describe the procedures that
will be undertaken to obtain sufficient waste information to operate a
hazardous waste management facility in accordance with its permit (i.e., to
ensure that wastes accepted by the facility fall within the scope of the
facility's permit, and that the process performance standards are met). The
waste analysis plan establishes the hazardous waste sampling and analysis
procedures that will be routinely conducted as a requirement of the RCRA
permit. If the plan is followed properly, any waste-related discrepancies
with the permitted management activities will be identified before waste
management begins. These objectives are the same for both onsite and offsite
facilities. However, the Agency believes that a waste generator owned and
operated facility will tend to know more about the waste generation process
than would a facility not owned and operated by the waste's generator. Thus,
offsite facilities are required by the regulations to conduct more frequent
checks on wastes than onsite facilities.

A waste analysis plan should demonstrate to EPA or State permitting
officials that the facility owner/operator knows what information is needed to
Operate the facility properly and has in place a program to gather the
necessary information. Once the plan is approved, it will serve as an
operating plan for waste sampling and analysis.

3.2 CONTENT AND ORGANIZATION

The RCRA regulations do not require a specific format for the waste
analysis plan. For ease of review, however, the plan should be organized to
present the reviewer with the required information in a logical manner.
Applicants may thus want to organize the application in such a manner that the
description of the facility or process to be permitted is clearly identified.
Sufficiently detailed information will be needed by the permit application
reviewer to judge the degree to which the plan addresses the following
questions.

I. What are the specific wastes or types of wastes that will be managed
within each process?

II. What are the waste-associated properties that are of concern in ensuring
safe and effective management (e.g., kcal/g (Btu) content, % water)?

III. What are the specific waste parameters that have to be quantified in
order to satisfy the data needs?

IV. How will the necessary data be obtained, including what sampling and
analysis procedures, and what attendant quality control/quality assurance
Procedures are to be carried out by the permitee?


Model WAP - Incineration: Page6 of 20
8. Total Organic Carbon (ppm) Test Method
9. Heating Value (kcal/g.) Test Method
10. Ash Content (percent) Test Method
ll. Corrosive Yes No Test Method
12. Ignitable Yes No Flash Point °C oF
Test Method
13, Reactive Yes No Test Method

Description of Results

Figure 1. Waste characterization form (continued).


TABLE 2.

FILTER CAKE SAMPLING INFORMATION

Stream

(and Containment Device)

Sampling Method

Rationale for Selection
of Sampling Technique

Comments

1.

2.

Moist filter cake
from wastewater
treatment plant
(Temporary sludge
storage container at
vacuum filter area)

Waste pile leachate,
homogeneous liquid
(Sump)

One grab sample
with trier (SW-846,
Section 1.2.1.5)

One grab sample with
Coliwasa or weighted
bottle. Sample near
bottom of sump.
(SW-846, Section
1.2.1.1).

Grab sample
preferred in order
to avoid dilution
by compositing.

Homogeneity of

liquid requires

only simple random
sampling. If there
is precipitation

of any metal,

highest concentration
will occur near
bottom.

Wear rubber gloves, apron,
shoes, mask, and breathing
apparatus.

Use linear polyethylene
sample container.

Toxic.

Do not collect sample
during rainfall.

Put in linear
polyethylene container.
Potentially toxic.

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ST 40 g abed


Model WAP - Incineration: Page 2 of 20
2. Identification of Wastes to be Incinerated

The Controlled Combustion Company plans to incinerate distillation
recovery bottoms from spent methylene chloride, trichloroethylene, and acetone
in accordance with the RCRA permit. Other wastes may be incinerated in the
future as long as the heats of combustion of each organic constituent in each
waste feed are greater than that of methylene chloride (POHC), i.e., they can
be burned more efficiently. Heats of combustion must be greater in order to
assure that 99.99% of the constituents are destroyed and removed as was
demonstrated in the trial burns with methylene chloride. The ash content,
chloride content, viscosity, and water content of each waste feed must be less
than that of the trial burn feed. Any waste feeds that do not meet these
conditions are restricted from incineration.

Table 1 contains the pertinent characteristics of each hazardous waste to
be incinerated. Our staff sampled and analyzed each of the wastes to provide
the initial characterization. They visited each generator's site and
collected samples three times at 2-week intervals. Table 1 reflects the
analytical results of those sample analyses. (Quality assurance and quality
control programs for sampling and analysis are described in Appendix I.) Each
generator allowed us to review their waste analysis data over past years which
also agreed with our test results. This initial characterization served to
establish that each of the wastes fell into one of the waste categories
intended for incineration. Figure 1 is the waste characterization form
completed for each waste.

Based on our waste analyses and discussions with generators about the
consistency of their wastes, we have selected waste stream boundary conditions
of + 15 percent of the limits provided in Table 1. These boundary conditions
wilT alert us to any untypical wastes arriving at the facility that may affect
incinerator performance. We do not anticipate that the waste characteristics
will fall outside this range. If they do, we will follow the contingency
procedures described in Section 4, “Parameters to be Monitored."


TABLE 1. WASTE CHARACTERISTICS

Stream! »2

Basis for
Hazard

Physical
Properties

Chemical
Composition

1. API Separator
Sludge (RCRA
No.3 K051)

2. DAF Float
(RCRA No.3 K048)

Chromium, Lead
(Toxic)

Chromium, Lead
(Toxic)

Density: 1.35 to 1.65 g/ml

Density: 1.15 to 1.45 g/ml

Water: 48 to 58% by weight
Electrical conductivity:
1 to 3 mmhos/cm
pH: 2.5 to 4
Oil: 20 to 26% by volume
Solids: 21 to 27% by weight
Total organic carbon:
8,250 to 9,450
Total chromium: 2,000 to
4,000 mg/kg
Lead: 300 to 600 mg/kg
Additional 40 CFR 261
Appendix VIII constituents :4

Water: 77 to 87% by weight
Electrical conductivity:

2 to 4 mmhos/cm
pH: 2.5 to 4
Oil: 11 to 14% by volume
Solids: 2 to 8% by weight
Total organic carbon:

4,600 to 5,400
Total chromium: 25 to 100 mg/kg
Lead: 250 to 500 mg/kg
Additional 40 CFR 261
Appendix VIII constituents :4

lprocess code for both streams is D81.
2Both streams are single layer wastes.

3pefer to 40 CFR 261.32.

4information on specific Appendix VIII constituents was not available for this model.

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TABLE 1, CHARACTERISTICS OF ELECTROPLATING WASTEWATER TREATMENT PLANT SLUDGE

Basis for Hazard Physical
Classification State Process Code Chemical Composition2
Cadmium, hexaval gnt Sludge, single- soa4 Total and Amenable Cyanide:

chromium, nickel
complexed cyanide,
(reactive, toxic)

layer

Negligible
Cadmium: 17,000 to 22,000 ppm

Total Chromium: 50,000 to
62,000 ppm

Water: 70 to 80% by weight
pH: 7.0 to 9,5

Total Organic Carbon: Negligible

this sludge is assigned the RCRA Number F006 (40 CFR 261.31).

Refers to characteristics of the sludge as it leaves the impoundment.
Nickel is not used in this electroplating process.

4Refers to surface impoundment storage.

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Model WAP - Tank: Page 11 of 12

Collector jd Brow1 Sample No. Pe)
Place of Collection oie wnt (ape [tos atudae Tank?

unborn.

Date Sampled Darth 8/983 Time Sampled of “OS p.m-

Field Information ddrrpale Lkiew) 30 mun utes) unl’ Tank)

Figure A-1. Sample container label.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


TABLE 4-1, WASTE ANALYSIS PLAN CHECKLIST - GENERAL INFORMATION

Il.

Ill.

IV,

FACILTIY DESCRIPTION!

a. Are all hazardous waste management processes identified? yes no
b. Is sufficient information provided for each process to ~ ~~
confirm that the wastes can be properly managed at the
facility? yes ho

IDENTIFICATION OF WASTES TO BE MANAGED!

a. Is there a list of wastes or description of waste types yes no
to be permitted for each process?
b. Are the properties of the wastes that are pertinent

to the process provided? __yes __ no
. Physical properties, physical state, chemical
properties

. Ignitability, reactivity, and/or incompatability
. RCRA number and basis for RCRA hazard designation
. Documented waste data from a source other than one's
waste analyses, e.g., data from a similar process

c. Does the owner/operator identify any waste characteristic
limitations? yes no
. Boundary conditions of waste properties ~~
. Restricted wastes

PROCESS TOLERANCE LIMITS!

a. Does the plan address any process tolerance limits
(e.g., the minimum Btu/1b of waste or waste mixture that

can be incinerated to 99.99%)? __yes no
b. Is any process pretreatment specified in order to
meet tolerance limits? yes no

WASTE PARAMETERS TO BE MONITORED
40 CFR 264,13 (b)(1)

a. Does the plan include parameters that are measured
to characterize the waste? yes no

b. Are rationales provided for the parameters? __yes no
40 CFR 264.13 (a)(3) and (b)(4)

c. Does the owner/operator address recharacterizing
the waste? __yes __ no
. Potential for wastes restricted from the

facility being included by mistake

Process design limitations

Variability of waste composition

Chemical/physical instability of the waste

Prior history of the generator's performance

and reliability

16


Model WAP - Tank: Page 2 of 12

2. Identification of Sludge

Table 1 contains the sludge characteristics that need to be controlled
within specified limits if we are to operate the tank in compliance with
anticipated permit conditions. The sludge entering the tank is a flowable
liquid with approximately 5 percent solids. The water content of the sludge
is reduced by the time the tank is emptied, but the sludge (approximately 25
percent solids) still remains flowable.

The sludge characterization yielding the data in Table 1 was performed
by the analysts on our wastewater treatment plant staff. Our staff sampled
and analyzed the two sludge streams four times over the past 2 years of our
RCRA interim status operation. Sampling and analysis procedures followed
those described in this plan. Quality assurance and quality control
procedures used to characterize the sludge are described in the appendix of
this waste analysis plan.

Boundary conditions have been established to alert us that the sludge
generating process is not operating normally. The sludge entering the storage
tank must always have a water content greater than 90 percent. The sludge,
during its storage and upon leaving the tank, should never contain less than
70 percent water. Sludge pH should not be below 6.0. The water contents are
maintained to decrease the potential for reaction due to drying. Too acidic a
pH may also trigger sludge reaction. These boundary conditions were
established based on our experience with the sludge and its potential for
reacting.


Model WAP - Tank: Page 6 of 12

The wet sludge is the only waste pumped to the two tanks, and we have
made every design effort to ensure that no unpermitted wastes enter the tanks.
The wet sludge is pumped to the tank via a pipe isolated from other wastes.
The storage tanks are located in an area protected from sources that might
initiate reaction (see 40 CFR 264.190 to 264,199), Uther chapters of this
Part B application describe further how protection is accomplished.

Should the nitrocellulose process or its means of operation ever change,
we will determine if the sludge characteristics have changed. First, we will
obtain as much information about the process or operation change as our
personnel can provide, and we will take an unscheduled sample of the most
recent sludge placed in the tanks and analyze it according to EPA-approved
procedures. Any nonroutine parameters for constituents that we suspect are
present will also be measured. If we detect a change in the time required for
the sample to react, we will make every effort to identify the source of the
change in reactivity.

Our offsite hazardous waste management facility contractor will be
notified of any change in order to determine if the waste is still acceptable
at his or her facility. If the waste is not acceptable, we will make every
effort to find another facility to receive it. In the interim, the sludge
will remain stored onsite in a special holding tank.


Model WAP - Waste Pile: Page 7 of 15

5. Waste Sampling and Analysis
Sampling

Table 2 identifies the representative sampling information selected for
the filter cake waste and for leachate that may accumulate in the waste pile
sump.

It is practically impossible to sample all areas within each waste pile
because access for sampling is limited to within a few feet of the pile's
perimeter. Furthermore, sampling filter cake only around the perimeter would
not be completely representative of all of the filter cake piled. Also it is
important to know the moisture content, pH, and the potential presence of
liner-damaging organic solvents in the filter cake before it enters the waste
pile in order to prevent piling unacceptable wastes. Therefore, to solve the
representative sampling problem and to monitor the moisture content of the
waste, we sample the filter cake in the small temporary storage container at
the vacuum filter area. From this container, a grab sample of the filter cake
is taken randomly. We see no need to divide the temporary storage container
into a grid for random sampling. The container is small (less than 5 cubic
yards), limiting the potential for unusual variations in sample compositions.
A standard G1-CM polyvinyl chloride trier will be used in sampling. This trie
is nonreactive to the filter cake. Should any leachate be generated and
collected in the waste pile sump, we will take a grab sample with a Coliwasa
device or weighted bottle submerged near the hottom of the sump.
Representative sampling techniques such as simple random sampling cannot be
used in this case. All samples are stored in containers of nonreactive linear
polyethylene (LPE) as described in SW-846, Section 1.2.2, until analysis.

We reviewed the scientific literature and our previous work history to
identify any needs for special filter cake handling procedures. This helps us
to be certain that our employees are protected and that the waste samples
remain representative during storage.

The approach described above pertains to characterization and
recharacterization sampling as well as to unscheduled sampling of the filter
cake,

Quality assurance and quality control procedures for waste sampling are
described in Appendix II.

Analysis

The wastewater treatment filter cake has heen analytically characterized
to assure its manageability onsite. The approach to choosing characterization
parameters is described in Section 4 of this plan. Table 3 identifies the
test methods for each parameter along with the rationale for the selection of
each parameter. All of the analytical methods listed are EPA-approved.
Quality assurance and quality control procedures for waste analysis are
described in Appendix II. Our in-house wastewater treatment plant staff and
XYZ Labs performed the initial characterization of the filter cake, and they
will recharacterize it annually.


Model WAP - Chemical Treatment: Page 17 of 20

APPENDIX

Quality Assurance/Quality Control Program

Program Goal

Our program's goal is to assure that we acquire accurate and precise
information in order to assure that the wastes we treat exhibit those
chemical/physical characteristics for which our process is permitted. We
accomplish this by making sure that --

. the wastes are the permitted organic solids, oxidizers, or
metal-based wastes;

. waste incompatibilities are identified so that they are treated
in separate batches; and

. no restricted wastes are accepted.

We generate a great deal of data at our facility. Thus, we carry out our
quality assurance/quality control program to the fullest to assure that
accurate and precise data are obtained.

Sampling Program

Two of our employees have been trained to sample waste shipments. This
Part B application contains a chapter on their training program. The
employees' sampling skills are observed quarterly by our operations manager.
Sampling equipment is inspected for decontamination and operability before
each shipment is sampled, and each inspection is documented, noting any
problems and corrective actions taken.

Since we plan to handle more than one waste and one generator at the
facility, all sample containers will be labeled (see Figure A-1), and vital
sampling information will be logged in the field (see Figure A-2) before a
designated driver carries the samples (with an accompanying list of those
samples) to the laboratory.

Analysis Program

Our laboratory personnel have been trained to perform the analytical
methods outlined in Table 3. This Part B application contains a description
of their training program. The employees’ analytical skills are checked with
blanks or standards that are included in each set of analyses.


Model WAP - Chemical Treatment: Page 10 of 20

. waste characteristics that affect treatment process performance,

. the ignitability, reactivity, or incompatibility
of the wastes, and

. those parameters that best indicate waste characteristic changes.

Figure 2 also shows the analytical procedures followed when a shipment
screening indicates that a waste does not agree with the characteristics of
our permitted wastes. In such an event, we contact the generator and, if
agreed, we perform a complete recharacterization (with the generator's
approval), analyzing for all the parameters previously selected and any
additional parameters that may be necessary. Based on these results, we will
accept or reject the waste shipment.

If we are ever notified by one of our generators or suspect that the
waste generating process or its means of operation has changed, we will check
to see if the waste has changed in character. We will obtain as much
information about the change as the generator can provide and receive the
generator's approval to take an unscheduled sample and completely characterize
it. The characterization results will be evaluated to decide if the waste
complies with those waste characteristics that the treatment process is
permitted to handle. If it does not, we will reject the waste.


experiments can serve to establish compatibility between wastes of interest for
a given process. An 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 waste. Standard
compatibility tests have not been published to date by EPA.

40 CFR 264.341 addresses waste information required for incineration
facilities. Waste analysis plans for incineration facilities should include
routine analyses of waste parameters that are required as a result of a trial
burn. Trial burns (or comparable information) are required before such a
facility is permitted to operate. A “trial burn plan," required for these test
runs, includes analyzing each hazardous waste to be incinerated for certain
hazardous constitutents listed in 40 CFR 261, Appendix VIII (i.e., Principal
Organic Hazardous Constituents (POHCs). The analytical data serve as references
for measuring incineration performance. A comparison of hazardous waste
constitutent concentrations before incineration to the levels emitted from the
incinerator allows the calculation of the destruction and removal efficiency.
This information provides a measure of how efficiently the facility is
destroying and removing the hazardous waste. Additional information
requirements for specific hazardous waste management processes can be found in
Section 4, “Checklists for Writing or Reviewing Waste Analysis Plans." EPA's
“Guidance Manual for Hazardous Waste Incinerator Permits" (SW-966) also
elaborates on waste analyses and trial burns. However, to obtain information
on current EPA test methods, refer to SW-846.

Recharacterization

Since consistent performance in a hazardous waste management process is
important, hazardous wastes may need to be characterized periodically in more
detail than is involved in “fingerprint analysis” (analyzing for a few key
parameters). Such detailed analysis (recharactertzation) serves to detect any
changes in the concentrations of chemical constituents, the appearance of new
constituents, or variations in physical properties. An owner or operator must
recharacterize a waste when its generation source has changed in order to
identify any changes in waste characteristics. Such a change in generation
sources may result from engineering modifications or from malfunctions/changes
in operation, While the generator should notify the waste management facility
operator of such occurrences, the owner/operator, particularly for an offsite
facility, should set up a program to look for waste changes that may occur even
without any notification from the generator. Appendix E of this manual
presents a method for selecting the frequency of waste recharacterization. It
is aimed at offsite facilities but can be easily modified for use by onsite
facilities.

Shipment Screening

Offsite hazardous waste management facilities are required by 40 CFR
264.13 to comply with additional regulations that help minimize the potential
for incorrectly identified and unacceptable waste shipments being handled. The
offsite facility waste analysis plan must specify the waste analysis data that

IL


TABLE 2.

WASTE SAMPLING INFORMATION

Stream Containment Sampling Number of Samples
Numbers Device Technique Taken Comments References
1.,3., Tanker truck Access limited Grab samples at 1, Do not composite Technique: sw-846, 1
and 4, to tank ports. top, middle, and sample. Section 1.4.1
(single Grab sample bottom of tank. 2. Wear goggles, Device: SW-846,
layered with weighted rubber gloves, Section 1.2.1.5
sludges) bottle. Protective
clothing, respira-
tor, and face
shield.
3. Store sample away
from acids and
standing water.
4, TOXIC WASTE.
2. Closed bed Access limited One vertical core 1. Do not composite Technique: SW-846,
truck to ports. Grab sample through samples. Section 1.4.1
sample with bung across 2. Wear rubber gloves, Device: SW-846,
trier. depth of drum. apron, mask, and Section 1.2.1.5
breathing appartus.
3. Place sample in
linear polyethylene
container.
4, TOXIC WASTE.

quawzeeu, [eoLweYy - dyM Lepow

02 40 21 abeg


Model WAP - Tank: Page 10 of 12

APPENDIX

QUALITY ASSURANCE/QUALITY CONTROL PROGRAM

Program Goal

Our program's goal is to obtain accurate and precise sludge
characteristics data resulting from sampling and analysis and to maintain
up-to-date documentation of those data. The analytical results we obtain are
available --

. to identify any anomalies that could lead to the sludge
reacting or exploding,

. should a spill occur onsite, and

. so we can notify our offsite hazardous waste management facility
contractor if a process or operation change is reflected in the
Sludge characteristics.

The amount of data we need to attain our goal is minimal. We have no onsite
disposal; our offsite hazardous waste management facility analyzes the sludge
themselves, and reactivity is the only potential threat the sludge poses.
Therefore, determining sludge reactivity constitutes our primary reason for
analysis.

Sampling Program

The sludge is sampled by two people on our wastewater treatment plant
staff, They have been properly trained to use the sampling and analytical
equipment described in Section 5, and their training program is described in
another chapter of this application.

Employee sampling skills are observed annually by our environmental
manager during the removal of sludge from tanks. We feel this frequency is
sufficient since sampling with a dipper is simple and characterization
sampling routinely occurs semiannually. Once a sample is taken, the dipper is
decontaminated.

When samples are taken, our employee logs vital data in a field bonk,
labels the containers (see Figure A-1), and hand carries the samples to the
treatment plant laboratory where he or she begins analyzing them within 24
hours, Until analysis begins, the samples are stored in a designated area
free from any sources of reaction.


ACKNOWLEDGEMENTS

This manual was written by Marion Deerhake and Garrie Kingsbury of the
Research Triangle Institute under Contract Number 68-03-3149-1-3 from the
U.S. Environmental Protection Agency, Office of Solid Waste, Washington, D.C.
Or. Alan Senzel also assisted in collecting data and preparing the initial
draft report.

The authors wish to thank the Office of Solid Waste and EPA Regional
Offices for their participation in the preparation of this manual. In
particular, Mr. David Friedman, EPA Technical Project Monitor, has contributed
significantly throughout the development of this manual.

Critical reviews of the draft by representatives of industry and
government were especially helpful.

iv


APPENDIX E

A RANKING METHOD TO SELECT FREQUENCY OF WASTE RECHARACTERIZATION

This ranking method has been developed to aid in selecting the
appropriate frequency of waste recharacterization. It is intended primarily
for facilities that receive wastes from an offsite generator; however, it may
also be modified for use by onsite facilities. The method allows several
criteria to be taken into consideration in determining the frequency of
recharacterization. It should always be kept in mind that the objective of
recharacterization is to minimize the potential for any environmental
contamination at a facility by an unmanageable waste.

Figure 1 is a worksheet designed to rate wastes (especially those
generated offsite) on the basis of the likelihood that the character of the
waste will be drastically altered between shipments. A worksheet should be
prepared for each generator and their waste that is served hy the facility.
The sheet lists five criteria to be evaluated--

. The potential for restricted wastes to be combined in a waste
shipment that is normally permitted.

. The design limitations of the hazardous waste management process.
. The variability of a waste's composition among shipments.

. The likelihood of the waste undergoing changes that will affect
its manageability.

. The prior history of the waste generator performance and
reliability.

Weighting factors ranging from one to five can be assigned to each of
these criteria to assess its relative importance (5 is the most important).
That is, how significant of an impact would an episode that falls under one of
these criteria have on the facility's operation; for example, a generator
mistakenly sends a shipment of wastes containing oxidizing agents rather than
the contracted spent solvent. These weighting factors will vary depending
upon the hazardous waste process under consideration and the limitations of
the facility's permit. It is often helpful to prepare a list of reasons why
criterion has been assigned a given weight.

After assigning weights, probabilities ranging from 0 to 4 should be
chosen for each criterion indicating the likelihood of a given generator and
waste meeting that criterion. For example, what is the likelihood of a
contracted waste having a restricted waste mixed in its shipment. It is again
helpful to prepare a list of reasons why a given probability is selected.

E-1


Model WAP - Landfill: Page 18 of 21

APPENDIX
QUALITY ASSURANCE/QUALITY CONTROL PROGRAM

Goal_of Program

Our program's goal is to collect representative waste information in
order to assure that the wastes we handle can he safely retained by our
landfill. We accomplish this by making sure that --

. no restricted wastes are accepted,
. significant waste characteristics are verified, and

. waste incompatibilities are identified so those wastes
are disposed in isolated cells.

We generate a great deal of data at our facility, and we carry out our quality
assurance/quality control program to the fullest to assure that accurate and
precise data are obtained.

Sampling Program

Two of our personnel have been trained to sample waste shipments. This
Part B application contains a chapter on our training program. The employees‘
sampling skills are observed quarterly by our operations manager. Sampling
equipment is inspected for decontamination and operability before each
shipment is sampled. Each inspection is documented, noting any problems and
corrective actions taken.

Since many wastes and generators are dealt with at our facility, we label
all sample containers (see Figure A-1) and maintain a field log of vital
sampling information (see Figure A-2) before a designated driver carries the
samples (with an accompanying list of those samples) to the laboratory.

Analysis Program

Our lab personnel have been trained to perform the analytical methods
outlined in Table 3. (See the Part B Training Program section.) Their
analytical skills are checked with blanks or standards that are included with
each analysis.


Model WAP - Impoundment: Page 15 of 16

Collector ¥. Sa Arie Date Sampled Yas 1G3 Time 9:00a.m, Hours

Affiliation of Sampler =

Address th : -T

number street city state Zip
Telephone (000) ssx-/AIR Company Contact MY : Adam L
LABORATURY
SAMPLE COLLECTUR'S TYPE OF
NUMBER SAMPLE NO. SAMPLE 1 FIELD INFORMATION

7 y- dludge. Lenasi | Sample is typi
Mult.

Analysis Requested Jett thramisem) Amd fadmism)

f . p ’

bimcling writen."
ONLALY) AAA LA

LABORATORY SECTION2

Received by k Carr icte? Niele dade Ma 1 Date 4/24/23
ABC AZ

Analysis Required .Ja7aZ Chien isa Qontk poclomnissnn

1 Indicate whether sample is soil, sludge, etc.
2 Use back of page for additional information relative to sample location.

Special Handling and/or storase Uraans qaqa bea) tusdetetnd larstar praTeeliare
;
y

ONM. AN

PART II:

Figure [I[-2. Sampling analysis request.

Source: “Test Methods for Evaluating Solid Wastes" SW-346, July 1982.


APPENDIX A

40 CFR 264.13 GENERAL WASTE ANALYSIS

(a)(1) Before an owner or operator treats, stores, or disposes of
any hazardous waste, he must obtain a detailed chemical and physical
analysis of a representative sample of the waste. At a minimum, this
analysis must contain all the information which must be known to treat,
store, or dispose of the waste in accordance with the requirements of
this part or with the conditions of a permit issued under Part 270
and Part 124 of this chapter.

(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.

(3) The analysis must be repeated as necessary to ensure that it is
accurate and up to date. At a minimum, the analysis must be repeated:

(i) When the owner or operator is notified, or has reason to
helieve, that the process or operation generating the hazardous waste has
changed; and

(ii) For off-site facilities, when the results of the inspection
required in paragraph (a)(4) of this section indicate that the hazardous
waste received at the facility does not match the waste designated on the
accompanying manifest or shipping paper.

(4) The owner or operator of an offsite facility must inspect and,
if necessary, analyze each hazardous waste movement received at the
facility to determine whether it matches the identity of the waste
specified on the accompanying manifest or shipping paper.

(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 will keep this plan at the
facility. At a minimum, the plan must specify:

(1) The parameters for which each hazardous waste 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) The test methods which will be used to test for these
parameters;

(3) The sampling method which will be used to obtain a
representative sample of the waste to be analyzed. A representative
sample may be obtained using either:

(i) One of the sampling methods described in Appendix I of Part 261
of this chapter; or

(ii) An equivalent sampling method.

(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; and

A-1


Model WAP - Impoundment: Page 13 of 16

APPENDIX II

QUALITY ASSURANCE/QUALITY CONTROL PROGRAM

Program Goal

Qur program's goal is to acquire accurate and precise sludge information
that could affect our impoundment performance and to maintain an up-to-date
documentation of that information. The analytical data we obtain are
available--

. to prevent any damage to our impoundment structure by the sludge,

. to prevent our sludge from reacting with the impoundment structure
or any unexpected contents,

. should a spill occur onsite, and

. so we can notify our offsite hazardous waste management facility
contractor if a process or operation change is reflected in the
sludge characteristics.

The amount of data we need to obtain our goal is minimal. We have no onsite
disposal, and our offsite hazardous waste management facility also analyzes the
sludge. Therefore, we analyze the sludge for just five parameters to assure
that it meets those characteristics stated in the RCRA permit.

Sampling Program

Two people on our wastewater treatment plant staff serve as sludge
samplers. They have been properly trained to use the sampling equipment as
described in our Part B application's "Training Program." Their sampling
skills are observed annually by our environmental manager during the sampling
sessions; we feel this is a sufficient frequency since sampling routinely
occurs annually.

The weighted bottles used to sample sludge are decontaminated before
reuse, When samples are taken, the employee logs vital data in a field book,
labels the containers (see Figure II-1), and prepares a request for analysis
for those samples sent to ABC Labs (see Figure II-2). The employee drives the
samples back to the laboratory, properly stores the ABC Labs samples for pickup
(within 48 hours), and then proceeds to our lab to analyze a sample for cyanide
within 24 hours.


Model WAP - Landfill: Page 1 of 21

MODEL WASTE ANALYSIS PLAN
LANDFILL

1. Facility Description

The Land Disposal Company owns and operates a commercial hazardous waste
landfill facility, receiving wastes that are generated offsite. The facility
is operating under a RCRA interim status permit. Today, we are requesting a
permit to operate under current RCRA landfill standards (40 CFR 264 Subpart
N).

The landfill receives organic and inorganic solid and sludge wastes (no
liquid wastes); however, some of these wastes are restricted from disposal
(see Section 2). No wastes containing free liquids and no wastes containing
greater than 70 percent water are accepted. The acceptable wastes require no
treatment before disposal and are not stored onsite for greater than 90 days.

The landfill trenches are designed to contain these wastes safely, so no
exposure to the surrounding environment occurs. (Another portion of this Part
B permit application contains a detailed description of our facility's
design.) The trenches contain synthetic liners and leachate collection
systems whose materials were selected for their compatibility with the waste
types we handle. The natural clay formation underlying our site also has a
very low permeability to the wastes we receive (see the Facility Design and
Hydrogeology chapters).


Model WAP - Impoundment: Page 6 of 16

We chose to have our in-house wastewater treatment plant staff and ABC
Labs recharacterize the sludge annually. We prefer annual recharacter-
izations, because --

1) our years of operating data (available upon request) indicate the
sludge's hazardous constituents, chromium, cadmium, and a negligible
amount of complexed cyanide, are consistently present; only the
concentrations of chromium and cadmium and the volume of water may
vary in the sludge;

2) variations in heavy metal concentrations do not affect the
impoundment's performance;

3) the offsite hazardous waste management facility that accepts the
sludge analyzes it for their own purposes; and

4) there is a low probability of an unusual pH, or of a high
concentration of free and/or complexed cyanide, or of organics present
in the sludge.

If we are ever notified by one of our process area personnel that the
electroplating or wastewater treatment processes or operations have changed,
we check to see if the sludge characteristics have changed. We obtain as much
information about the change as our personnel can provide and then take an
unscheduled sample (according to our sampling procedures) from the wastewater
treatment plant.

The analysis procedures include forwarding a sample to a commercial lab,
ABC Labs, whom we have contracted to perform atomic absorption analyses for
chromium and cadmium in the sludge. We will inform ABC Labs of any known
sludge changes, and they will analyze a sample. ABC Labs will make every
effort to characterize the sludge should they detect a significant change in
cadmium or chromium concentration.

Our personnel will analyze sludge for free and complexed cyanide and they
will proceed to characterize the sludge more completely if a significant
increase in cyanide is detected. If the process change requires that we
analyze for any nonroutine parameters, sludge samples will be analyzed either
in-house or sent to ABC Labs.

We will notify our offsite hazardous waste management facility if any
changes occur, so the owner/operator can decide if the sludge is still
acceptable at the facility. If the waste is not acceptable, we will make
every effort to find another facility to receive the sludge. In the interim,
the sludge will remain stored onsite in transport tankers.


TABLE 4-1. (continued)

. Precision and accuracy of sampling procedures
. Rationale for sampling strategy selected

no

no

no

no

no

no

no

b. 2Are any samples taken by nonfacility people? yes
. Certification/documentation of representative ~~
sampling procedures
40 CFR 264.13 (b)(2)
c. Is waste analysis information provided? yes
. SW-846 test method and number if EPA-approved _—
. Detailed description and reference of any method
not EPA-approved
40 CFR 270.30 (e)
d. Does the plan include a QA/QC program for waste
sampling and analysis? yes
. Goals of program ~~
. Intended use and quantity of data to be gathered
. Acknowledgement that QA/QC will be followed as
described in specific test methods in SW-846.
e. Does the program include the performance evaluation
of trained sampling and analysis personnel? yes
. Frequency of evaluation and rationale ~~
. Documentation of evaluation
f. Is there a sample chain of custody procedure? yes
. Container labeling and seals —_
. Field logbook
. Receipt and logging of samples by lab personnel
. Chain of custody records
. Sample analysis request sheet
. Method of containment and preservation
. Confirmation sheet of sample delivery to lab
g- Does the internal or commercial lab document the lab
aspects of chain of custody? __yes of
. Numbering and documenting path of sample through
labs
. Destiny of remaining sample after analysis
. Documentation and forwarding of test results
to manager for filing
h. Is lab equipment inspected, maintained, and serviced
periodically? __yes

linclusion of this information is recommended 1) to make the application
easier to review, and 2) to allow the plan to stand alone for use as an

operating document.

This information is not required in a waste analysis

plan by regulation; chemical and physical analyses of the waste (40 CFR
270.14 (b)(2)) may be referenced from another Section of Part B.
2applies primarily to offsite facilities.

18


Model WAP - Container: Page 7 of 15

5. Waste Sampling and Analysis

Sampling

We sample one drum from each process area since 1) we generate such small
volumes of solvent, and 2) the solvent has a very low potential for varying in
composition within the process area. The specific drums to be sampled will be
selected using the simple random sampling method for containers as described
in “Test Methods for Evaluating Solid Wastes" (SW-846), Section 1.4.1. Simple
random sampling entails using the random numbers table to select drums to
sample. [See Appendices C and D of this manual.] All containers are the same
type of 55-gallon drum and are easily accessible for sampling through the
bung. Since the waste is homogeneous, a representative sample can be obtained
even though the sampler is limited to a single vertical area.

A glass Coliwasa device will be used to sample the spent solvent. Glass
is inert to chlorinated organics so analysis should be free of interference.
Samples will be stored in glass sample containers with teflon-lined Bakelite®
caps. These materials will not react with chlorinated organics.

The storage facility is designed to prevent any run-on of precipitation.
No direct precipitation should collect in our facility because it is sheltered
from the weather. However, if any liquid is collected in the storage sump, it
will be sampled by taking a Coliwasa grab sample and analyzed for the same
parameters as the drummed waste. If the sump liquid is hazardous as defined
in 40 CFR Part 261, it will be drummed, labeled, and stored along with the
other trichloroethylene waste.

Our sampling personnel will take special precautions when sampling any
wastes related to trichloroethylene because of its known toxicity. We
reviewed the scientific literature and our previous work history to identify
any needs for special handling procedures for the waste in order to protect
our personnel and keep the samples representative.

A summary of our sampling procedures is provided below. The approach
pertains to characterization as well as to unscheduled sampling of the spent
trichloroethylene.


TABLE 2.

REPRESENTATIVE SAMPLING TECHNIQUES

Stream Containment Device Sampling Technique Comments
A-1 Off-spec 55-gallon drum Simple random grab sample 1. Wear rubber gloves, safety
lead with thief (SW-846, goggles, and a self-
acetate! Section 1.2.1.4). Sample contained respirator.
cube root of total number 2. Clean hands carefully.
of containers per shipment .2 3. Toxic.
4. Use glass container with
_ teflon cap.
A-2 Pigment Closed-bed truck Vertical core sample through
filter two ports with trier 1. Wear rubber gloves, apron,
cake (SW-846, Section 1.2.1.5). shoes, mask, and breathing
apparatus.
2. Use linear polyethylene
R-1 Pigment Open-bed truck Simple random grab sample with sample container.
filter trier (SW-846, Section 1.2.1.5). 3. Toxic.
cake One sample per depth level.

LLtspuey - d¥M L8PpoW

TZ $0 21 abe


Model WAP - Tank: Page 12 of 12

Analysis Program

The two trained analysts are monitored by the environmental manager
during sludge analysis. The tests for measuring moisture, water, and pH
follow quality assurance/quality control procedures outlined in the methods
descriptions. The analytical data generated are documented and kept on file
in our environmental manager's office.

The lab equipment is inspected and serviced semiannually and as required
on a nonroutine basis. Any leftover sample is returned to the storage tank.


TABLE 4-2.

(continued)

PHYSICAL, CHEMICAL, AND BIOLOGICAL
TREATMENT (cont'd.)

3. Procedures to deter-
mine the compatibility of
a waste to process

structure (if not deter-
mined when structure was

first selected)? no

—es__
4. Procedures to deter-
mine the compatibility of
a waste to any raw mater-
ials or other wastes
potentially or previously
held in the process
structure? yes no
5. Procedures for
analyzing ignitable/
reactive wastes man-
aged in the process
structure? yes
LAND TREATMENT

Does the waste analysis plan include
the following:

1. Any additional waste
characteristic parameters
required as a result of an
EPA-approved land treatment
demonstration, e.g,,

Appendix VIII PHCs¢?

yes no

2. Sampling and analysis
Procedures for Item 1.
parameters? yes no
3. Procedures to deter-

mine the compatibility of

a waste to any raw mater-

ials or other wastes

potentially applied in a

given treatment zone? yes no

4, Procedures for ana-
lyzing ignitable/reactive
wastes to be treated? yes no
LANDFILL

Does the waste analysis plan include
procedures for the following where
appropriate:

1. Inspecting containers
for free liquids before
disposal and for handling
any unacceptable free
[liquids that may appear?

yes no
la. Inspecting containers
|for 90% volume by waste
Jand for handling any
|containers of waste that
Jare unacceptable by the
|facility that may appear?

yes__no

no |

|3. Determining the compat-
ibility of a waste to land-
fill liner(s) and leachate
collection system materials
|(if not determined when
materials were first
selected)?

yes__no

4. Determining the compat-
|ibility of a waste to any
jother wastes potentially
|disposed in the landfill?

yes no

5. Analyzing ignitable/
reactive wastes to be
|disposed?

yes__no
6. a) Sampling and ana-
lyzing leachate collected
| and b) managing the
leachate if hazardous?

yes___no

|
|
|
L

1 POHC - Principal Organic Hazardous

Constituent.

PHC - Principal Hazardous Constituent.

ran


Model WAP - Chemical Treatment: Page 19 of 20

Date 3/8/83

Sample Identification Number 3-2 Time “/7:0GQ.m:

1, Waste Identification

a. Waste Type Emauon Control dust eledlge proon Atconatary Lead ortt
b. Facility Waste Number 3 /

c. Suspected Composition J( with Cadmium, Lead, and
OL Ent
2. a. Waste Generator HeacdSmelZinrs Unc.d: Generation Process
Address ; Leack pmeltrng -
Aeadyille , USA Qe ‘on Contisl. dete

3. Purpose of Sampling
4. a. Sampling Point Location Janko Buck
b. Description

Taken ror PLOW Access pot mid. -_beved
5. a. Number of Samples Taken b. Volume per Sample
Ong One Ltn
6. Any Field Measurements Taken Yo

Parameter Measurement

7. Observations During Sampling Sample Applors) Fegpical

8. a. Sample Destination b. Means of Transport

Un-heuse Latroroliory Vari

Signature of Sampling Person: (-CAarZpr

Figure A-2. Field log.

Source: "Test Methods for Evaluating Solid Wastes," SW-846,


Model WAP - Land Treatment: Page 1 of 16

MODEL WASTE ANALYSIS PLAN
LAND TREATMENT

1. Facility Description

The Refining Company is a refiner of petroleum products. The treatment
of wastewater from the refining process generates two hazardous wastes,
dissolved air flotation (DAF) float and American Petroleum Institute (API)
Separator sludge. These wastes are listed as hazardous in 40 CFR Part 261
primarily because of their toxic levels of lead and hexavalent chromium;
however, toxic organics may also be present in the wastes.

The Refining Company desires to obtain a RCRA permit to land treat the
DAF float and API Separator sludge on its site. The land treatment process
involves spreading the wastes over a designated plot of land followed by
continued management. The soil and applied wastes are tilled to promote waste
degradation, transformation, and immobilization within a given depth of soil
(treatment zone) as defined in the permit. Only the DAF float and the API
Separator sludge generated by us onsite will be treated at the facility. No
nonhazardous waste streams will be land treated at this facility.

As required under RCRA, a land treatment demonstration will be performed
for EPA. The results of this demonstration will indicate successful
degradation, transformation, or immobilization of hazardous constituents in
the waste. Another chapter of this Part B application provides a detailed
description of the proposed treatment demonstration plan.

lthis waste analysis plan will not address the storage of hazardous waste
before land treatment. A real waste analysis plan would be required to do so,
but it is excluded here because a separate model plan has been prepared for a
storage facility.


EEE |


Model WAP - Container: Page 14 of 15

Collector 4 farhaatcd Sample No. 1g-]

Place of Collection Process Onon) B

Date Sampled Yoweandstr) 16,1993 Time Sampled 33 O0G@0.m-
Field Information damale Tadeen) ade mri Level uh drsser)

Figure II-1. Sample container label.

Source: “Test Methods for Evaluating Solid Waste" SW-846, July 1982.


Model WAP - Waste Pile: Page 11 of 15

SAMPLE APPENDIX I

XYZ LABORATORIES
Date: February 13, 1983
Sample Number: 1-1 Client: The Color Company

Collected: February 12, 1983
Received: February 12, 1983

Sample Process Area Test.
Number Stream Parameter Results Method
1-1 1. Total 100 ppm 3050/7190
chromium
Lead 50 ppm 3050/7420
Trichloroethylene Not 8010
Detectable
Ethyl benzene Not 8240
Detectable

lutest Methods for Evaluating Solid Waste," SW-846. July, 1982.
(Atomic Absorption Methods)

TT.
Signature of Certification: Jans Doe

Jane Noe, President



The products of each criterion weight and probability should be totaled
in the far right column of the worksheet along with the maximum total
possible. Incorporating these totals into the worksheet equation yields a
value of "X" that can be used in the following chart to determine the percent
of a generator's shipments that should be recharacterized each year.

% of number of shipments

Xx recharacterized over one year!
100 100%
75 - 100 75%
50 - 75 50%
25 - 50 25%
Q- 25 10%

This chart assumes that a facility receives at least one shipment of a given
waste each year from each generator. It is recommended that at least the
first shipment be recharacterized, so one can document waste characteristics
in case future shipments are not received.

Figure 2 is an example of how the worksheet would be completed.

lpi stribute sampling and analysis of shipments should be well-distributed
over the year.

E-3


Model WAP - Impoundment: Page 5 of 16

4, Waste Parameters to be Monitored

To select waste parameters, we 1) reviewed existing information on the
sludge properties such as 40 CFR 261, Appendix VII, and the BID on RCRA waste
F006, 2) noted what properties best indicate any change in a waste, and 3)
compared this information to our storage facility's design criteria so that we
can prevent any noncompliance with our RCRA permit conditions. These steps
included identifying the impoundment design and operation limitations
described in Section 3,

The sludge characteristics are only expected to change in the cadmium and
chromium concentrations, pH, and the percent volume of water; therefore, these
parameters will be monitored. The construction materials in the surface
impoundment are not sensitive to the concentration of the metals, and the
pressure on the liner is limited by the volume of impounded waste that is
controlled by decanting. Although these characteristics are not a common
threat to the structural integrity of the impoundment, they will be monitored
so that information is available in case the liner is ever damaged. We
monitor sludge pH because unusual values may indicate threatening sludge
anomalies. The sludge typically contains a negligible amount of complexed
cyanide with no free cyanide, but if our wastewater treatment plant were
upset, the potential may exist for cyanide to enter the impoundment.
Therefore, free and complex cyanides are monitored. No organics enter the
electroplating wastewater; however, total organic carbon will be monitored to
assure no liner damaging organics are present.

Thus, the keys to preventing any sludge reactions are to make sure that
1) the cyanide levels are low, 2) organics do not enter the wastewater, and
3) the sludge is in its customary form. The fact that the sludge is
transported to the impoundment through an isolated pipe precludes contamination
from other process wastes.

The surface impoundment is not decontaminated after it is emptied because
it will be refilled with the same type of sludge. Therefore, no
incompatibilities should exist, and tests for incompatibilities are not
conducted routinely. The transport vehicles are decontaminated by their owners
before receiving the sludge, and they are constructed of materials compatible
to the sludge, thus eliminating the potential for reactions,

We decided how often it was necessary to characterize our waste with
these tests by considering --

. the potential for other materials on our site to be placed in the
impoundment by mistake,

. the variability of our sludge's composition, and

. the instability of the waste.


Model WAP = Waste Pile: Page 12 of 15

Appendix II

Quality Assurance/Quality Control Program

Program Goal

The program's goal is to obtain accurate and precise waste analysis data
and maintain up-to-date documentation of those data. The analytical data we
obtain are available --

. to prevent any damage to the waste pile structure by the filter
cake,

. should a spill occur onsite, and

. so we can notify our offsite hazardous waste management facility
contractor if a process or operation change is reflected in the
filter cake characteristics.

The quantity of data we need to attain our goals is not major. We have no
onsite disposal, and our offsite hazardous waste management facility analyzes
the sludge also for their purposes.

Sampling Program

We sample and analyze the waste except that the analyses for chromium,
lead, trichloroethylene, and ethyl benzene are performed by XYZ Labs. Two
people on the wastewater treatment plant staff serve as both samplers and
analysts, and they have been properly trained to use the sampling and
analytical equipment described in Section 5. A description of their training
is found in the "Training Program" chapter of this Part B application. Their
sampling skills are observed annually by our environmental manager during the
sampling sessions. We believe this is a sufficient frequency since
characterization sampling routinely occurs annually.

Once a sample is taken, the trier is decontaminated. When samples are
taken, the employee logs vital data in a field book, labels the containers
(see Figure II-1), and hand carries them to a designated storage area until
XYZ Labs picks up the samples (within 24 hours). Our sampling employee
prepares a request for analysis for those samples sent offsite for analysis
(see Figure II-2) and then proceeds to analyze the filter cake (within 24
hours) for all remaining parameters at the wastewater treatment plant
laboratory.

Analysis Program

The Color Company's two trained analysts are monitored by the
environmental manager during filter cake analyses. The test methods used


Model WAP - Incineration: Page 16 of 20

A waste will be rejected if recharacterization analyses indicate it does
not fall within our permit specifications.

We have chosen to analyze discrete waste streams for the parameters in
Table 2 rather than analyze the waste feed. Since our waste
recharacterizations and shipment screenings involve the analysis of discrete
waste streams, we plan to use these test results to characterize the waste
feed rather than repeat those tests again. Waste feed properties will be
estimated based on the volumes of waste streams blended together. The waste
feed will be sampled and measured for heating value once a week to ensure that
it remains under the heating value maximum and, in turn, prevents damage to
the refractory materials.


Model WAP - Incineration: Page 19 of 20

Date $/a9 /g3

Sample Identification Number A -A-FT-/] Time 7:00 pm:

an

2.

5.

6.

Waste Identification

Purpose of Sampling
a. Sampling ot Location
b. Description Frmet ta tanker)
Tube samp "then phone the vertical Lepth
a. Number of Samples Taken b. Volume per Sample

Pre amet doe front tap pork one galton

Any Field Measurements Taken No

Parameter Measurement

Observations During Sampling
tamale apparscl pd escrbitch ui of tea) Caen tutather
a. Sample Destination b. Means of Transport

Onute Unbovatory Tack

Signature of Sampling Person: 74 - Mant

Figure I-2. Field log.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


Model WAP - Container: Page 1 of 15

MODEL WASTE ANALYSIS PLAN
CONTAINER STORAGE

1. Facility Description

The Aircraft Parts Manufacturing Company uses trichloroethylene (TCE) as
a cold cleaning solvent to remove grease, oil, and dirt from its products
before shipment. There are three principal manufacturing processes at the
company's plant, each of which generates one waste stream of spent solvent
degreaser consisting of trichloroethylene, oil, grease, and dirt. This spent
solvent degreaser represents the only hazardous waste generated onsite. This
waste is designated RCRA hazardous (F001) due to the toxicity of trichloro-
ethylene. It is stored in 55-gallon drums on a sheltered cement slab near the
loading dock until 45 to 50 drums have accumulated. The waste is shipped to a
commercial solvent reclamation facility at approximately 6-month intervals.

The Aircraft Parts Manufacturing Company is requesting a RCRA permit to
store spent trichloroethylene in drums at the designated area onsite described
above. The storage area will be permitted to hold only the spent
trichloroethylene.


Model WAP - Landfill: Page 11 of 21

5. Waste Sampling and Analysis

Sampling

Sampling procedures were developed by first identifying the wastes’
physical/chemical properties and means of containment. We selected the
appropriate representative sampling techniques and sampling devices from "Test
Methods for Evaluating Solid Wastes" (SW-846). Since the equipment selected
is listed to handle material of the same physical form as our waste, we assume
the equipment is suitable. Scientific literature and work histories
volunteered by the generators were reviewed to identify any needs for special
waste handling procedures to protect our personnel and keep the samples
representative. Quality assurance/quality control procedures are addressed in
the appendix.

Table 2 summarizes the representative sampling procedures selected for
each waste stream. Specific waste streams are listed because their means of
containment varies from one generator to another.

We use simple random sampling for wastes arriving in 55-gallon drums.
The drummed wastes listed in Table 2 are homogeneous and can be grab sampled
at mid-level in the drum. Simple random sampling entails using the random
numbers table to select drums to sample. [See Appendix C of this manual. ]
The number of drums sampled is based on the American Society for Testing and
Materials (ASTM) cube root equation for barrels. [See Appendix D of this
manual. ]

We sample closed-hed trucks through the access ports in the trailers. We
take a vertical sample that covers the depth of the bed. Since access is
limited, the representativeness of the waste sample is also limited.

We use random sampling for open-bed trucks where the sample areas are
based on a three-dimensional grid. The volume of the load is divided into
levels of imaginary cells based on the load length, width, and depth, and cell
numbers are assigned in sequence. We then use the random numbers table to
select the numbered cell to sample. [See Appendix C of this manual.] We next
take one sample from the randomly chosen cell. Only one sample per truck is
taken since the purpose of the sample is to verify that the waste is
consistent with the manifest and does not contain more than 70 percent water.

Table 2 also lists “leachate" as a waste stream. Should any leachate be
generated and collected in our trench sump, we obtain a grab sample near the
bottom of the leachate's depth. Since we are limited to vertical sampling in
the sump manhole, representative techniques are difficult to use.

We will take any unscheduled samples as described above, or we will
develop any special procedures that are necessary to obtain representative
samples on the generator's site.


What wastes can we not handle
and thus need to be prevented
from being accepted?

PCB-containing materials (>50 ppm).
Dioxin-containing materials

(>1 ppb chlorinated dioxins).
Chromium wastes (>5 ppm Cr).

Process Tolerance Limits

What waste properties do we need to
be concerned with to ensure that
the incinerator operates within the
permit envelope?

Waste Parameters to

Constituents in the incinerator
waste feed must have heats of
combustion of at least 4.44 kcal/g
(8,000 Btu/1b). This value is
based on the heating value of the
POHC used in the trial burn test.

Feed to the incinerator must be a
liquid with less than 85% water
to maintain burning efficiency.

Waste feed must have less than 5%
organochlorine and an ash content
of less than 40% to comply with
emissions standards.

be Monitored

What parameters will be measured to
ensure that the above properties are
maintained?

How will we avoid accepting wastes
which are outside the facility's
permit?

Heat of comhustion

Viscosity

Water content

Ash content

Organochlorine content

EP metals content

Compatibility with materials of
construction.

Compatibility with other wastes that
it may contact.

[Applicant should also include
rationale for selection of each
parameter. ]

Prior to agreeing to accept waste
from a generator, the client
will be required to submit the
following information about the
waste, including ranges for each
Property to be expected in routine
production:

Heat of combustion
Viscosity


TABLE 3. WASTE ANALYSIS INFORMATION

Stream Analytical Rationale for Detection
Number! Parameters? Methods3 Parameters Limit
(ug/L)

1., 2., 3., *Reactivity U.S. Gap Test or U.S. Identify reactive wastes -

4. Internal Ignition Test 4 for safe handling.

1. *Total and amenable SW-846, Method 9010 Verify no cyanide -
cyanide (Titration) reactivity.

1., 2., 3., “pH SW-846, Method 9040 Assure within pH -

4. (pH Meter) treatability range.

1., 2., 3., “Specific gravity ASTM D1429, Method C Waste verification. -

4, (Erlenmeyer Flask)

1., 2., 3., Arsenic SW-846, Method Identify unexpected 2

4. 7061 (AA) metals.

1l., 2., 3., Barium SW-846, Methods Identify unexpected 400

4. 3050/7080 (AA) metals.

1., 2., 3., Cadmium SW-846, Methods Measure treatment 5

4. 3050/7130(AA) performance.

1., 2., 3., Total chromium SW-846, Methods Measure treatment 50

4. 3050/7190(AA) performance.

1., 2., 3., Lead SW-846, Methods Measure treatment 100

4, 3050/7420(AA) performance.

uawjeail [221We4 - dyM LePOW

02 30 pT abeg


Model WAP - Landfill: Page 2 of 21

2. Identification of Wastes to he Landfilled

Table 1 lists the pertinent characteristics of each hazardous waste for
which we are requesting a RCRA permit, i.e., the wastes we currently manage at
the landfill facility. The analytical data on off-spec lead acetate were
provided by the generator. Our staff sampled and analyzed the two pigment
filter cake waste streams five times (once every 2 weeks), resulting in the
analytical data found in Table 1. The initial characterization data in Table
1 for the dust/sludge from secondary lead smelting were provided by the waste
generator. The Land Disposal Company has confidence in these data because of
the generator's work history and the knowledge that their process goal is to
recover as much of the metals as possible. Our staff sampled and analyzed the
bottom tar waste three times during a 6-week period to obtain the initial
characterization data given in Table 1. A detailed display of all the data
collected is presented in Appendix III. [This model does not include Appendix
III due to the lack of representative data. However, an actual plan could
include such data.] Quality assurance and quality control programs for
sampling and analysis are described in the appendix.

The Land Disposal Company conducted the initial characterization of each
waste to ensure that no restricted wastes were present and to verify the waste
composition, Compatibility among wastes was also considered.

Figure 1 is an example of the waste characterization form we complete for
each waste. All of the wastes currently managed are mutually compatible.
Therefore, we see no need to test routinely for compatibility.

Waste stream boundary conditions of + 10 percent of the waste
characteristic limits shown in Table 1 have been designated. These boundary
conditions have been set to identify anomalies in waste characteristics. This
helps alert us to any unusual properties that may require our attention. We
selected 10 percent after reviewing our waste analyses and analytical data
from each generator. The contingency procedures discussed in Section 4,
"Waste Parameters to be Monitored," will be followed if boundary conditions
are exceeded.

The Land Disposal Company restricts the following wastes from the site:

free liquids ignitable wastes

gaseous wastes reactive wastes
oxidizers corrosive wastes
cyanides radioactive wastes
sulfides polychlorinated biphenyls

The landfill trenches are not designed to retain these wastes chemically or
physically. We do have the capability of accepting certain incompatible
wastes. We would safely dispose of these incompatible wastes by isolating
them in clay cells within the trenches.


Model WAP - Landfill: Page 8 of 21
Waste Shipment Arrives
Compare Shipment
Externally to
Its Manifest Discrepancy
Visually Inspect A
Shi it
pmeny Contact
{ Generator
Sample Waste
Y
Analyze Waste for
Key Parameters
y
Evaluate Analytical Data Reject
Waste
Shipment
Discrepancy
~~
Contact
Generator
y
Recharacterize
Waste
Evaluate Analytical Data
y
Accept Waste << $< —_—________}

Shipment

Figure 2. Waste shipment screening procedures.



Model WAP - Tank: Page 1 of 12

MODEL WASTE ANALYSIS PLAN
TANK STORAGE

1, Facility Description

The Solid Fuel Company formulates nitrocellulose-based propellants. We
generate wastewaters originating from --

. cleaning of blending, packaging, and handling equipment and
storage facilities;

: wet milling of propellant castings;
. air pollution wet scrubber control devices; and
. loading, assembling, and packaging of ordnance.

These wastewaters are physically treated onsite in settling pits where they
produce a single-layer sludge which is a RCRA reactive hazardous waste due to
its nitrocellulose content.

The Solid Fuel Company requests a RCRA permit to store the wastewater
treatment sludges in two open concrete tanks onsite. The tanks were designed
specifically to contain the nitrocellulose-based sludge. We would accumulate
the sludge until the tanks reach capacity and then transport it to an offsite
hazardous waste management facility. The storage promotes sludge drying and
is cost-effective. The tanks must be managed in the following ways to assure
safe storage: 1) they will not be used for any waste that is incompatible
with the sludge, 2) the sludge moisture content will not be allowed to fall
below 70 percent, and 3) the tank will be protected from any sources that
might initiate reaction.

140 CFR 261.32 lists this waste as "K044 - wastewater treatment sludges from
the manufacturing and processing of explosives." This waste category can be
reactive due to one or more explosives industry products, nitrocellulose in
this case.


It is recommended that a waste analysis plan be organized based on these
four questions. The plan's organization should be keyed to the
decision/review process, presenting the logical approach and decision tree
used by the permit applicant in arriving at answers to each data need
question. It should be designed to lead the reviewer through the thought
process employed by the applicant.

Usually other portions of the RCRA permit application will contain an
indepth description of the facility and the processes to be permitted. Those
sections will establish the types and the characteristics of wastes to be
managed and any process constraints. The waste analysis plan should reference
these other sections of the application, and it is suggested that the
applicant summarize those points that are particularly germane to the plan in
order to assist the reviewer and user.

3.3 ABBREVIATED EXAMPLE PLAN

In order to illustrate how the above questions might be addressed ina
logical, easy to understand manner, an abbreviated example of portions of a
waste analysis plan follows. This example is not intended to represent an
actual facility plan. Examples of representative plans for various types of
facilities are presented in Appendix B.

The sections of the example plan that follow the Facility Description are
written from the perspective of an applicant and discuss areas that would have
to be addressed in any waste analysis plan.

Facility Description

An offsite facility requesting a RCRA permit for its hazardous waste
incinerator will be assumed in this example. The facility would receive
wastes in both drums and tank trucks and would store the waste in either the
receiving drums or in large blending tanks until sufficient waste was on-hand
for an incinerator run.

A permit is being requested for a facility which would be allowed to burn
liquid wastes containing up to 5 percent organochlorine content, as long as
the wastes accepted contain PCBs at <50 ppm, dioxin at <l ppb, or chromium at
<5 ppm.

Identification of Wastes to be Managed

Issues to be Addressed Response
What wastes do we want a permit Liquid wastes or wastes that can
to manage? be made pumpable by blending or
heating.


Model WAP - Container:

APPENDIX I

SMITH LABORATORIES

Page 10 of 15

Date: January 21, 1983
Sample Number: Drums 01-1 Client: Aircraft Parts Mfg. Co.
18-1 Address
30-1
Collected: January 18, 1983
Received: January 18, 1983
Sample Process
Drum Area
Number Stream Parameter Results Test Method
01-1 A Specific 1.38 asTuh
gravity
Flash point 75.2° C 10102
%Trichloroethylene 90% 80102
(by volume)
18-1 B Specific 1.34 astml
gravity
Flash point 79,4° C 10102
4Trichloroethylene 85% 80102
(by volume)
30-1 c Specific 1.36 astmi
gravity
Flash point 77.7° C 10102
%Trichloroethylene 87% 80102

(by volume)

l ASTM American Society for Testing and Materials
2 "Test Methods for Evaluating Solid Waste" SW-846 July 1982

Signature of Certification: fohee drasth
n Smith, President


TABLE 2. (continued)

Stream! Parameters2 Analytical Methods3 Rationale for Parameters
All streams *Flashpoint SW-846 1010 (Pensky- Waste verification. Identification
Martens Closed Cup) of ignitables for safe handling.
All streams Reactivity U.S. Gap Test or U.S. Identification of explosives for
Internal Ignition Test4 safe handling.
All streams *Organochloride content SW-846, Method 9020 Maintain compliance with chloride
(shipment analysis of (Microcoulometric emissions standards via hydrogen
B-1 is not performed.) Titration). chloride removal system.
All streams Volatile and semivolatile SW-846, Methods 8240 Identify any hazardous organic
organic constituents. and 8250, respectively constituents that are present to

(GC/MS; detection limits determine if Btu values exceed

vary based on constituent) methylene chloride's.
A-1, C-1 Methylene chloride SW-846, Method 8010 Verify toxic constituent. Monitor

(GC) destruction and removal.

A-2 Trichloroethylene SW-846, Method 8010 Verify toxic constituent. Monitor
(GC Detection Limit = destruction and removal.
0.02 ug/L)

B-1 Acetone SW-846, Method 8015 Verify ignitable constituent.
(GC Detection Limit =
1 ug/L)

lRecharacterization Frequency: A-1 and A-2 - semiannual; B-1 - annual; C-1 quarterly.

2asterisk denotes key parameters measured with each shipment.

3APHA - American Public Health Association's Standard Methods for the Examination of Water and Wastewater 1980.
ASTM - American Society for Testing and Materials.

SW-846 "Test Methods for Evaluating Solid Waste" July 1982.

4TAuthor's note: These explosivity tests are currently under development by the Bureau of Mines for EPA.]

UOLZeUBULDUT ~ dyM LapoW

02 40 ST abeg


TABLE 4-1. (continued)

d.

40

e.

40

f.

40

g.

Are there procedures in place should recharacterization
prove a waste is unacceptable by the facility? yes no

CFR 264.13 (b)(5)

2are any wastes analyzed outside the facility? yes no
. Documentation of analytical procedures and
representative sampling

CFR 264.13 (c)

2noes the plan include waste shipment screening
procedures? yes no
. Procedures to review shipment's manifest
. Procedures to inspect shipment visually
. Frequency and % of shipment inspected, sampled,
and/or analyzed annually
. Procedures when a shipment arrives that is
unacceptable by the facility
. Key parameters for shipment analysis of each waste
or waste type ( finger printing)

CFR 264.13 (a)(3)(i)

Are there procedures should the owner/operator be
notified or suspicious that the waste generation
process or operation has changed? __yes no
. Procedures to obtain information needed
. Sampling and analysis procedures
. Criteria to evaluate waste change information
. Procedures for handling wastes proven
unacceptable by the facility

WASTE SAMPLING, ANALYSIS, and QA/QC PROCEDURES

40

a.

CFR 264.13 (b)(3)

Noes the plan include representative waste sampling

procedures? yes no

. Sampling method number and reference

. Sampling device

. Description of any method not approved by EPA

. Statistically representative sampling technique
(simple, stratified, or systematic random sampling;
composite or grab sampling; subsampling)

. Practicality of statistically representative
sampling (physical barriers, alternative methods)
addressed

. Number of sampling sites

. Waste containment device when sampling

. Physical state(s)/layers of waste

17


the generator of the waste provides. It is important that the plan
describe the procedures to be taken by the facility owner/operator in order to
determine how well the generator's data represents the waste to be managed.

Since the owner/operator of the offsite facility is not able to monitor
waste generation operations daily, the exact waste characteristics of each
shipment will not be known. Hence, an offsite facility must, at a minimum,
visually inspect and compare the contents of each shipment to the accompanying
manifest to identify the waste. The shipment is sampled and analyzed only to
the extent necessary to verify that it meets permit waste specifications
(fingerprint analysis). An owner or operator must recharacterize a waste when
a shipment does not match the manifest description. Shipment screenings may
also be necessary for onsite facilities particularly when the facility
receives a variety of wastes. The level of screening to be required for an
onsite facility is a function of the facility operator's knowledge about the
generation process.

Typically, waste shipments are sampled and analyzed for a few key
chemical and physical parameters. These key parameters are selected from the
initial waste characterization parameters measured before the owner/operator
agrees to handle the generator's waste. The parameters should reflect
characteristics that substantiate the waste composition as described in the
RCRA permit. Criteria that one might consider when selecting key parameters
are:

. the need to identify restricted wastes,

. parameters representative of the incinerator's chemical/physical
design criteria and performance,

. the potential ignitability, reactivity, or incompatibility of the
wastes, and

. Parameters that best indicate changes in waste characteristics.

While fingerprint parameters are often a subset of characterization
parameters, this may not always be the case. For example, one may use
screening tests to detect constituents that are not normally present in the
waste even though the tests do not identify the specific contaminant. The
Agency does not currently have an approved set of test procedures for such
Purposes. However, reference might be made to "Test Methods for Evaluating
Solid Waste" (SW-846) and “Design and Development of a Hazardous Waste
Reactivity Testing Protocol" (EPA-600/52-84-057) for suggested fingerprint
analysis procedures.

Selecting a few key parameters for analysis of each shipment
("fingerprinting") expedites waste characterization, which is important because
of the time and labor involved in receiving shipments. The test methods for
these key parameters are based on the initial waste characterization test
methods which are described in "Test Methods for Evaluating Solid Waste"
(SW-846) and other EPA publications. Any changes in waste characteristics that
could affect the performance of the hazardous waste management process should
be detectable by conducting these tests.

12


1. INTRODUCTION TO MANUAL

The Resource Conservation and Recovery Act (RCRA) was passed by Congress
to assure the proper treatment, storage, and disposal of hazardous wastes. As
a result of this Act, RCRA permits are required for hazardous waste management
facilities. Such permits are issued to those management facilities that can
demonstrate an ability to safely and effectively manage specific hazardous
wastes or waste categories. The EPA document "Permit Applicants' Guidance
Manual for the General Facility Standards of 40 CFR 264" (SW-968) provides
general guidance on preparing the various sections of a RCRA Part B permit
application.

An important aspect of hazardous waste management is the process by which
the information needed to manage the wastes is obtained. One of the
requirements of the Federal regulations is that this process be set forth ina
waste analysis plan and submitted as part of the RCRA permit application. The
waste analysis plan should describe how one decides what information is
needed, the nature and extent of the information needed, and the method by
which the information will be gathered.

The purpose of this manual is to provide guidance to both permit
applicants and reviewers/writers on how to prepare and evaluate waste analysis
plans. This manual provides--

. an explanation of the RCRA regulations that require a
waste analysis plan,

. a discussion of the purpose and objectives of a waste
analysis plan and a recommended approach for preparing a
plan,

. checklists to assist the preparer/reviewer in
assuring that the analysis plan is complete, and

. example waste analysis plans for various hazardous
waste management scenarios.

By following the guidance in this manual, a permit applicant should be able to
develop a waste analysis plan that satisfies the intent of the regulations and
that can be reviewed easily by the permitting official.


Model WAP - Chemical Treatment: Page 7 of 20

4, Waste Parameters to be Monitored

Waste analysis parameters were selected after 1) reviewing existing
information on the waste properties, for example, 40 CFR 261 Appendix VII
(including a search for ignitability and reactivity), 2) noting what
Properties best indicate any change in a waste, and 3) comparing this
information to our treatment facility's design criteria and trial treatment
test results so that we can prevent any noncompliance with RCRA permit
conditions.

The treatment structure's materials of construction were chosen for their
compatibility to the specific waste categories listed in Section 2; therefore,
this aspect of compatibility is not a factor. Design information about the
treatment structure can be found in another chapter of this Part B
application,

Since the permit will be based on the type of waste the process can
treat, we chose waste analysis parameters based primarily on waste
characteristics and those properties that are indicative of treatment
performance. These include pH, specific gravity, EP toxic metals, total and
amenable cyanide, flash point, reactivity, phenol, and PAH. For those
nonhazardous constituents listed in Section 3 that retard the setting of
cement, we have chosen to conduct cement setting tests on small samples of
waste. Conducting tests to measure the specific constituents would be quite
lengthy and may not be accurate. Waste-to-waste compatibility tests will be
conducted also. Waste compatibility to treatment reagents and treatment
structures has already been demonstrated.

We plan to completely recharacterize the wastes periodically. This will
verify that the shipment screenings are correct and identify any waste changes
that cannot be verified by simple screening.

We selected the recharacterization frequencies by considering --

. the potential for restricted wastes to be combined in a shipment,
. the variability of the waste composition between shipments,
. the likelihood that a waste will undergo changes that would

alter its permitted characteristics, and
. the performance history and reliability of the waste generator.

Section 5, "Waste Sampling and Analysis," lists the analysis procedures,
provides a rationale for each analysis parameter selected, and identifies the
frequencies of waste recharacterization.

All incoming waste shipments will be screened following those steps
displayed in Figure 2. The screening procedures are based on our generators,
the wastes they plan to ship, and applicable RCRA regulations.


Model WAP - Incineration: Page 5 of 20

Date
1, Generator
a. Name
b. Address
c. EPA ID Number
2. Waste Identification
a. Facility Waste Number Sample Number

b. RCRA Waste Number
c. DOT Waste Number
d. Name of Waste

e. General Description of Waste Generation Process

3. Sampling
a. Date Sampled b. Sampling Method
c. Name and Affiliation of Sampler
d. Was sample taken during normal process operation? Yes No

If no explain:

4, Physical State at 21° C (70° F) Solid Sludge Liquid

5. Specific Gravity

6. Viscosity (Centipoise) Test Method

7. Water Content (percent) Test Method

Figure 1. Waste characterization form,


Model WAP - Impoundment: Page 12 of 16

APPENDIX I
ABC LABORATORIES
Date: October 1, 1983
Sample Number: 23-1

Collected: September 30, 1983
Received: October 1, 1983

Process Area Test
Stream Parameter Results Methods
Electroplating Total 50,000 ppm 3050/7190
Wastewater chromium

Treatment

Plant Sludge
Cadmium 17,000 ppm 3050/7130

lvTest Methods for Evaluating Solid Waste," SW-846, July 1982,
(Atomic Absorption Methods)

Signature of Certification: vo. 4 ohnarw
d

I. Johnson, Office Branch Manager


TABLE 4-3.

OPTIONAL ITEMS TO CONSIDER WHEN PREPARING A WASTE ANALYSIS PLAN

I, IDENTIFICATION OF WASTES TO BE
MANAGED

An identification number for a waste
that may indicate its generation
source

Known health and environmental effects
Any analytical data sheets on waste

Any existing documentation on the
waste's compatibility or
incompatibility

Certification of validity of any
waste data provided by a generator

II. WASTE PARAMETERS TO BE MONITORED

Screening procedures@

. Reference to reviewing shipment -
manifests for information
such as--

- Manifest document number | -

- Generator's name, address, and
EPA I.D. number |

- Each transporter's name and
EPA I.D. number

- The destination of each ship-
ment, i.e., HWMF, address, and| -
EPA I.D. number

- An alternative HWMF, address,
and EPA I.D. nuniber

- Quantity/volume of waste in

|
|
|
|
- DOT shipping name and number |
|
shipment

|

Il. WASTE PARAMETERS TO BE MONITORED
(cont 'd.)

Number and type of containers

Signed certification and date

+ Visual inspection of shipment

Number and type of containers
match manifest

Shipment labels/placards/marks,
ji.e., RCRA and DOT, match
manifest description

Presence of free liquids and
consistency with manifest
description

Irregularities with shipment,
e.g., leaks

Wastes restricted from the
facility that are visibly
present

Waste color's consistency with
the characterization form's
description

Consistency between the waste's
visible physical state and the
characterization form's
description

Acceptance/rejection procedures

Documentation of acceptance
when results of waste inspec-
tion and analysis agree with
waste characterization data

22


Model WAP - Chemical Treatment: Page 18 of 20

Collector 2. Coszew Sample No. 9-2
Place of Collection Jgméeer) Perk? acbistes 4 Orta).
Date Sampled Wayrch J, FR? Time Sampled //,96 @.m-

Field Information wdleryple Ladeta) fren thas’ pcctan feat tbh Aesek:
Mienyale jypeassd Lgpicak.
a

Figure A-1. Sample container label.

Source: "Test Methods for Evaluating Solid Wastes," SW-846, July 1982.


Total organic carbon - APHA 505

Major organic constituents - SW-846
8010-8150 (based on suspected
constituents)

PCB - SW-846 8080

Dioxin - SW-846 8280

Instability properties - Dupont DTA
[Method would be described in
an appendix]

What quality assurance/quality control Quarterly review of staff skills in

Procedures will be followed for sampling and analysis.
sampling and analysis? Maintaining a field tog of samples
taken.

Labeling samples.

Following SW-846 QA/QC procedures
for each test method.

Inspection and maintenance of
sampling and analytical equipment.

Documentation and filing of all
sampling and analysis information.

3.4 DISCUSSION OF THE PLAN INFORMATION NEEDS

Facility Description

Before the reviewer can evaluate the adequacy of the proposed testing, the
permit applicant needs to identify the waste management processes that operate
at the facility. Enough information is needed concerning what wastes can and
cannot be properly managed by their facility so that the application reviewer
can judge whether the testing proposed is adequate.

While this information will generally be exhaustively described and
discussed in other sections of the permit application, it would be useful to
include a summary of this information in the waste analysis plan since the plan
may later serve aS an operating manual during facility operation. In addition,
it is helpful to application reviewers to have a waste analysis plan that
stands alone.

Identification of Wastes to Be Managed

This section of the plan should include--

» . a list of the wastes or waste types that the applicant wants to be
“permitted to manage in each process operating at the facility,

. a list of any wastes known not to be manageable, and

. known waste properties which, if exhibited by the waste, would
preclude the waste's acceptance at the facility.


Model WAP - Chemical Treatment: Page 16 of 20

for selecting each parameter. All analyses will be performed in-house.
Quality assurance and quality control procedures for waste analysis are
described in the appendix.

The frequencies of recharacterization selected are also found in Table 3.
They were based on a ranking exercise that considers the issues addressed in
Section 4. [See Appendix E of this manual for an explanation of this
ranking exercise.] The details of the ranking exercise are not included since
they take the waste generators’ performance history into consideration.
However, the details are available upon request.

Should recharacterization analysis prove that the waste is not manageable
by our treatment process within the specified permit conditions, we will
reject it.


APPENDIX B

EXAMPLE WASTE ANALYSIS PLANS

The model waste analysis plans presented in this Appendix pertain to
hazardous waste management procedures for hypothetical facilities. The purpose
of including these examples in this manual is to demonstrate approaches to
Preparing complete waste analysis plans for each of the basic nazardous waste
management scenarios.

The model plans included here address the following hazardous waste
management practices:

Container storage Land treatment
Tank storage Incineration
Surface impoundment Chemical treatment
Waste pile Landfill.

Each case study has been kept as simple as possible in an effort to focus
on the necessary elements of the waste analysis plan.

On July 20, 1984, EPA proposed "a standard RCRA permit application form
for use by a select group of facilities whose only activity subject to RCRA
permitting consists of storing in above-ground tanks or containers hazardous
wastes that have been generated on-site." (49 FR 29524). This application
form was developed because certain types of storage facilities “present
regulatory control issues that are essentially identical." This proposed
application form is scheduled to be finalized by mid-1985. Some storage
facilities may not fit into this waste management classification or may be
located in a state that would not use the form. For these reasons, along with
the proposed status of the form, model waste analysis plans for container and
tank storage facilities that are based on existing regulations are included in
Appendix B.

The following tests are not addressed in the Appendix B model waste
analysis plans:

. waste management compliance monitoring (e.g., groundwater
monitoring, incinerator stack monitoring),

. waste management process operation monitoring (e.g., groundwater
monitoring, incinerator stack monitoring),

. pre-permit process performance analyses (e.g., trial burns, land
treatment demonstrations), and

. closure plan analyses.


Model WAP - Landfill: Page 21 of 21

Lab personnel document receipt of each sample. Waste samples are stored
until analysis based on their expected content. Screening samples are analyzed
as soon as possible to avoid delays in shipment processing. Characterization/
recharacterization samples are analyzed depending on their storage life.

Sample identification numbers are assigned to replicates analyzed. The quality
assurance/quality control procedures for analysis follow those outlined in each
test method of SW-846, "Test Methods for Evaluating Solid Waste," and other
EPA-approved methods. All test results are documented on the characterization
form shown in Figure 1 and are kept on file.

Analytical equipment is inspected and serviced semiannually in addition to
routine checks before each analysis. Leftover samples are returned to their
original containers.


Model WAP - Land Treatment Page 9 of 16

10.

ll.

12.

Ignitable Yes No Flash Point °C oF

Test Method

Reactive Yes No Test Method

Description of Results

EP Toxic Metals Yes No

Contaminant Concentration Method of Analysis

Total Organic Carbon (mg/L) Test Method

Organic Components (Including PHCs and Total Phenols) (percent by wt.
or mg

Test Method

Authorized Signature

Title and Date

Figure 1. Characterization form (continued).


TABLE 3. (continued)

Stream Analytical Rationale for Detection
Number? Parameters Methods Parameters Limit
(ug/L)
1., 2., 3., Mercury SW-846, Method 7471 Identify unexpected 0.2
4. (cold vapor technique) metals.
1., 2., 3., Selenium SW-846, Method 7741 (AA) Identify unexpected 2
4. metals.
1., 2., 3., Silver SW-846, Methods 3050/ Identify unexpected 10
4. 7760 (AA) metals.
5. *Flash point SW-846, Method 1010 Verify waste. -
5. Phenol SW-846, Method 8040 Verify waste and measure 1.4
(Gas Chromatograph) treatment performance.
5. PAH SW-846, Method 8100 Verify waste and measure -
(Gas Chromatograph) treatment performance.
1., 2., 3., *Cement setting Needle penetration Identify the presence of -
4., 5. retardants test (COE) constituents that retard
setting.
1., 2., 3., *Waste compatibility Mix wastes proportional to Identify incompatible wastes. -
4., 5. treatment mixture?

lRecharacterization Frequency: Stream 1.- semiannual; 2.- annual; 3.- quarterly; 4.- annual.

2Asterisk denotes key parameters measured with each shipment.

3SW-846 “Test Methods for Evaluating Solid Waste" July 1982.

ASTM American Society for Testing and Materials.

COE Corps of Engineers

4T author's note: These explosivity test methods are currently under development by the Bureau of Mines for EPA.]
5[Author's note: An actual waste analysis plan would provide a description of the test method.]

quaujPas) [POLWay) - d¥M Lapow

02 30 ST abeg


Model WAP - Land Treatment: Page 2 of 16

2. Identification of Wastes Treated

Table 1 identifies general physical and chemical characteristics of the
two types of wastes to be land treated. The API Separator sludge is high in
solids, having a heavy sludge character. It is not flowable as a liquid. The
DAF float is flowable and is handled more like a liquid because of its low
solids content.

The waste characteristics in Table 1 are based on analyses performed over
the past year by our in-house staff using EPA-recommended methods. The
Appendix VIII analyses were done according to the methods described by EPA in
guidance memoranda issued on April 3, 1984, and May 25, 1984. Quality
assurance and quality control procedures used to characterize the wastes are
described in the appendix to this waste analysis plan.

After completion of the treatment demonstration, the Refining Company
will propose principal hazardous constituents (PHCs) for use as indicator
Parameters for unsaturated zone monitoring at the full-scale land treatment
unit. PHCs will be selected on the basis of their ability to indicate the
fate (degradation, transformation, and immobilization) of all hazardous
constituents in the waste. A more detailed discussion of PHCs is provided in
the unsaturated zone monitoring plan.

The Refining Company has established boundary conditions for the API
Separator sludge and the DAF float based on the results of recent and past
analyses of these wastes at our plant. The Refining Company will use the
waste stream boundary conditions shown in Table 2 to determine if a given
batch of waste has characteristics that are typical of the API Separator
sludge or DAF float that the Refining Company land treatment facility is
permitted to manage. These conditions were selected based on waste analysis
data from our years of operation. If the characteristics of a given batch of
waste fall outside these boundary conditions, the Refinery Company will
conduct a more detailed investigation of the waste batch and notify EPA of our
findings. Section 4 describes in detail the Refinery Company's approach to
boundary condition analyses. Based on our years of operating experience, we
would not expect the waste to fall outside these limits. (Operating records
are available upon request.)


This information is necessary to evaluate the adequacy of the proposed testing
program. If the applicant chooses, the information may be placed in other
parts of the permit application. However, incorporation of this information in
the waste analysis plan will make the application easier to review and also
allow the plan to stand alone and be used as an operating manual.

Before conducting extensive testing to determine the waste properties that
might be acceptable for management at a given type of facility, the applicant
may want to refer to EPA background documents or other sources on the specific
waste or management process of interest. In addition to EPA background
documents, other sources of information include published scientific or
engineering literature; data from trial tests and waste analyses; and previous
experiences. For example, 40 CFR Part 261, Appendix VII enumerates major
hazardous constituents in each RCRA listed waste. "A Method for Determining
the Compatibility of Hazardous Wastes" (EPA-600/2-80-076) provides helpful
information on compatibility of chemical classes and their relation to
industry. This supplemental information may help identify what waste
information should be obtained by analysis and what analytical methods to use.

At this point it is appropriate to introduce the "boundary condition"
concept that will be used in the example waste analysis plans in Appendix B.
Boundary conditions are the maximum and minimum values of waste properties
which, if exceeded, would alert the operator that the waste does not meet its
typical properties and requires further attention before acceptance.

Process Tolerance Limits

A second concept that will be used in the example plans is that of
“tolerance limits." Tolerance limits represent those characteristics of a
waste or waste mixture that a waste management process can handle while
maintaining permit compliance. These limits can be quantitative or
qualitative. The tolerance limits are generally linked to the performance
goals of the waste management process. The waste analysis plan should address
these tolerance limits and describe the rationale for their selection.

Tolerance limits may thus be based on considerations of--

. the efficiency at which the process is designed to operate (e.g.,
99.99% destruction and removal efficiency for incineration), and

. potential incompatabilities between new wastes and the process raw
materials, structure, and currently managed wastes.

Questions that might need to be answered about process limitations are,
for example--

. How much supplemental fuel will have to be blended with the
waste for proper incinerator operation?


Model WAP - Land Treatment Page 8 of 16

6.

The Refining Company (Generator)
P.O. Box 00
Anytown, USA 00000

EPA ID Number USA 000000000

Date
Waste Identification

a. Facility Waste Number Sample Number
b. RCRA Waste Number

c. DOT Waste Number

d. Name of Waste

e. General Description of Waste Generation Process

Sampling
a. Date Sampled b. Sampling Method

c. Name and Affiliation of Sampler
d. Was sample taken during normal process operation?

Physical State at 21° C (70° F) Solid Sludge

Yes No

Liquid

Specific Gravity

Percent Water (Free Liquids) Test Method

Electrical Conductivity Test Method

Corrosive Yes No pH (regardless of corrosivity)

Figure 1. Characterization form,


TABLE 4. (continued)
Detection
Parameters Analytical Methods Limit Rationale for Parameters
(ug/L)
Mercury AA Method 7471 0.2 Identify unexpected constituents.
(SW-846)
Selenium AA Method 7741 2 Identify unexpected constituents.
(SW-846)
Silver AA Methods 3030/7760 10 Identify unexpected constituents.
(SW-846)
*Total organic APHA 505 - Treatment performance affected

carbon

*Total phenols
(SW-846)

Appendix VIII Constituents:

Volatile

organics mass spectrometer

Semivolatile
organics

Method 8040-Gas chromatograph -

Method 8240-Gas chromatograph/ 1ug/g
(SW-846)

Method 8270-Gas chromatograph/ 1lyg/g
mass spectrometer (capillary
column technique) (SW-846)

by organic content of waste.

Required by EPA because of slow
biodegradation and effect on
treatment.

Identify Appendix VIII constituents
and assess treatment performance.

Identify Appendix VIII constituents
and assess treatment performance.

quarterly key analyses and annual recharacterizations are performed.
2An asterisk indicates parameters are monitored quarterly.

3sW-846, "Test Methods for Evaluating Solid Waste," July 1982.
These explosivity tests are currently under development by the Bureau of Mines for EPA.J

4Tauthor's note:
S5APHA American Public Health Association

Water and Wastewater 15th

Standard Methods for the Examination of

edition, 1980.

t2UaUy RBA) pueT - GYM Lapow

9T 40 €T abeg


Model WAP - Incineration: Page 13 of 20

5. Waste Sampling and Analysis

Sampling

The sampling procedures are based on the wastes’ physical/chemical,
properties and means of containment. We selected the appropriate
representative sampling techniques, devices, and containers from "Test Methods
for Evaluating Solid Wastes" (SW-846). The equipment selected is listed for
handling material of the same physical form as our waste. Scientific
literature and work history volunteered by the generators were also reviewed
to identify any needs for special waste handling procedures necessary to
protect our personnel and keep our samples representative. Based on this
review, we will be certain that the sampling personnel wear goggles, rubber
gloves, and aprons; that the area is well-ventilated when sampling; and that
personnel are fully aware that certain wastes are toxic.

Since the still bottoms will be delivered in tanker trucks, we will
screen each shipment hy taking grab samples through the tank access ports. A
vertical sample will be taken at each port so as to obtain as representative a
sample as possible across the depth of the tank, considering the limited
access. Long glass tubing (SW-846, 1.4.1)(decontaminated between samples)
will be used to obtain full vertical samples. Sampling with this tube will be
hased on the same principle as sampling shallow depths with Coliwasas. The
ASTM Method 0140-70 describes the tube sampling method. Waste samples will be
stored in glass hottles with teflon caps (SW-846, 1.2.2).

The same sampling approach is used for routine waste characterization and
recharacterization and for unscheduled sampling of the wastes.

Quality assurance and quality control procedures for waste sampling are
described in Appendix I.

Analysis

Table 2 identifies the test methods chosen to characterize and
periodically recharacterize the wastes and our rationale for selecting each
parameter. Key parameters selected to screen the wastes in each shipment are
also identified. All analyses will be performed in-house, and all the
analytical methods are EPA-approved. Quality assurance and quality control
procedures for waste analysis are discussed in Appendix I.

The frequencies of recharacterization are as follows: 1) streams A-1 and
A-2 -semiannual, 2) stream B-1 -annual, and 3) stream C-1 -quarterly. They
were selected based on a ranking exercise that considers the issues addressed
jn Section 4, [See Appendix E of this manual for an explanation of this
ranking exercise.]


Model WAP - Impoundment: Page 8 of 16

Containment Surface impoundment

Sampling Technique Limited simple random sampling
Grab sample

Sampling Device Weighted bottle

Number of Samples Taken Grab one sample per depth level

Comments 1, Wear goggles, rubber gloves,

protective clothing, respirator,
and face mask.

2. Store sample away from acids
and standing water.

3. TOXIC WASTE,

References Technique: sw-846,! Section 1.1.3.1
Device: SW-846, Section 1.2.1.2

1sw-846 “Test Methods for Evaluating Solid Waste" July 1982,

Quality assurance and quality control procedures for waste sampling are
described in Appendix II.

Analysis

The wastewater treatment sludge has been analytically characterized with
respect to its manageability onsite. Table 2 lists the test method selected
for each parameter and the rationale for choosing each parameter. Al]
analytical methods in Table 2 are EPA-approved. Quality assurance and quality
control procedures for waste analysis are discussed in Appendix II. Our
wastewater treatment plant staff and ABC Labs will perform these waste
analyses,


Model WAP - Impoundment: Page 14 of 16

Collector WK, DAudy. Sample No. /5 -

Date Sampled Lalit Ltr) Qa 1923 Time Sampled 9: No a.m.
Field Information Lian alt Aa apalan al _< Tpyptca VA

Figure II-1. Sample container label.

Source: "Test Methods for Evaluating Solid Wastes" SW-846, July 1982.


"Proper operation and maintenance includes effective
performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and
process controls, including appropriate quality
assurance procedures,"

This quote is the extent of regulatory requirements for quality assurance and
quality control. Further information, however, may be found in Section 10 of
“Test Methods for Evaluating Solid Waste" (SW-846). An adequate quality
control/quality assurance assurance program must address all of the technical
aspects of such a program described in Section 10 of SW-846. Appendix B
contains example waste analysis plans for various hazardous waste management
scenarios. These examples should be reviewed to gain insight as to an
appropriate level of detail for a quality assurance/quality control program for
various levels of hazardous waste management facilities. As shown in the
examples, quality assurance/quality control programs may be presented best as
an appendix to a waste analysis plan.

14


TABLE 3. WASTE ANALYSIS INFORMATION
Detection Rationale for
Stream! Parameter? Test Method3 Limit Parameter Selection
(ug/L)
A-2, B-1, C-1, L-1 *bH SW-846, pH Method - Identify restricted corrosive

A-2, B-1, C-1, D-1

A-2, B-1, C-1, D-1,
L-1

D-1

A-2, B-1, C-1, D-1

*Free liquids

*water content

*Flash point

*Reactivity

9040 (Electrode)

SW-846, Method 9095
(Paint Filter Test)

ASTM D95 (Distillation)
or D176 (Centrifuge)

SW-846, Method 1010
(Pensky-Martens Closed
Cup)

U.S. Gap Test or U.S.

Internal Ignition Test®

wastes. Waste verification.

Identify restricted free
liquids.

No more than 30% water is
allowed in waste to maintain
integrity of landfill
structure and minimize
leachate generation.

Identify restricted ignitable
wastes.

Identify restricted reactive
wastes.

LLEsPueT - d¥M LePOW

Tz 30 ST abe


Model WAP - Land Treatment Page 10 of 16

5. Waste Sampling and Analysis

Sampling

The approaches described below pertain to characterization and
recharacterization as well as to unscheduled sampling of the DAF float and API
Separator sludge.

The DAF float is stored temporarily in an enclosed mobile tank before it
is spread over the land treatment area. This tank serves as a sampling point
to determine if the waste is treatable. We sample the float at three vertical
points from the access port in the tank. We choose not to composite the three
ports' samples because the concentration of heavy metals may not be evenly
distributed throughout the tank. Compositing samples with different
concentrations may mask the true metals concentrations in the sludge as it is
pumped from the tank to the land. For example, if the bottom of the tank
contained a high lead concentration, too much lead would be applied to an area
of land. This could hinder the treatment zone's performance and contaminate
soils outside the zone. A Coliwasa constructed of Type 316 stainless steel is
used to sample the float (SW-845, 1.2.1.1). The collected sample is then
placed in a container made from nonreactive linear polyethylene (LPE) (SW-846,
1.2.2). .

The API sludge is sampled at each API Separator. Random grab samples are
taken at three points within an imaginary, 3-dimensional grid of the sludge in
the separators. [See Appendix C of this manual.] In order to obtain a
reliable profile of key parameters in the sludge, the samples are not
composited because the potential exists for uneven distribution of metals that
have settled in the separators. The sludge is sampled with a trier
constructed of Type 316 Stainless Steel (SW-846, 1.2.1.5), and the sample is
stored in LPE containers (SW-846, 1.2.2).

We reviewed the scientific literature and our previous work history to
identify any needs for special waste handling procedures that are necessary to
ensure the safety of our employees who sample or handle the waste and to
assure that the waste samples remain representative during storage.

Table 3 contains information pertaining to all the sampling procedures
described, including safety precautions. Quality assurance and quality control
procedures for sampling waste are described in the appendix.

Analysis

Table 4 identifies test methods for each waste parameter to be measured.
Detection limits are provided for some methods where applicable. The table
also includes the rationale for choosing each parameter as discussed in
Section 4. The test methods were selected from EPA's "Test Methods for
Evaluating Solid Waste" (SW-846), the American Society for Testing and
Materials (ASTM) compendium of test methods, and the Anerican Public Health
Association's Standard Methods for the Examination of Water and Wastewater.
Quality assurance and quality control procedures for waste analysis are
discussed in the appendix.



TABLE 4-2. WASTE ANALYSIS PLAN CHECKLIST - SPECIFIC HAZARDOUS WASTE
MANAGEMENT PROCESS
|
CONTAINERS {TANKS (cont'd.)

|
Does the waste analysis plan include |2. Determining compat-

procedures for the following where
appropriate:

1. Determining compat-
ibility of a waste to a
container (if not deter-
mined when containers
were first selected)?

2. Determining compat-
ibility of a waste to
other wastes stored nearby
in containers, piles, open
tanks, or surface impound-
ments?

3. Determining compat-
ibility of a waste to
wastes previously held in
reused containers that
were not decontaminated?

4, Analyzing ignitable/
reactive containerized
wastes? _3
5. Analyzing liquids that
are collected in a storage

area? yes

TANKS

est

yes

no

no

Does the waste analysis plan include

procedures for the following where
appropriate:

1. Determining compat-
ibility of a waste to a
tank (if not determined
when tank was first

selected)? __yes

no

jibility of a waste to any
|raw materials or other
[wastes potentially or
|previously held in the

|tank? __yes__no
|
|3. Analyzing ignitable/
__yes__no |reactive wastes managed in
|tanks? yes___no

|
| SURFACE IMPOUNDMENTS
|

|Does the waste analysis plan include
|procedures for the following where

yes__no |appropriate:

1. Determining compat-
ibility of a waste to the
{impoundment's materials of
{construction (if not deter-
{mined when materials were
|first selected)?

yes no

—_—
|2. Determining the compat-
[ibility of a waste to any

[raw materials or other

|wastes potentially held in

|the impoundment? yes

no

no |

|3. Procedures for ana-
|lyzing ignitable/reactive
{wastes managed in impound-

|ments? yes

no

|
|WASTE PILES

|Does the waste analysis plan include
[procedures for the following where
|appropriate:

|

1. Determining the compat-
[ibility of a waste to the
|pile's materials of con-
|struction (if not deter-
|mined when materials were
|first selected)?

|

yes no

19


Model WAP - Tank: Page 5 of 12
4, Waste Parameters to be Monitored

The sludge must be safely stored in an open tank for up to 6 months to
dry without reacting. It can be managed for this period because 1) the tanks
were designed specifically to store the reactive sludge, and 2) our years of
operating data, which cover a broad range of production rates, indicate that
the sludge fed to the tanks remains relatively consistent in composition.
Also, variations in sludge composition are not sufficient to offer a serious
threat of unexpected constituents.

To select the proper parameters to monitor storage performance, we 1)
reviewed existing information on the sludge properties (including its
reactivity), 2) noted what properties best indicate change in a waste, and 3)
compared this information to the tank design criteria so we can assure
compliance with RCRA permit conditions. These steps included identifying the
tank design and operating limitations described in Section 3.

The wastewater treatment sludge generated by nitrocellulose production
contains nitrocellulose and water. The sludge characteristics are expected to
change only in the ratio of solids-to-water and perhaps pH. Parameters were
chosen based primarily on the most significant sludge property-reactivity (or
explosivity). The sludge pH, percent moisture, and, in turn, explosivity are
measured to provide a sufficient indication of any important variation in
Sludge character.

When the tanks are emptied for offsite transport of the sludge, they are
not decontaminated because they are being refilled with the same type of
sludge that the tanks previously held. Therefore, no potential waste
incompatibilities can occur and there is no need to monitor waste
characteristics for incompatibilities. The transport vehicles are
decontaminated by their owners before receiving the sludge, and they are
constructed of materials that are compatible with the sludge to eliminate the
potential for reactions.

Our in-house wastewater treatment plant staff will recharacterize the
sludge semiannually as a load is prepared for offsite shipment. We prefer
semiannual recharacterizations, because --

1) our years of operating experience indicate that the sludge's primary
constituent, nitrocellulose, remains consistent; only its
concentration relative to the moisture content and pH may vary in
the sludge within a safe range (operating data available upon
request);

2) the offsite hazardous waste management facility that accepts the
sludge also analyzes it for their own purposes; and

3) the sludge samples are most representative when taken during tank
drainage.


Model WAP - Land Treatment Page 6 of 16
4. Waste Parameters to be Monitored

This section identifies the waste parameters that will be monitored to
generate the information that the Refinery Company needs to properly manage
the API Separator sludge and DAF float at the proposed land treatment unit.
We have selected waste parameters that allow us to 1) demonstrate that the
waste characteristics are within the established boundary conditions, 2)
address process tolerance limits, and 3) successfully manage the waste at the
land treatment unit in accordance with 40 CFR Part 264, Subpart M.

To select the appropriate waste parameters, we 1) reviewed existing
information on the waste properties, 2) noted what properties best indicate
any change in waste characteristics that affect treatability, and 3) compared
this information to our treatment process design criteria so that we can
prevent any noncompliance with RCRA permit conditions. Since the RCRA permit
will be based on the type of waste treated, waste analysis parameters were
chosen based on those waste characteristics that affect treatability.

The following parameters have been selected to monitor boundary
conditions/tolerance limits: water content, electrical conductivity, pH,
total organic carbon, and Appendix VIII hazardous constituents including total
chromium and lead. Of the Appendix VIII constituents, principal hazardous
constituents (PHCs) will be monitored frequently. A complete scan for the 89
Appendix VIII constituents specified by EPA will be performed with periodic
waste recharacterizations. [Refer to EPA's April 3, 1984, memorandum on land
teatment and Appendix VIII constituents.] Because our wastes may contain low
concentrations of various phenolic compounds that are not biodegraded easily,
EPA has required that total phenols be measured. Exceeding the boundary
conditions/tolerance limits for the waste characteristics could result in
untypical wastes that could contaminate the environment beyond the designated
treatment zone. Parameters to be monitored for RCRA waste characteristics
include ignitability (flash point), reactivity, and EP toxic metals in
addition to total chromium and lead. These characteristics will be monitored
with periodic waste recharacterizations. Specific gravity will be measured to
help verify waste characteristics.

In selecting waste characteristics to monitor, we also considered the
potential for halogenated organic constituents to be present in the sludges.
Based on our waste analyses of the sludge over the years and records of
sludges from similar refining facilities within our company, there is no
evidence that halogenated organics would be present in the sludge. (These
data are available upon request.)

Although a very low probability exists that wastes not permitted for
treatment could be mistakenly combined with the permitted wastes, such a
mistake could reduce land treatment performance. We must be sure that the
wastes we handle are the DAF float and API Separator sludge and that the
wastes do not contain nonpermitted components (i.e., boundary conditions are
met). This assurance is provided by sufficiently analyzing the wastes as
described in this plan. We decided how often we felt it necessary to
characterize the waste with these tests by considering--


TABLE 1.

WASTE CHARACTERISTICS

Stream! »2,3

Basis for
Hazard Listing

Physical
Properties4

Chemical
Composition
(or % by volume)

A Spent Solvent
Degreaser (TCE)

B Spent Solvent
Degreaser (TCE)

Cc Spent Solvent
Degreaser (TCE)

TCE (Toxic)

TCE (Toxic)

TCE (Toxic)

Specific gravity:
1.30 to 1.46
Flash point:
73 to 77 °C

Specific gravity:
1.26 to 1.41
Flash point:
77 to 81 °C

Specific gravity:
1.28 to 1.44
Flash point:
75 to 79 °C

TCE: 85 to 95% by volume
Oil and grease:

5 to 15% by volume

Dirt: negligible

TCE: 80 to 90% by volume
Oi1 and grease:

10 to 20% by volume

Dirt: negligible

TCE: 82 to 92% by volume
O71 and grease:

8 to 18% by volume

Dirt: negligible

lprocess code for all streams is SO1, container storage.
"A", "B", and "C" refer to process areas.
3a11 streams are assigned RCRA number F001 (40 CFR 261.31).

4a11 streams are liquid with one layer.
the flash point is 32° C.

The specific gravity of pure TCE i

1.465, and

raauLezU0D - d¥M LePoW

st #0 € abed


APPENDIX C
HOW TO USE A RANDOM NUMBERS TABLE FOR WASTE SAMPLING

This appendix has been developed to demonstrate how hazardous waste can
be sampled without any bias by the sampler. It is important that the sample
you obtain is representative of the actual waste's chemical and physical
characteristics. To avoid taking many samples that are expensive and tedious,
you can, with the aid of a random numbers table, select areas in a waste
collection that should be just as representative of the waste.

The following example explains how to use a random numbers table.

Let us assume that we have 30 drums stored. We assign a two digit number
to each drum ranging from "01" to "30", Now refer to Table 1, "Random
Numbers". We will use these numbers to decide which of our 30 drums to
sample. We select the point at which to begin in the table by using our date
of sampling. For example, if we sample on October 14, 1983, we move to the
10th horizontal set of numbers. (October is the 10th month of the year.) We
then move to the 14th set of vertical numbers (the 14th day of the month).
Next we use the years, "83", We start with th: first number on the first row
of this set of 10 digits and count 8 digits to the right. At the eigth digit,
we then count down 3 digits. This is our starting point. We read the numbers
from left to right in sets of two digits since the maximum number of barrels
(30) has two digits. Any number greater than 30 is ignored. If any number is
repeated, each repeat is ignored. If we come to the end of a row on the page,
we return to the far left on that same page and begin reading numbers left to
right in the next row below it. We continue selecting two digit numbers
between "01" and "30", inclusive, until the number of drum samples required
has been fulfilled.

If we wanted six samples, we would hegin with --

[2p 83533 asada

ar3] psho

[Six was chosen as a sample number only for the purpose of this demonstration.
It does not mean that everyone should sample six out of every thirty drums.]
Therefore, drums numbered 24, 25, 01, 03, 18 and 05 will be sampled. Figure 1
displays the barrel numbers selected.

This random numbers method can also be used for other waste sampling
scenarios, e.g., surface impoundments. These other scenarios may entail
dividing your waste collection into a three-dimensional grid. Figure 2
displays how such an area could be numbered for three levels of depths. The
number of levels required depends on the waste and on the facility design.
"Test Methods for Evaluating Solid Wastes" (SW-846) should be reviewed for
EPA's latest guidance on determining the total number of points to sample.

C-1


Model WAP - Chemical Treatment: Page 8 of 20

Waste Shipment Arrives
Compare Shipment
Externally to
Its Manifest Discrepancy
Visually Inspect Y
Shipment Contact
i Generator
Sample Waste
Analyze Waste for
Key Parameters
Evaluate Analytical Data Reject
Waste
Shipment
Discrepancy
y
Contact ——EE
Generator
Recharacterize
Waste
Evaluate Analytical Data

Accept Waste
Shipment

Figure 2. Shipment screening procedures.


4, CHECKLISTS FOR WRITING OR REVIEWING WASTE ANALYSIS PLANS

This section presents “checklists” of information needed in a waste
analysis plan. These checklists are intended to help agency permit writers to
review permit applications more expeditiously and uniformly. They are also
useful to permit applicants as a convenient check to make sure the application
contains the necessary information. The checklists address the items that are
required in a "complete" plan as well as additional items which, if present,
will make the plan more useful and assist the reviewer in evaluating the
application. The checklists are designed to allow one to check off if an item
is or is not properly addressed. By properly addressing the checklist items,
an applicant can minimize the chances of submitting an incomplete application.
For the convenience of the user, the checklist items not required by the
regulations are footnoted.

Table 4-1, "Waste Analysis Plan Checklist- General Information," applies
to all hazardous waste management facilities. The checklist can be used
regardless of the specific hazardous waste management process(es) operated at
the facility. It is divided into five major cateyories:

. Facility Description

. Identification of Wastes to be Managed
. Process Tolerance Limits

. Waste Parameters to Be Monitored

. Waste Sampling, Analysis, and Quality Assurance/
Quality Control (QA/QC) Procedures.

These five categories correspond to the example provided in Section 3.3,
"Abbreviated Example Plan." Applicable RCRA regulations are cited within the
checklist.

Table 4-2, “Waste Analysis Plan Checklist - Specific Hazardous Waste
Management Process," presents additional checklist items specific to
particular hazardous waste management processes. These checklists include
information items that are required in addition to the general checklist
information. They are based on 40 CFR 264, 265 (thermal, chemical, physical,
and biological treatment), and 270 information requirements. Only those
portions dealing with the specific process will be applicable to a given
facility's waste analysis plan.

Table 4-3, "Optional Items to Consider When Preparing A Waste Analysis
Plan," contains information that is not specifically required under RCRA,
However, this information may contribute to a more complete waste analysis
plan, making it more useful to operators on a day-to-day basis. Permit
reviewers should use this table with discretion when reviewing waste analysis
plans since the regulations do not require this material.

15


Model WAP - Impoundment: Page 4 of 16

3. Surface Impoundment Tolerance Limits

The surface impoundment has the following limitations:

. the volume of sludge in the impoundment must not exceed the design
capacity in order to prevent overflow and contamination of adjoining
areas,

. the impoundment should not receive any wastes that are incompatible
with its butyl rubber liner, e.g., organics, so that it remains
impermeable to the heavy metals; thus the total organic carbon in
the wastes must be negligible, and

. the impoundment should not receive any wastes that are incompatible
with the metallic sludge, reacting to damage the liner or emit
dangerous gases; this includes free and complexed cyanide that
must remain negligible in the waste.

These qualitative tolerance limits were established to assure that the surface
impoundment safely stores the sludge without threatening environmental
contamination.


Model WAP - Chemical Treatment: Page 5 of 20

8. Reactive Yes No Test Method

Description of Results

9. EP Toxic Metals Yes No

Contaminant Concentration Method of Analysis

10, Organic Components (Indicate percent by weight or mg/L) Test Method

11, Inorganic Components (Indicate percent by weight or mg/L) Test Method

I hereby certify the accuracy of these data and the representativeness of
the waste sample.

Signature and Title

Date

Figure 1, Waste characterization form (continued).


Model WAP - Incineration: Page 9 of 20
4. Parameters to be Monitored

The distillation recovery bottoms must meet the chemical and physical
requirements specified in the incinerator permit. To select the analysis
parameters to represent the waste characteristics, we 1) reviewed existing
information on the waste properties such as generator data and EPA's
Background Information Document for the specific waste, 2) noted what
properties best indicate any change in the waste, and 3) compared this
information to the incinerator design criteria and trial burn test results.

The three categories of wastes are analyzed for specific gravity,
viscosity, elemental analysis (including metals), and total organic carbon to
verify waste composition; corrosivity, reactivity, and flash point to assure
safe handling. Percent water, ash content, and heat of combustion are
monitored to assess various aspects of incinerator performance. Wastes are
scanned by GC/MS for the presence of hazardous constituents. Also,
waste-specific parameters to be determined are methylene chloride,
trichloroethylene, organic chloride (total organic halogens), flash point, and
acetone. POHCs are monitored to estimate destruction and removal efficiency.
All the wastes we intend to manage are mutually compatible; therefore, we see
no need to test routinely for compatibility.

We plan to recharacterize the wastes periodically to identify changes
that cannot be verified by waste shipment screenings. The frequency for
recharacterizing the wastes was selected by considering --

. the potential for restricted waste being combined in a shipment,
. the variability of the waste composition between shipments,

. the likelihood of a waste undergoing changes that alter its
permitted characteristics, and

. the prior history of the waste generator.

Section 5, “Wastes Sampling and Analysis," contains a description of the
analysis procedures to be followed and identifies the frequencies of waste
recharacterization.

We screen shipments, because the potential may exist for generators to
include, by mistake, wastes other than those permitted for incineration at our
facility. This could affect the incinerator's destruction and removal
efficiency by reducing the heating value of the waste, for example. Figure 2
iispiays the sequence of events that are to be followed when waste shipments
2 rive at our facility. We developed the screening procedures based on our
trowledge of the generators and the wastes they ship.

When a waste shipment arrives at the facility, we first check the
manifest for completeness and correctness. At a minimum, we will look for the
following information on each manifest:

. a manifest document number;


Model WAP - Incineration: Page 11 of 20

. the generator's name, address, and EPA identification number;
. each transporter's name and EPA identification number;

. the destination of the waste shipment, i.e., hazardous waste
management facility, address, and EPA identification number;

. an alternative hazardous waste management facility, address, and
EPA identification number;

. a Department of Transportation shipping name and number;

. the quantity or volume of waste in the shipment; and

. a signed certification of the shipment's content.
The shipment will be inspected visually, noting --

. if the shipment labels/placards match the manifest;

. any irregularities in the shipment (e.g., leaks);

. if any restricted wastes are visibly present; and

. if the waste appearance matches any previously noted descriptions.

It is standard procedure to check manifests and inspect shipments
visually regardless of the waste. Additional sampling and analysis of wastes
are more dependent on the specific generator and the waste. All of the waste
shipments will be sampled as described in Section 5, “Waste Sampling and
Analysis," but the analysis of waste shipments does not always include
measuring all the parameters used in the initial waste characterization. A
subset of these, known as "key parameters," is selected, so we can obtain the
best indication of waste identity and incinerability, within reasonable given
time and labor constraints. Four criteria are considered when selecting key
parameters, These are --

. the need to identify restricted wastes,

. waste characteristics that affect the incinerator's performance,

. the potential ignitability, reactivity, or incompatibility of the
wastes, and

. parameters that best indicate changes in waste characteristics.

We feel assured that we can adequately screen incoming shipments by basing our
key parameters on these criteria.

In the event that a waste shipment does not pass the screening tests, we
contact the generator and, if requested, we perform a complete


2. REGULATORY REQUIREMENTS

Title 40 of the Code of Federal Regulations, Part 264.13 establishes the
requirement for a waste analysis plan and describes the information that is
required in such a plan (see Appendix A). These regulations are applicable to
all types of hazardous waste management facilities. In addition to the above
general requirements, management-specific requirements are described in the
following sections of the regulations:

40 CFR 264.170 to 264.178 Containers (Subpart 1)

40 CFR 264.190 to 264.199 Tanks (Subpart J)

40 CFR 264.220 to 264.230 Surface Impoundments (Subpart K)
40 CFR 264.250 to 264,258 Waste Piles (Subpart L)

40 CFR 264.270 to 264.282 Land Treatment (Subpart M)

40 CFR 264.300 to 264.316 Landfills (Subpart N)

40 CFR 264.340 to 264.351 Incinerators (Subpart 0)

40 CFR 265.370 to 265.382 Thermal Treatment (Subpart P)

40 CFR 265.400 to 265.406 Chemical, Physical, and Biological

Treatment (Subpart Q)

The waste analysis plan regulations distinguish between two types of
hazardous waste management facilities:

+ Onsite facility--the facility that manages only those hazardous
wastes that are generated on its own geographic site (see 40 CFR
260.10 for more information), and

+ Offsite facility--the facility that receives and manages hazardous
wastes that are generated outside the site in question.

Certain parts of the waste analysis plan requirements pertain to all hazardous
waste management facilities while others apply only to offsite facilities.

While the regulations governing waste analysis plans are extensive and
complex, their objectives are simple. These are--

1. to ensure that sufficient information is available to determine
whether the wastes considered for management at a hazardous waste
management facility fall within the scope of the facility's permit,
and

2. to ensure that the facility has sufficient information about the
wastes to properly manage the wastes once they are accepted.

To comply with the regulations, each waste analysis plan must address the
procedures that will be followed to accomplish these objectives.


TABLE 2.

WASTE STREAM BOUNDARY CONDITIONS

Parameter API Separator Sludge DAF Float

Total Chromium (mg/kg) 1,590 to 4,500 0 to 150
Lead (mg/kg) 250 to 825 200 to 750
Water (% by weight) 30 to 70 70 to 95
Electrical

conductivity (rmhos/cm) 0 to 5 0 to 6
pH 2.5 to 6 2.5 to 5.5
Total organic carbon (TOC) (mg/L) 8,000 to 9,750 4,300 to 5,700
Total phenols (ug/g) 0 to 150 0 to 75

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91 40 p abeg


Model WAP - Container: Page 8 of 15

Containment Device 55-gallon drums
Sampling Technique Simple random sampling
Grab samples
Sampling Device Coliwasa
Number of Drums Sampled One drum from each stream
Comments 1. Wear goggles, rubber gloves, and apron.
2. Have area well-ventilated.
3. Get sample from midlevel of drum.
4. Place sample in glass bottle with teflon

cap.
5. TOXIC WASTE,

References Technique: SWw-846!, Section 1.4.1
Device: SW-846, Section 1.2.1.1

lgw-846 “Test Methods for Evaluating Solid Waste” July 1982.

Quality assurance and quality control procedures for waste sampling are
described in Appendix II.

Analysis

Table 2 identifies the test method to be employed to measure each waste
parameter. All parameters and test methods apply to all three of the wastes
streams due to their similarity. The test methods were chosen from the
American Society for Testing and Materials (ASTM) compendium of test methods
and EPA's "Test Methods for Evaluating Solid Waste" (SW-846). Quality
assurance and quality control procedures for analyzing the waste are discussed
in Appendix II.


TABLE 2. (continued)

+ Stream Containment Device

Sampling Technique

Comments

C-1 Dust/sludge
secondary lead
smelting

D-1 Bottom tars
from phenol

Open-bed truck

§5-gallon drum

Simple random grab sample
with trier (SW-846,
Section 1.2.1.5). One
sample per depth level.

Simple random grab
sample with Coliwasa

Wear rubber gloves, apron,
shoes, mask, and breathing
apparatus.

Use linear polyethylene
sample container.

Toxic.

Wear goggles, mask, rubber
gloves, apron, and boots.

production (SW-846, Section 1.2.1.1). 2. Place sample in glass
Sample cube root of total container with teflon cap.
number of containers 3. Get one mid-level sample.
per shipment. 4. Toxic.
L-1 Leachate, Sump Simple random grab sample with 1. Do not collect during
homogeneous Coliwasa (SW-846, Section rainfall.
liquid 1.2.1.1). Sampling dependent 2. Put in linear polyethylene

on volume of leachate
collected in sump.

container.
Potentially toxic.

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ltypically, off-spec materials are not analyzed.
Source of cube root equation: ASTM D140-70.

T2 $0 €1 abed


Model WAP - Incineration: Page 20 of 20

All test results are documented on the characterization form shown in Figure
1 and are kept on file in our facility's office.

Analytical equipment is inspected and serviced semiannually in addition to
routine checks before each analysis. Leftover samples are returned to storage
for incineration.


TABLE 3. WASTE SAMPLING INFORMATION

Stream Containment Device Sampling Method Comments
DAF Float Temporary storage Grab sample with 1. Wear goggles and rubber
tank Coliwasa (SW-846,1 gloves.
Sections 1.4.2 2. Store sample in LPE
and 1.2.1.1) containers.

3. Grab one sample at each
of three depth levels.

4. Toxic waste.

API Separator Sludge API Separator Random grab sample 1. Wear goggles, rubber
with trier (SW-846, gloves, and apron.
Section 1.2.1.5) 2. Store sample in LPE
containers.

3. Grab one sample at each
of three grid areas
randomly selected in the
separator.

4. Toxic waste.

lsw-846, "Test Methods for Evaluating Solid Waste," July 1982.

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9T $0 TT abe


Model WAP - Container: Page 11 of 15

SMITH LABORATORIES

Date: May 15, 1983
Sample Number: Drums 03-1 Client: Aircraft Parts Mfg. Co.
16-1 Address
28-1

Collected: January 18, 1983

Received: January 18, 1983

Sample Process

Drum Area

Number Stream Parameter Results Test Method

03-1 A Specific 1,42 astm)
gravity
Flash point 76.5° C 10102
*Trichloroethylene 92% 380102
(by volume)

16-1 B Specific 1.29 astml
gravity
Flash point 77.8° C 10102
%Trichloroethylene 87% 80102
(by volume)

28-1 c Specific 1.30 astml
gravity
Flash point 77.5° C 10102
“Trichloroethylene 85% 80102

(by volume)

1 ASTM American Society for Testing and Materials
2 “Test Methods for Evaluating Solid Waste" SW-846 July 1982.

Signature of Certification:

n smith, President