WASTE ANALYSIS PLAN 

FOR 

TRADE WASTE INCINERATION 
WASTE ANALYSIS PLAN 

OUTLINE 

PAGE 

1.0 INTRODUCTION 3 

2.0 SAMPLING METHODOLOGY 4 

2.1 Materials 5 

2.2 Types of Containment 5 

2.2.1 Containers and Tanks 5 

3.0 ANALYTICAL RATIONALE 7 

3.1 Mandatory Analyses 7 

3.2 Non-hazardous Waste Analyses 9 

3.3 Supplemental Analyses 9 

4.0 PROFILING PROCEDURES 13 

4.1 Procedural Requirements 13 

4.1.1 Information Provided by Generator 13 

4.1.2 Waste Management Decision 14 

4.1.3 Waste Re-evaluation * 15 

4.1.4 Exceptions to the Foregoing Requirements 15 

4.1.5 Standard Profiles 17 

4.2 Decision Evaluation Logic for Profiling Procedures 17 

5.0 INCOMING WASTE SHIPMENT PROCEDURES 21 

5.1 Receiving Procedures 22 

5.1.1 Exceptions to Incoming Waste Analysis Procedures 23 

5.2 Incoming Waste Shipment Decision Evaluation Logic 25 

5.2.1 Waste Identification 25 

5.2.2 The Need For Additional Analysis 25 

5.2.3 An Evaluation of Whether a Waste is Found 

to be in Conformance or Non-conformance 26 

5.2.4 An Evaluation of Whether Wastes Found to be in 

Non-conformance can be Accepted or will be Rejected 26 

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6.0 PROCESS OPERATIONS PROCEDURES 29 

6.1 Storage 29 

6.1.1 Waste in Containers 29 

6.1.2 Waste in Tanks 29 

6.1.3 Bulk Solids Storage 30 

6.2 Decanting 30 

6.3 Incineration 30 

6.3.1 Pre-treatment Analyses 31 

6.3.2 Treatment Residue Evaluation 32 

7.0 QUALITY CONTROL POLICY 34 

ATTACHMENTS 

APPENDIX WAP-A: ANALYTICAL PROCEDURES 

APPENDIX WAP-B: ASH AND DRY SCRUBBER SOLIDS SAMPLING PROTOCOL 

APPENDIX WAP-C: WASTE ACCEPTABILITY CRITERIA 

APPENDIX WAP-D: DETERMINATION OF INCOMING WASTE CONFORMANCE/NONCONFORMANCE 

APPENDDI WAP-E: CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURE 

APPENDIX WAP-F: BIBLIOGRAPHY OF STANDARD CHEMICAL REFERENCE MATERIALS 

APPENDIX WAP-G: HM-181 COMPATIBILITY CLASSES 

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WASTE ANALYSIS PLAN 

In accordance with the regulatory requirements set forth in 40 CFR 264.13 and 35 IAC 

724.113, Chemical Waste Management, Inc. (CWM) has developed this Waste Analysis Plan as an 

integral part of the RCRA Part B Permit Application for its Trade Waste Incineration (TWI) 

facility located in Sauget (St. Clair County), Illinois. The procedures set forth in this plan ensure 

that this facility will be in compliance with all requirements of 40 CFR 264.13 and 35 IAC 724.113. 

A copy of this plan will be available at the facility at all times. 

1.0 INTRODUCTION 

The purpose of this Waste Analysis Plan (WAP) is to describe and document the necessary sampling 

methodologies, analytical techniques and overall procedures used to determine the acceptability and 

management of all wastes which enter this facility for treatment or storage. These procedures shall apply to 

all hazardous and nonhazardous wastes (hereafter referred to as "waste") received by the facility, except 

samples as identified and defined in 40 CFR 261.4(d), (e), and (f). Specifically, the plan delineates the following: 

Analytical Parameters, Rationale and Techniques to identify wastes or 

determine information so that treatment and storage techniques can be 

utilized. 

Sampling Methodology to ensure that adequate and representative samples are 

taken. 

Profiling Procedures to determine the acceptability of a particular waste 

stream pursuant to facility permit conditions and operating capabilities prior 

to acceptance of the waste at the facility. 

Incoming Waste Shipment Procedures to identify that the delivered waste 

conforms to the accompanying manifest, profile documents, and the conditions 

of the facility permit. 

Process Operations Procedures to maintain safe and appropriate methods of 

storage, treatment, disposal or movement of wastes within the facility. 

Residue(s) resulting from on-site treatment of land disposal restricted wastes 

will be evaluated, as needed, against the appropriate treatment standard or 

prohibition. 

Quality Control Policy the facility laboratory follows to achieve high quality analytical results. 

The forms shown within this WAP are typical forms currently used by the existing facility. These forms 

may require updating to equivalent or alternate forms based upon changes in regulations, customer needs, 

facility operations, or company policies. TWI will provide notification to the EEPA-DLPC Permit Section as 

required by 35 IAC 703.280. 

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For purposes of implementation and performance of this WAP, "TWI Laboratory" means the TWI 

laboratory or any CWM laboratory, any CWM subsidiary laboratory, or any CWM designated contract 

laboratory, in addition, the use of TWI means CWM or WMX Technologies. 

The Laboratory, Technical, Operations, Environmental, and General Managers or their designees 

hereinafter are collectively referred to as "Facility Management", or individually referred to as the Laboratory, 

Technical, Operations, Environmental, or General Manager. 

All wastes handled by this facility will be subjected to these procedures. This is to help ensure that 

this facility will be in compliance with applicable permits and regulations. 

The company strives to maintain, at all times, complete compliance with the hazardous waste 

regulations. Because new requirements, such as those promulgated under the land disposal restrictions, often 

become effective prior to the time WAP revisions can be formally made and approved by all appropriate 

agencies, it is impossible to have in place an approved WAP meeting all the conditions of immediately effective 

regulatory requirements. 

In light of these facts, the facility will have in place a written protocol specifying the new requirements 

such as testing and frequency prior to receipt and/or processing of the regulated waste. The facility may also 

periodically revise the protocol to reflect scientific advances or additional regulatory requirements. If WAP 

revisions are necessary because of a new regulatory rule, they will be submitted within 60 days after the 

effective date of the rule. 

2.0 SAMPLING METHODOLOGY 

Sampling is performed at the facility to identify waste shipments and by the waste generator to make 

the initial waste determination at their location. Specific sampling procedures are dependent on both the 

nature of the material and the type of containment. A full-depth representative sample will be obtained from 

each container and tank truck unless the physical properties (i.e., heterogenous debris, extremely hard material, 

or high shear force) preclude obtaining a full-depth representative sample. Exceptions to obtaining full-depth 

samples are noted in Section 2.1 and do not apply to frozen or chilled material. 

This section presents sampling methodologies to be utilized on-site by personnel in accordance with 40 

CFR 264.13(c)(2) and/or 35 IAC 724.113(c)(2). Waste generators are referred to 40 CFR 261, Appendix I 

and/or Appendix A of 35 IAC 721 for sampling procedures. In the case where the generator submits a sample 

for initial profile approval, TWI requires the generator to certify that the sample submitted is representative. 

The sampling equipment and procedures described in this WAP represent the facility's recommended 

sampling protocol for general types of waste material and containment. All methodologies will be updated and 

revised as the references are updated and revised. 

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2.1 Materials 

At a minimum, the methodologies utilized for specific materials correspond to those referenced in 40 

CFR 261, Appendix I and/or 35 IAC 721, Appendix A The sampling methods and the equipment utilized for 

these and any different materials are presented in Table 2-1. This table is a simplified summary of data 

excerpted from 40 CFR 261, Appendix I and/or 35 IAC 721, Appendix A. 

Care must be taken when collecting samples to ensure that excessive loss of volatile organic compounds 

does not occur during sample handling and storage. Sample containers must not be left opened except when 

preparing for the addition or removal of the sample, and sample jars must be filled as completely as practicable. 

Certain waste materials will require deviations from the these protocols. When deviations are 

necessary to sample materials which cannot be sampled using the recommended protocol (for example, debris, 

extremely hard materials, or other high shear force materials), the facility will obtain a representative sample, 

based on the circumstances preventing a vertical section, knowledge of the waste, and the container size and 

shape. For example, debris and like material will be sampled with scissors, tongs, hammer and/or chisel. 

Adhesives or other highly elastic substances will be sampled with a scoop or shovel and scissors or tongs. 

Resins and other extremely hard materials will be sampled with a hammer and a chisel. 

(See Appendix WAP-E). 

2.2 Type of Containment 

In addition to American Society for Testing Materials (ASTM) and other EPA-approved sampling 

procedures, TWI has instituted specific methodologies for ensuring that samples taken from various types of 

containers are representative. The type of container may be transportable such as drums, portable transport 

units (e.g. small tanks, roll off boxes), and tanker trucks; or stationary (e.g., tanks) and in-process sources. The 

sampling devices are selected, depending on the size and type of containment and on the specific material 

involved. 

Because there is a much greater tendency for heterogeneity in a vertical plane rather than a horizontal, 

sampling will be performed to address this concern (e.g., full-depth vertical samples will be taken when 

possible). When samples are collected which consist of multiple phases, analysis will be conducted on the 

sample as a whole. In addition, access to a container (i.e., drum bungs, tank truck domes, and large tanks with 

sampling ports) will influence the location from which samples can be taken. 

2.2.1 Containers and Tanks 

Sampling of small containers (e.g., drums, cartons, and other small units) varies with the nature of the 

waste material. For flowable materials, the sampling device to be used is either a Coliwasa unit or tube 

sampler to draw a full vertical axis sample of the flowable material (or other appropriate device as listed in 

Table 2-1). For nonflowable wastes, a tube sampler or a trier is used to obtain a sample (or other appropriate 

device as listed in Table 2-1). 

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Large containers and tanks for flowable materials and bulk containers for solid materials may be either 

stationary or mobile. Liquids are sampled with a Coliwasa or tube sampler to obtain a vertical section (or other 

appropriate device as listed in Table 2-1). Light, dry powders and granules are sampled with a tube sampler 

to obtain a vertical core (or other appropriate device as listed in Table 2-1). Heavier solids are sampled by trier 

or shovel, or by coring with a tube sampler (or other appropriate device as listed in Table 2-1). Stationary 

tanks for blending of liquids for feeding the incinerator are sampled with a bacon bomb (or other appropriate 

device as listed in Table 2-1). In addition, tanks may be sampled from tank sampling ports or taps through 

tank inlets or outlets. 

TABLE 2-1 

SAMPLING METHODS AND EQUIPMENT 

MATERIAL METHOD EQUIPMENT0 

Extremely viscous liquid ASTM D 140-70a or 

ASTM E 300a 

Tube samplerd, thief, 

or Coliwasa 

Crushed or powdered ASTM D 346-75a or 

ASTM E 300a 

Tube samplerd, trier, 

scoop, or shovel 

Soft ASTM D 420-69a or 

ASTM E 300a 

Tube samplerd, trier, 

auger, scoop, or shovel 

Soil-like material ASTM D 1452-65a

 or 

ASTM E 300a 

Tube samplerd, trier, 

auger, scoop, or shovel 

Fly ash-like material ASTM D 2234-76a

 or 

ASTM E 300a 

Tube samplerd, trier, 

auger, scoop, or shovel 

Containerized liquids SW-846b

 or 

- ASTM E 300a 

Coliwasa/tube 

samplerd, weighted bottle, 

bomb, or tank sampling ports 

American Society for Testing Materials, 1982. Annual Book of ASTM Standards, Philadelphia, PA, 

or most recent edition. 

'Test Methods for Evaluating Solid Waste, Physical/Chemical Methods", SW-846, Third Edition, 

September 1986 as amended by Update I (July 1992), U.S. Environmental Protection Agency, Office 

of Solid Waste (NTIS, 5285 Port Royal Road, Springfield, VA 22161) or more recent edition or revision 

(GPO, Supt. of Documents, Washington, DC 20402). 

The specific equipment is dependent on the type of container. See SW-846 for specific examples. See 

also Section 2.2. 

Personal Protection and Safety Training Manual (Cincinnati, Ohio: U.S. Environmental Protection 

Agency, National Training and Operational Technology Center, 1981) pp. 3-1 and 3-4, or current 

revision. 

WAP-6 REVISION 11 

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3.0 ANALYTICAL RATIONALE 

In accordance with 40 CFR 264.13(b)(5) and/or 35 IAC 724.113(b)(5), a pre-existing waste 

characterization is supplied to TWI by the waste generator on the Waste Profile Sheet (WPS, Figure 4-1). The 

generator supplies TWI with all the information required to characterize, treat, store or dispose of his waste, 

as defined in 40 CFR 264.13(a)(1) and/or 35 IAC 724.113(a)(1). [ref: 40 CFR 264.13(a)(2) comment and/or 35 

IAC 724.113(a)(2) Board Note]. See Section 4.1 for a discussion regarding the information and data to be 

supplied by the generator. The analyses if necessary, are provided by the generator or TWFs laboratory to 

evaluate the pre-existing waste characterizations and to comply with facility acceptance criteria. 

Analytical methods are classified as Mandatory Analyses, Blend Analyses, and Supplemental Analyses. 

This arrangement allows a tiered approach to waste identification, enabling TWI to structure the analyses to 

adequately identify the waste or to define operational parameters for various treatment processes. 

At a miniTmim, all incoming wastes are subjected to the Mandatory Analyses as at first step in the 

analytical scheme (except as noted in Section 4.1.4). Supplemental Analyses are performed as specified in 

Section 3.3. The Blend Analyses are used to determine the liquid blend characteristics in order to maintain 

a steady state (normal) operation of the incinerator (see Section 6.3). Facility Management will perform 

additional analyses to augment the mandatory screening or to provide operational control as prescribed in 

Section 3.3, Supplemental Analyses. The parameters which constitute these categories are described below. 

The methods to be utilized in determining these parameters are identified in Appendix WAP-A (as required 

by 40 CFR 264.13(c)(1) and/or 35 IAC 724.113(c)(1)). Facility Management may waive specific Mandatory or 

Supplemental Analyses if performing the analysis presents a safety hazard in the laboratory as specified in 

Section 4.1.4. 

A summary of the analytical parameters within each category and their usage is provided herein. 

Analyses are not repeated for sequential activities or movement of the same waste within the facility unless 

required by changes in the waste's character. See Section 6.0 for a complete description of parameters 

performed in conjunction with process operations. The results of all tests and inspections described below will 

be maintained at the facility as part of its operating record for a minimum of three years after the testing has 

been performed. 

3.1 Mandatory Analyses 

Mandatory Analyses are basic fingerprinting procedures (key parameters) which are used to identify 

a waste and to ensure that the appropriate waste management technique can be utilized. In addition, they aid 

in liquid blending decisions and to determine the proper solid waste feed sequence prior to incineration. 

Mandatory Analyses: 

Provide the information concerning the waste which is pertinent to the safe storage, processing and 

incineration of the waste; 

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Provide Facility Management with data which can be used to evaluate the consistency of information 

provided by the generator. 

Incoming Mandatory Analyses are performed on the incoming waste shipment samples in order to make the 

final decision of whether or not the facility can manage a particular waste stream shipment (except as noted 

in Section 4.1.4) and determine if the waste shipment conforms to the identity of the waste as identified on 

the waste shipment manifest, and to the profile information. 

When necessary for profile purposes, select Mandatory Analyses may also be performed on a generator 

supplied sample if the generator supplied information is not sufficient (See Section 4.1.1). If an incoming waste 

conforms to the information provided in the profile, then the information gathered can be used to safely manage 

the waste. 

In accordance with 40 CFR 264.13(c)(1) and/or 35 IAC 724.113(c)(1), the parameters and associated 

rationale for the Mandatory Analyses are as follows: 

1. Physical Description (appearance) is used to determine the general physical properties 

of the waste (color, physical state, layering, turbidity, viscosity). This facilitates visual 

comparison of the sampled waste with prior waste descriptions or samples. 

2. Heating Value (BTU) is used to establish the proper blend characteristics, evaluate 

its suitability for incineration and develop appropriate packaging requirements. There 

are no minimum or maximum acceptance limits for incoming waste shipments based 

on heating value. Heating value of a particular blend is controlled by the incinerator 

feed blend (see Section 6.3). This testing does not apply to liquid decant drums which 

will be blended prior to incineration. 

3. Chlorine Content (CI) is used to establish the proper blend characteristics, appropriate 

container packaging requirements and/or evaluate potential impacts on the incinerator 

and/or pollution control equipment. This testing does not apply to liquid decant drums 

which will be blended prior to incineration. 

4. Radioactivity Screening is performed to detect radioactive materials above background 

levels (greater than 0.5 millirads per hour) and to ensure that mixed waste, as defined 

in the TWI Part B RCRA Permit is not accepted by the facility. 

5. Flammability Potential Screening is used to indicate the fire-producing potential of the waste. 

This testing can be applied to all wastes, liquids, semi-solids or solids. All incoming liquid 

material indicating a positive flammability potential will be stored as Class I flammable liquids, 

unless closed cup flash point is performed showing a flash point of greater than 100°F. 

6. Water Mix Screening is used to determine whether the waste has a potential to vigorously 

react when mixed with water, to form gases or other products, or whether it generates 

significant heat. This testing does not apply to wastes that are already in contact with excess 

water. 

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7. Cyanides Screening indicates whether the waste has the potential to produce hydrogen cyanide 

upon acidification below pH 2.0. It is not required if the pH of the waste is less than or equal 

to 2.0. 

8. Oxidizer Screening is used to indicate the absence or presence of strong oxidizing material. 

9. pH Screening is undertaken to indicate the pH and, in general, the corrosive nature of the 

waste. Full range paper is used for the initial screening of wastes. Waste accepted by the 

facility will, generally, be in the range of 2.0 to 12.5 pH units. liquid waste outside of this 

range may be analyzed for alkalinity/acidity. Based on the results or the chemical composition, 

the appropriate process code is specified. If the material exhibits corrosive properties as 

identified in technical literature vs. tank farm material of construction, corrosion testing may 

be performed to allow for storage, or it will be accepted as specialty feed material and injected 

directly into the incinerator without blending. 

10. Paint Filter Test is used to determine whether free liquids are present in a waste. It is not 

performed on free flowing materials. 

11. Sulfide Screening indicates whether the waste has the potential to produce hydrogen sulfide 

upon acidification below pH 2.0. It is not required if the pH of the waste is less than or equal 

to 2.0. 

3.2 Non-hazardous Waste Analyses 

Non-hazardous wastes will be sampled as described in Section 5.1 and tested for physical description, 

radioactivity screening, flammability potential screening, water mix screening, and pH screening (if liquid). 

Non-hazardous solid wastes will be sampled and analyzed, as described above, for heat content and chlorine 

content. Non-hazardous liquid waste streams will be sampled and analyzed, as described above, for 

compatibility testing prior to management in bulk storage tanks. If any of these screens are positive the 

material will be considered discrepant and all mandatory analyses completed (see Mandatory Analysis, Section 

3.1). 

3.3 Supplemental Analyses 

Supplemental Analyses are performed to further identify wastes and will be performed when needed 

as directed by Facility Management or as specified in the following rationale. 

Supplemental Analyses are conducted when the Mandatory Analyses indicate that further information 

is needed to confirm the waste or to properly store and/or process the waste. The analyses are performed as 

directed by Facility Management. The results of these analyses provide Facility Management with another level 

of confidence concerning the proper means of storage and/or processing. 

Some of these additional analyses utilize unique procedures and protocols formulated by TWI, which 

have been found to be preferable for waste identification. These analyses will meet CWM performance 

standards. Others are standard analytical techniques recognized by the U.S. EPA and ASTM. The parameters 

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which constitute the Supplemental Analyses are identified below, the methods to be utilized in determining 

these parameters are in Appendix WAP-A 

1. Containerized Storage Compatibility is used to ensure proper compatibility within containerized 

storage buildings. This testing applies only to containerized wastes which do not pass the paint filter 

test. The testing program will not apply to small quantity packaged chemicals, material repackaged 

or solidified, or other material exempted under 4.1.4 and 5.1.1. In the event that a compatibility is 

performed on materials which are indicated as incompatible per DOT HM181, the compatibility test 

will take precedence over the DOT hazard class grouping. 

2. Tank Farm Compatibility will be assessed by performing a liquid waste compatibility on the liquid 

waste received for bulk storage with a composite of the tanks and storage container within the 

containment system to which the new waste will be added. Containment area master composite will 

be made up once per week. The incoming material will be checked against this master composite. 

3. Gas Chromatography Scan is used to separate and identify certain organic compounds. 

4. Metals (e.g.. As, Be, Cd, Cr, Ni, K, Na, T i Pb, Hg, Se) identifies heavy metals concentrations in 

wastes to determine regulatory status of the waste. Inorganic mercury waste as specified in 35 IAC 

728. Table D, mercury high subcategory streams will be analyzed to ensure the mercury concentration 

is less than the LDR regulatory limit. 

5. Closed Cup Flash Point identifies ignitable liquid wastes for storage purposes. This test will be 

performed when the generator has not provided analytical data with the WPS. This test will also be 

performed to resolve non-conformance issues when; 

a) An incoming waste indicates a positive flammability potential; and 

b) Profile information indicates that the material should not exhibit a flammability potential; 

and 

c) The discrepancy cannot be resolved through discussions with the generator. 

6. Acidity/Alkalinity may be performed on liquid inorganic waste which exhibits a pH greater that 12.5 

or less than 2.0 to evaluate the processability of these wastes. 

7. Apparent Viscosity is an indicator of one of the feed characteristics to the incinerator. It is 

determined during profiling on liquids when the Physical Description indicates the waste is viscous or 

when analytical data is not provided by the generator on the WPS. 

8. Confinement Test is used to measure the magnitude and rate of heat generation from a material 

subjected to a programmed temperature increase under confined conditions. This test will be used 

as an indicator of the waste's explosion potential. For materials for which the Facility Management 

lacks explosivity information, either as provided by the generator, through the facility's previous 

experiences with the material, or in a review of standard reference materials (a bibliography of 

standard references available to the site is included as Appendix WAP-F) and Facility Management's 

WAP-10 REVISION 11 

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evaluation of the chemical structure of the compound fails to preclude an explosion potential for the 

material, the suspect material will be subjected to a Confinement Test. 

9. Liquid Waste Compatibility is used to determine if waste streams can be blended without causing a 

release to the environment. This test will be performed on all liquid wastes received for bulk storage, 

decant to bulk storage, or blending prior to incineration with all tanks within the containment system 

to which the new waste will be added. 

10. PCBs are nm to indicate whether PCBs are present in wastes and to ascertain their concentration. 

PCB analysis will be provided by the generator or analysis will be performed prior to profile decision 

approval. Incoming waste shipments will be subjected to PCB testing based on the criteria defined 

in CWM's PCB Suspect Analysis Policy. Materials containing PCBs above 50 ppm will not be 

accepted. Organic extractions will not be performed on oxidizing wastes because of the safety hazard 

involved. 

11. Chlorophenoxy Herbicides by HPLC is used to determine the presence of dioxin suspect compounds 

Silvex and 2,4,5-T (see Appendix WAP-C) at a level of 0.01% or greater subject to detection 

level/matrix interference. Suspect waste streams are identified by the TWI Dioxin Suspect Analysis 

Policy. 

12. Phenol Screening is used to determine the presence of dioxin suspect compounds pentachlorophenol 

(see Appendix WAP-C) at levels greater than 0.01% or greater, subject to detection level/matrix 

interference. Suspect waste streams are identified by the TWI Dioxin Suspect Analysis Policy. 

13. Ash Content is used to determine the percent ash in waste feeds to the secondary combustion 

chamber. This test is performed on liquid blends for injection in the SCC burners. 

14. Fluorine Content is used to determine the percent fluorine in waste feeds to the secondary combustion 

chamber. This test is performed on liquid blends for injection in the SCC burners. 

15. Bromine Content is used to determine the percent bromine in waste feeds to the secondary 

combustion chamber. This test is performed on liquid blends for injection in the SCC burners. 

16. Specific Gravity/Density indicates the density of the waste. This information is used to assure that 

the specific gravity of bulk liquids is less than the design specific gravity for the storage tanks (1.5). 

Other parameters not listed here may be added as required by changes in regulations, company policy, etc. 

See Figure 3.1 for a summary of analytical requirements. 

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FIGURE 3-1 

SUMMARY OF ANALYSIS 

INCOMING 

PARAMETER PROFILE WASTE 

Physios! l^sriptim X 

pH Screen X 

% 

Oxidizer Screen X 

B^l^activily Stoma % 

Flammability Potential Screen X 

Water M » <%) X 

Paint Filter Test X 

Wmt Valw 0Tm XiM 

Chlorine Content X(4) 

A^<totte**i $m 

Specific Gravity S(6) 

& 

GC Scan (3) S 

8 

Acidity/Alkalinity S 

Sulfide $*bb«& <1> X 

Liquid Waste Compatibility s 

$ 

Pentachlorophenol Screening (3) s 

C^Jwropheaw HerWcfctes HPLC 0) * 

Mercury s 

Fhiorme $ 

Bromine s 

Metals s 

Confinement Test s 

X = Mandatory Analysis (1) Does not apply to waste with pH <or =2 

S = Supplemental Analysis (2) Does not apply to waste already in 

contact with excess water. 

(3) Not performed on oxidizing waste. 

(4) Not performed on liquid decant drums. 

(5) Liquids only. 

(6) Bulk liquids only. 

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4-0 PROFILING PROCEDURES 

TWI has developed a series of control procedures to determine the acceptability of specific wastes 

for management at the facility. The profiling procedure dictates what information a potential customer must 

provide to enable TWI to carry out its responsibility to obtain information necessary to manage the waste. In 

accordance with 40 CFR 264.13(b)(5) and/or 35 HI. Adm. Code 724.113(b)(5) this facility requires, at a 

minimum, the generator to supply all the information required by 40 CFR 264.13(a)(1) and/or 35 DL Adm. Code 

724.113(a)(1) (see Section 4.1 for a discussion regarding the information and data to be supplied by the 

generator) necessary to characterize, treat, store or dispose of each waste stream. 

Profiling is the mechanism for deciding to reject or accept a particular type of waste-prior to its 

acceptance at the facility-based on the conditions necessary to maintain incinerator operations at a (normal) 

steady state, the limitations of existing permits, and its compatibility with other wastes being treated, stored 

or disposed at the facility. 

Prior to- accepting a waste at the TWI facility for treatment, storage or disposal, a determination has 

previously been made by the generator (and reviewed by TWI) that the waste is either: 

o a characteristic waste as defined in subpart C of 40 CFR 261 and/or subpart C, 35 Dl. Adm. 

Code 721, 

o a listed hazardous waste as defined in subpart D of 40 CFR 261 and/or subpart B, 35 Dl. 

Adm. Code 721, 

o a solid waste which is not a hazardous waste as defined in 40 CFR 261.4(b) and/or 35 Dl. 

Adm. Code 721.104(b). 

The generator's supplied characterization (Waste Profile Sheet (WPS), Figure 4-1 in Section 4.1) 

provides TWI with information concerning the distribution of waste components as well as the nature of the 

waste components. 

4.1 Procedural Requirements 

For each new waste stream that is a candidate for delivery to the facility, except for those special 

materials noted below in Section 4.1.4, the following procedures are implemented: 

4.1.1 Information Provided by Generator 

The generator will provide TWI with: 

(1) chemical and physical data requested on the Waste Profile Sheet (WPS), typical form shown 

as Figure 4-1. This information will be based on the following: 

o Analytical Data; the generator must provide any available analytical data to support 

the information provided on the WPS. At a minimum, the generator must provide 

the following; 

Flash Point (liquids only) 

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PCB 

Apparent Viscosity (liquids only) 

pH 

Radioactivity Screen 

Where the generator does not provide analytical data, for the above items, the data 

will be developed by TWI prior to waste profile approval. 

o For waste code information, existing or published data on the waste or on waste 

generated from similar processes; 

o Process and ingredient information. 

(2) a representative sample; if required (a representative sample may not be required by TWI 

if Facility Management determines that the profile documentation supplied by the generator 

gives sufficient information to maintain compliance with permit and operational constraints 

and that submittal of a sample would not aid in the disposal decision process. Also see 

Sections 4.1.4 and 4.1.5). Non-hazardous waste profiles for which the generator has 

provided analytical data to support this determination will not require a sample. 

(3) Certification that the representative sample when required for approval (see above) has been 

obtained using procedures identified in 40 CFR 261, Appendix I and/or 35 HI. Adm. Code 

721, Appendix A or equivalent methods. 

(4) Land Disposal Restriction (LDR) Notification/Certification Information and/or Data (40 CFR 

Part 268): 

(5) Material Safety Data Sheets, where available; 

(6) While not specifically required, generators are encouraged to provide other supporting 

documentation, including additional analytical results, product ingredients, etc. which will 

assist in the approval process. 

CWM maintains as part of its profiling information generator-supplied and CWM-developed 

information. This information may be accessed electronically or via hard copy. 

4.1.2 Waste Management Decision 

After evaluating the data supplied by the generator, Facility Management will determine the 

acceptability of the waste based on: (1) permit conditions; (2) the availability of proper waste management 

techniques and operational conditions necessary to maintain a steady state (normal) operation of the 

incinerator; and (3) storage and compatibility concerns. See Section 4.2 for a detailed discussion of the decision 

evaluation logic for profiling procedures. 

WAP-14 REVISION 11 

9/29/94 
4.1.3 Waste Re-evaluation 

In accordance with 40 CFR 264.13 and/or 35 HI. Adm. Code 724.113, a waste profile re-evaluation 

will be conducted when one of the following occurs: 

o A generator notifies TWI that the process generating the waste has changed; 

o The results of inspection or analysis indicate that the waste received at the facility does not 

match the identity of the waste designated on the accompanying manifest (or shipping paper) 

or profile documentation (See Section 5.2.3); or 

o Every five years. A waste profile re-evaluation along with a vigilant incoming load screening 

program is sufficient to ensure that wastes continue to be properly managed at the facility. 

For bullet items one and three above, this re-evaluation process consists of a review of the paperwork to 

ascertain that the analytical data is accurate and current and that it is sufficient to properly manage the waste 

as intended. The procedure typically involves comparing the current waste profile to the available results of 

routine inspection, sampling, and analysis obtained upon receipt of an incoming load of the waste stream. To 

augment this review, if existing analytical is not sufficient, the generator may be asked to review the current 

waste profile, to supply a new profile, and/or to submit a sample for analysis, or TWI may obtain a sample from 

a shipment of the waste. 

4.1.4 Exceptions to the Foregoing Requirements 

Exceptions to the foregoing requirements include the following special materials as determined by 

Facility Management: 

(1) Packaged chemicals and debris (e.g., glassware, syringe, lab coats, etc.), from laboratories, 

hospitals, household clean sweeps, manufacturing facilities, etc., including scintillation vials 

packed in accordance with Small Quantity Chemical Guidelines (SQCG's). Scintillation vials 

as certified by the generator to exhibit less than 0.05 microcurie/gram radioactivity 

(scintillation vials at this level may exhibit radioactivity above background but less than 0.5 

millirads per hour). For packaged chemicals, the generator will supply a packing list 

(Inventory) for each container (e.g., drums) specifying type and quantity of chemicals 

contained within. Compliance with the SQCG's and accuracy of the drum inventory provided 

to TWI for review must be certified by the technician packaging the waste through 

completion of the drum inventory sheet. This drum inventory sheet must be reviewed and 

approved for each container by the TWI Facility Management prior to acceptance at the 

facility. TWI will open and inspect the contents of randomly selected direct charge containers 

received from each packing organization to verify that the contents conform to the drum 

inventory. Drums containing scintillation vials will be screened to verify that they are not 

radioactive (as noted above). See Section 5.1.1(1) for a complete description of Incoming 

Waste Shipment procedures for small quantity chemical drums. Occasionally, TWI 

WAP-15 REVISION 11 

9/29/94 
determines that a particular material is not acceptable and so notifies the customer. If the 

customer agrees with TWFs determination the unacceptable material is removed from the 

container. These drums will be tracked on-site for the purposes of determining waste 

storage compatibility by manifest/profile/unique drum identification combination. 

(2) Empty containers as defined at 35 IAC 721.107(b), (e.g. empty fiber, steel or plastic drums 

or bags). These wastes will be visually inspected upon receipt. In addition to differences in 

physical appearance, these wastes will be determined to be nonconforming when they contain 

material in quantities greater than 3% of the total volume of the container or more than one 

inch of residue remains on the bottom of the container. 

(3) Pharmaceutical and other commercial products packaged in consumer quantities in their 

original untampered packaging. 

(4) Commercial products or chemicals: off-specification, outdated, unused of banned. These 

materials must be received in the original container or packaged as designated by TWI. 

(5) Aerosol cans and Lecture Bottles. 

(6) Controlled substances defined in 21 U.S.C. Section 802 regulated by the Federal 

Government such as cocaine and other drugs. These are typically generated by a 

pharmaceutical company, health care agencies or state or federal agency. 

(7) Potentially Infectious Medical Waste (PIMW) as defined by IEPA. 

(8) Wastes which are visually identifiable through an inspection process. Examples of these 

types of wastes are, batteries, cathode ray tubes, crushed glass, piping, filters and filter 

cartridges, wire or tubing, paper products, syringes, metal sheeting and parts, explosive 

components and devises. This list is not meant to be all inclusive, and may be expanded with 

IEPA approval. 

(9) Prior Agency Approval: Materials which do not fall into one of the other exemption 

categories, but present impractical sampling or analysis complications. Use of this exemption 

will be granted on a profile specific basis, with initial review by the IEPA field office 

(Collinsville). Profile approval will be subject to IEPA-DLPC Permit Section written (e.g. 

fax) approval. 

The requirement that a generator provide a representative sample is waived for these materials 

because they exhibit unusual or impractical sampling and analytical complications and are of such a nature that 

their contents are known in sufficient and reliable chemical and physical detail that sampling and analysis is 

not warranted. For these exceptions, the generator will supply TWI with chemical and physical characteristic 

information necessary for proper management of the waste and sampling is not required. The above wastes 

will be described on a WPS as shown in Figure 4-1 and accompanied by supporting documentation (e.g., drum 

inventory, Material Safety Data Sheets (where available), and other data made available by the generator), 

including information as to whether the waste is subject to the Land Disposal Restrictions of 40 CFR Part 268. 

WAP-16 REVISION 11 

9/29/94 
4.1.5 Standard Profiles 

Standard Profiles may be used for waste streams which are similar in physical and chemical 

characteristics, generated by similar industries or processes, consistent with the USEPA approach of assigning 

a listed waste code to similar process wastes. 

An analytical database will be developed for a specific Standard Profile based on analytical data from 

waste streams that are representative of wastes from similar industries, processes or historical data. CWM 

will review the database and determine whether the individual waste streams are sufficiently similar in physical 

and chemical characteristics to an established Standard Profile. The analytical database developed as discussed 

above will replace the requirement for a profiling sample (see Section 4.1.1) for each individual waste stream. 

Specific candidate waste streams which are identified as conforming to an existing IEPA approved 

Standard Profile will be managed under the existing disposal decision specific for that Standard Profile. 

4.2 Decision Evaluation Logic for Profiling Procedures 

The Facility Management is responsible for the profile evaluation decision (e.g., whether to approve 

the candidate waste for acceptance). The data obtained from the WPS (Figure 4-1), any analysis performed 

by the CWM Laboratory, and any other information provided by the generator or developed during the 

assessment of the waste is evaluated by Facility Management. The facility General Manager will designate 

written authority for profile decision approval to qualified individuals based on training, experience, and 

supervised decision reviews. See Figure 4-2 for required waste management decision information. 

Facility Management will apply technical experience and judgement to all the available information 

in order to reach a technical profile approval decision. At a minimum, the following criteria will be assessed: 

o Management methods available; 

o Conditions or limitations of existing permits and regulations; 

o Capability to manage the waste in a safe and environmentally sound manner; 

o WPS description of the process generating the waste; 

o WPS description of the chemical and physical properties of the waste; 

o Any additional documentation supplied by the generator, including information that the 

waste is subject to a Land Disposal Restriction of 40 CFR Part 268; 

o Results of Mandatory Analyses if applicable (see Section 4.1.1); 

o Results of Supplemental Analyses, as required, 

o MSDS recommendations (when available). 

A summary of particular data which, when observed on the WPS or during the Profiling phase, will 

subject the candidate waste stream to restrictions, special packaging requirements, or outright rejection from 

further consideration is provided as Appendix WAP-C. 

WAP-17 REVISION 11 

9/29/94 
A waste stream will be rejected during the profiling phase for the following reasons: 

o Incomplete or outdated information supplied by the waste generator which cannot be 

supplemented by the generator, 

o WPS information is inconsistent and the discrepancy cannot be resolved with the generator. 

Inconsistent information is that which is mutually exclusive based on scientific facts and 

principles (for example, WPS indicates that a waste containing 50% acetone is 

nonflammable). 

o Sample analyses and WPS information are inconsistent and the discrepancy cannot be 

resolved with the generator, 

o The facility is not permitted to treat, store, or dispose of the particular waste in question (for 

example, the waste is radioactive), 

o The facility does not have the capacity to treat, store, or dispose of the waste stream in 

question. 

o Facility experience with similar materials or standard reference materials (See Appendix 

WAP-F) indicates that this material cannot safely be incinerated by limiting size of charges 

or other processing controls. See Appendix WAP-C for Waste Acceptability Criteria. 

o Facility Management is not assured of the ability of the facility to safely treat and store the 

waste. 

The profile evaluation is concluded with documentation of the decision regarding the acceptability 

of the waste and the proposed method of management, including such special packaging requirements as may 

be required of the generator. The acceptability decision is embodied within the waste management decision. 

A master Waste Keceipt Analysis Document (WEAD) (See Figure 5-1) will also be prepared by completing those 

sections of the form which require information gathered during the profile process (generator name, profile 

number, results of profile analyses, decisions restrictions, etc.). A copy of this master WRAD will be made at 

the time the waste is scheduled to transmit profile information to operations and the laboratory for the 

Incoming Waste Acceptance process. 

WAP-18 REVISION 11 

9/29/94 
FIGURE 4-1 

GENERATOR'S WASTE MATERIAL PROFILE SHEET 

WAP-19 EEVISION 11 

9/29/94 
Zaze ? rir.-e d Classica l W a s - « Managsmsn- , Inc . 

WAST E PROFIL E Profil e • 

Check here i f this i s * Recertification LOCATION OF ORIGINAL 

•GENERAL INFORMATION 

,

!:. Generator Nana: Generator USEPA ID: 

2- Generator Address: Billin g Address: _ 

( ) Same 

3. Technical 

Contact/Phone: . 

4. Alternate " Billin g 

Contact/Phone: Contact/Phona: 

PROPERTIES AND COMPOSITIOH 

5. Process Generating Waste: 

6. Waste Na 

7A. Is this a USEPA hazardoua waata (40 CFR Part 261)? Yea (_) No (_) 

B. Identify ALL USEPA liste d and characteristic wasta coda nuabars (D,F,K,P,U): 

State Waata Codaa: 

8. Physical State 3 70F: A. Solid( J Liquid( J Both(J Gas(_) B. Single Layer ( J Multilayer ( J C. Free liq . ranga to % 

9A. pH: Ranga or Not applicable (_) B. Strong Odor (_);describe 

10. Liquid Flash Point: < 73F ( J 73-99F (_) 100-139F ( J 140-199F (_) >- 200F ( J N.A. ( J Closed Cup (_) Ope* Cup (_) 

11. CHEMICAL COMPOSITION: Lis t ALL constituents (incl . haloganatad organics) present in any concentration and forward analysis 

Constituents Range Unit Description * 

TOTAL COMPOSITION (MUST EQUAL OH EXCEED 100%): 

12. OTHER: PCBs i f yes, concentration ppa, PCBs regulated by 40 CT* 761 (J . Pyrophoric ( J Explosive (_) 

Radioactive ( ) Benzene i f "yes, concentration _ ^ ppa. Shock Sensitive (_) Oxidizer (_) 

carcinogen ( j infectious ( j othar Ai r Reactiv e ( ) Wate r Reactive~ ( ) 

13. If wasta subject to the land ban ft neata treataant standards, check hara: _ 6 supply analytical results whera applicable. 

SHIPPING INFORMATION 

14. PACKAGING: Bulk Soli d (_) Bulk Liquid (J Drum ( J Typa/Siza: ; Othar 15. .ANTICIPATED ANNUAL VWM s Units J Shipping Frequency: 

SAMPLING INFORMATION Sample Tracking Number: 

16a. Saapla source (drua, lagoon, pond, tank, vat, etc.): ; 

Data Sampled: Sampler's Name/Company: 

•16b. Generator*s Agent Supervising Sampling: 17. (_) Bo saapla. required (See instructions.) 

GENERATOR'S CERTIFICATION 

I hereby certif y that al l information submitted in thi s and al l attached documents contains true and accurate descriptions of 

this wasta. Any saapla submitted i s representative aa defined in 40 CFR 261 - Append!* I or by using an equivalent method. Al l 

relevant information regarding kno%#n or suspected hazards i n tha possession of tha generator has baan disclosed. I authorize 

CWM to obtain a saapla from any waata shipment for purposes of recartifIcation . 

Signature Mama and Titl e Date 
FIGURE 4-2 

WASTE MANAGEMENT DECISION 

WAP-20 BEVISION 11 

9/29/94 
Date 9/29/94 

Time 9»35x57 

WASTE MANAGEMENT DECISION 

Location of origina l 

Page . - i l 

I. Generator and Facilit y Information 

Decision Sit a 

Propoaad Management Facilit y 

Tracking #i Priorit y i 

Profil e # i ^ Date Received! 

Effectiv e Dates 

Generator i _____ 

Waate Category Codes 

Description s 

I I. Decision t o Deny Approval fo r Management of Waste 

Reason for Denying Approval 

Initia l Approval Name (print) Date 

Fina l Approval Name (print) Date 

b) Precaution Conditions or Limitations on Approval 

(2) Contracting Conditions 

(3) Sit e and Contracting Conditions 

c) Analytica l Requirements for Each Load 

d) Decision Expiratio n Date 

Initia l Approval Name (print) Date 

IV. Fina l Decision 

State any Additional Precautions, Conditions, or Limitations 

Fina l Approval Name (print) Date 
5.0 INCOMING WASTE SHIPMENT PROCEDURES 

In accordance with 264.13(c) and/or 35 HI. Adm. Code 724.113(c), each shipment of waste, upon 

arrival at the facility, will be inspected as defined herein before the initiation of any further activity. This 

serves two purposes. First, it compares the actual waste identity with that determined in the profile process 

and that listed on the waste manifest. If the waste conforms to the expected descriptions and properties as 

determined during the profile review, then the information obtained during profiling can reasonably be used 

as the basis for managing the waste which arrives at the facility. Secondly, it provides a second level of 

assurance that the contemplated waste management technique can be utilized. Other CWM personnel (or a 

CWM-approved laboratory) can provide the Mandatory and/or Supplemental Analyses required prior to or 

concurrent with the arrival of the load. Waste shipments that have arrived at the facility are considered to be 

in the receiving process until such time that Facility Management makes a final decision regarding waste 

acceptability; at such time the wastes are considered accepted. 

If the waste does not conform to the expected descriptions and properties as determined during the 

profile review (is found to be nonconforming), then the information obtained using the Mandatory Analyses and 

any Supplemental Analyses performed, will be utilized to manage the waste. 

All waste shipments which are subject to the Land Disposal Eestrictions of 40 CFR Part 268 and have 

been treated, exempted, varianced, or meet the appropriate treatment standard or prohibition without 

treatment must be accompanied by a form from the treater or generator, certifying that the treated, exempted, 

or varianced waste meets the appropriate treatment standard, prohibition, or variance (or that the untreated 

waste naturally meets the treatment standard or prohibition) and includes any applicable analytical data or 

reference to such data or documentation (in accordance with 40 CFR 268). Furthermore, all wastes which are 

subject to the land disposal restrictions and require treatment must be accompanied by a form from the 

generator (or treater) that (1) notifies that the waste contains prohibited constituents; (2) identifies the 

appropriate treatment standards associated with the material; and (3) includes any applicable analytical data 

or reference to such data (in accordance with 40 CFR 268). See Section 4.1.1 for a discussion regarding the 

information and data to be supplied by the generator. 

WAP-21 REVISION 11 

9/29/94 
5.1 Receiving Procedures 

Incoming waste shipment identification begins upon arrival of the waste at the facility. The 

inspection, sampling and analysis of the incoming waste will be performed in accordance with the 

methods/parameters described in Sections 2.0 and 3.0. 

In the case of container shipments not covered in the exceptions, each container in the shipment will 

have its contents visually inspected by obtaining a full depth vertical sample to verify that the contents are 

similar prior to compositing. The receiving technician will note physical state for each drum on the receiving 

documents (see Figure 5-1, Physical Description Worksheet), which the lab will compare to the profiled physical 

description of the waste. Incoming wastes will have its full depth vertical sample visually inspected for color 

and phase (liquid, solid, semi-solid). Drums of packaged chemicals will be randomly opened and inspected to 

verify that the drum is packed as identified in Section 5.1.1. 

Upon delivery, 10 percent of the containers from each waste profile within a shipment, will be 

randomly selected and sampled, according to Section 2.0. In the event that a single drum of a specific waste 

profile is received, that drum will be sampled. A mayimiim of five containerized shipment samples from the 

same waste profile may be composited prior to analysis, provided the individual samples are similar in physical 

appearance. 

For waste receivers over 80 drums, an additional single drum grab sample will be taken as part of 

the incoming analysis. The grab sample will be subject to normal receiving piandatory analysis. This grab will 

be compared to the profile data. 

Where containers are to be randomly selected for sampling or inspection (including packaged chemical 

drum inspection), the containers to be evaluated will be selected using a random number table, or a random 

number generator on a personal computer or programmable calculator. Drum numbers will be assigned to the 

drums in a shipment upon off-loading prior to inspection or sampling. The random numbers will be generated 

to establish which containers will be evaluated at this time. ~~ 

Container samples will be composited only with samples from the same profile which are of similar 

color and phase. In addition, if wastes from the same profile exhibit differences in physical appearance during 

the Mandatory Analyses and these cannot be resolved, (See 5.2.4) then all remaining containers will be sampled 

to determine which drums are conforming, unless a determination can be made from the container visual 

inspection. 

Samples from incoming waste shipments will be subjected to Mandatory Analyses (see section 3.0). 

All such samples will be retained for a period required to approve the waste for incineration. 

The results of the visual inspections and Mandatory Analyses will be documented on the waste 

receipt analysis document (WEAD), typical form attached as Figure 5-1. This form is used to document the 

profile evaluation data, the results of the Mandatory Analyses (see Section 3.1), and the determination of 

conformance/non-conformance (see Section 5.2). 

WAP-22 REVISION 11 

9/29/94 
5.1.1 Exceptions to Incoming Waste Analysis Procedures 

The following materials, which are defined in Section 4.1.4, will not be sampled upon arrival but, at 

a minimum, will be subjected to a visual inspection as described below. These materials are not sampled 

because they exhibit unusual or impractical sampling and analytical complications and because sufficient 

chemical and physical data has previously been obtained: 

1) Packaged chemicals and debris (see Section 4.1.4 for description). This inspection procedure 

will apply to those drums which are selected for verification of the drum inventory sheets 

(DIS). During the verification, these drums will be identified as conforming, non-eonforming 

and processable, or non-conforming and discrepant. The definitions and responses will be 

as follows: 

Conforming Drums: A drum that meets guidelines and all material -is identified and 

corresponds with DIS. Conforming drums will be processed. 

Processable Drums: A drum that is not conforming but sufficient information is available 

to determine its acceptability. The following are examples of processable drums: 

1. Missing DIS but DIS available in approval package; 

2. Material identified on DIS but not present in the drum; 

3. Broken bottle(s) with legible labels(s); 

4. Broken bottle(s) and label(s) destroyed, but material identifiable with logical 

deduction and DIS review; 

5. Extra containers of identified material; 

6. Extra identifiable and acceptable material; 

7. Extra materials consisting of PPE and job supplies (e.g., markers, absorbent 

bags, cardboard); 

8. Material on DIS present but quantities are incorrectly identified; 

9. Non-containerized compound but identifiable from DIS; 

10. Missing label but container type/size match DIS. 

Processable drums will be accepted and processed. The generator or packer of processable 

drums will be notified of the inaccuracies associated with the processable drum. The 

generator or packer will also be notified that the continued receipt of processable materials 

versus conforming, will not be tolerated and will result in the issuance of deterrent 

measures, up to and including banning the generator/packer from sending hazardous waste 

to TWI for treatment. 

WAP-23 REVISION 11 

9/29/94 
Discrepant Drums: A drum where insufficient information is available to determine 

acceptability of the drum or the drum contains unacceptable material. The following are 

examples of discrepant drums: 

1. One or more broken bottles where the contents cannot be determined; 

2. Unidentifiable material; 

3. Missing label and container does not match anything on the DIS; 

4. Unacceptable material in drum; 

5. DIS not available. 

The portion of the drum which is discrepant will be rejected. All non direct charge drums 

will be inspected during processing in the Specialty Processing Building. 

2) Empty containers as defined at 35 IAC 721.107(b). These wastes will be visually inspected 

upon receipt. In addition to differences in physical appearance, these wastes will be 

determined to be nonconforming when they contain material in quantities greater than 3% 

of the total volume of the container or more than one inch of residue remains on the bottom 

of the container or when the shipping container (overpack) has free liquids in more than the 

above quantities. 

3) Pharmaceutical and other commercial products packaged in consumer quantities in their 

original untampered packaging. TWI will open and visually inspect 5% of the incoming outer 

containers of these materials to verily that the shipment contains consumer packages. 

4) Commercial products or chemicals. TWI will open 5% but not less than one of the incoming 

containers of each incoming profile to ensure that the material is as described on the WPS. 

5) Aerosol cans and Lecture Bottles: These wastes will be visually inspected upon processing 

into burnable charges. 

6) Controlled substances defined in 21 U.S.C. Section 802. These types of materials will not 

be opened or sampled by TWI due to the regulations governing these materials. TWI will 

require an inventory from the packer of these materials as specified in the procedures 

outlined in Section 4.1.4. These materials are generated by a pharmaceutical company or 

health care agencies or state or federal agency. 

7) Potentially Infectious Medical Waste (PIMW) as defined by IEPA. 

8) Wastes which are visually identifiable through an inspection process. Wastes in original 

packaging will be subject to 5% inspection as per 5.1.1.4 above. Wastes which are not in 

original packaging will be subject to 100% visual inspection. Examples of these types of 

wastes are, batteries, cathode ray tubes, crushed glass, piping, filters and filter cartridges, 

wire or tubing, paper products, syringes, metal sheeting and parts, explosive components and 

devises. This list is not meant to be all inclusive, and may be expanded with local IEPA 

approval. 

WAP-24 REVISION 11 

9/29/94 
9) Prior Agency Approval: Materials which do not fall into one of the other exemption 

categories, but present impractical sampling or analysis complications. Use of this exemption 

will be granted on a profile specific basis, with initial review by the IEPA field office 

(Collinsville). Profile approval will be subject to IEPA-DLPC Permit Section written (e.g. 

fax) approval 

5.2 Incoming Waste Shipment Decision Evaluation Logic 

After a waste has been received by the facility, inspected, sampled, and analyzed in accordance with 

Sections 5.1, 2.0, and 3.0, Facility Management will review the profile information, the Mandatory Analyses, 

and the manifest to determine whether the material received conforms with the profile information and the 

manifest, and whether it can be safely managed at the facility. The major functions in the process are as 

follows: 

5.2.1 Waste Identification 

Facility Management will rely on one or more of the following sources of information to determine 

the identity of the incoming material together with any other available information: 

o Visual Inspection of the container contents, 

o Sampling. 

o Results of Mandatory Analyses. 

o Appropriate Land Disposal Restriction Notification/Certification Form, 

o Waste Manifest. 

The information gathered from the above sources will be compared with information taken from the 

following sources developed during profiling (see Section 4.1): 

o Waste Profile Sheet, 

o Results of any analyses. 

o Any additional documentation supplied by the generator, such as a Material Safety Data 

Sheet, product ingredient, etc. 

Specific criteria for waste comparison are shown on the WRAD (Figure 5-1). Comparisons will be 

documented on the WRAD. Determination of conformance with specific parameters will be determined as 

described in Appendix WAP-D. 

5.2.2 The Need for Additional Analyses 

Facility Management will perform additional analyses according to the criteria in Section 3.3 when 

manifest information or results of the Mandatory Analyses do not conform or are inconsistent with profile 

information (Le., if a waste is nonconforming as described in Appendix WAP-D or information gathered is 

mutually exclusive based on scientific facts and principles). 

WAP-25 REVISION 11 

9/29/94 
5.2.3 An Evaluation of Whether a Waste is Found to be in Conformance or Non-conformance 

The Facility Management must classify the waste as being in non-conformance if it is significantly 

different from the information shown in the profile paperwork or on the manifest, or differs in quantity from 

that indicated on the manifest, in accordance with 40 CFR 264.72 and/or 35 HI. Adm. Code 724.172. 

Three major criteria are used to arrive at this decision. They are: 

o For bulk wastes, variations greater than 10% in volume or, 

o For batch wastes (e.g., drums, bags, etc.), any variation in piece count (i.e., the 

number of pieces listed on the manifest or drum inventory does not agree with 

the number of pieces received) or, 

o If inspection or analysis of any waste determines significant differences exist 

between the physical properties of the waste and the descriptions on the profile 

and/or shipping paperwork. Significant differences are: 

1) Variations from conformance criteria as described in Appendix WAP-D or; 

2) Analytical results which are mutually exclusive based on scientific facts and 

principles from the waste description on the manifest or profile paperwork. 

5.2.4 An Evaluation of Whether Wastes Found to be in Non-conformance can be Accepted or 

will be Rejected 

If the information collected in (1) and (2) above indicates that one or more of the incoming waste 

evaluation criteria is significantly different from the manifest or profile information, Facility Management must 

undertake to account for the apparent observed difference. This evaluation will include one or more of the 

following: 

o Review of sampling methods to verify representative sampling; 

o Supplemental Analysis, as specified in Section 3.3; 

o Further evaluation of the waste profile and incoming analytical or discussions with the 

generator. 

If information gathered during this evaluation can resolve the discrepancy, the resolution of the 

discrepancy will be documented on the WRAD along with the results of the incoming waste analysis. 

If discrepancies in incoming waste evaluation criteria cannot be resolved, the waste will be considered 

non-conforming and the results documented on the WRAD along with the results of the incoming waste 

analyses. 

Wastes found to be in non-conformance will either be rejected or re-profiled for possible acceptance 

by the facility despite the variance. 

Wastes that are rejected during unloading may be placed back on the truck for transportation, as 

arranged with the generator. Wastes that are rejected after the transporter has departed the facility are held 

WAP-26 REVISION 11 

9/29/94 
in a storage area holding only compatible materials, based on the Mandatory Analyses results. A record is kept 

of the location of all drums on-site at all times. 

Alternatively, TWI may re-evaluate the waste to determine whether the waste material as shipped 

(i.e., inconsistent with WPS and/or manifest data) can be handled at the Facility. If the facility determines that 

the waste can be managed consistent with permit requirements, the shipment will be managed. The profile 

information will be amended prior to acceptance of the next shipment. Wastes to be re-profiled will be subject 

to the profile process requirements as set forth in Section 4.0. 

If the re-evaluation procedure indicates that the waste can be accepted and the generator concurs, 

a revised waste management decision will be prepared by Facility Management, if the method of management 

changes. 

If a discrepancy cannot be resolved within 15 days of shipment receipt, the IEPA will be notified, in 

writing, of the discrepancy and of attempts to reconcile it. Waste will be rejected for the following reasons: 

o Facility Management for any reason determines that it cannot manage the material in 

compliance with all regulations, permit requirements, and standards of health and safety, 

o A manifest discrepancy (or non-conformance) cannot be resolved to the 

generator's and TWFs satisfaction using the procedures outlined above, 

o The generator's/transporter's paperwork is not in order and the problems cannot 

be corrected upon arrival, 

o Storage space in container storage areas or in on-site bulk liquid storage tanks is not 

available to provide segregation of incompatible materials, 

o A liquid waste is not compatible (per the Liquid Waste Compatibility Test) with waste 

already in storage and no segregation or other management method is available. 

Rejected wastes will be picked-up by the generator or by a permitted transporter to be returned to 

the generator's facility or transported to an alternate hazardous waste treatment, storage, or disposal facility. 

WAP-27 REVISION 11 

9/29/94 
FIGURE 5-1 

PHYSICAL DESCRIPTION WORKSHEET 

AND 

WASTE RECEIPT ANALYSIS DOCUMENT 

WAP-28 REVISION 11 

9/29/94 
T WI LABORATORY ANALYSIS REPORT 

PROCESS COOE: 

( ) PCB ANALYSIS REQUIRED 

( ) VERIFY BURNABLE CONTAINERS 

( ) VISUAL NSPECTION ONLY 

( ) MERCURY ANALYSIS REQUIRED 

( ) DIOXiN PRECURSOR ANAL. REQUIRED 

RECEIVER No. 

DRUM STORAGE COMPATAEMLrTY 

MANIFEST No. ________ _ 

PROFILED DOT HAZARD CLASS: 

No. of DRUMS: 

DATE: RESULTS: PASS: FAIL:. 

SAMPLER SIGN: 

SAMPLE NUMBER PROFILE CONFORMS 

Drum No. YES NO DATE ANALYST 

No. of torn 

"

:

."-..^::in::H: - • 

No. of torn u:::: _ - 1 = :::H:HH:-H: 

- • 

Fret Liquid (%) tH:s:::H::H 

Pump** 

iiiiiii 

iiiiiii 

iiiiiii iiiiiii §188 

Color 

iiiiiiii 

:ir.!ti 

iiiiiiii 

::S:::H:iH: 

Turtftfty 

Apparent \Aecotty 

Physiul Stats S::=::n::n: 

WtfwRMCtMty 

Rsdhtion Screen 

Oridtanr Screen - E - *- = - ~ 

Cyanide Screen 

:!::=::::::•:: 

SuNde Screen 

=

 -

Flem. Pot Scmn 

pH SCTMfl 

SoecMc GreMfcy 

Incidental Odor 

Paint Fftsr Test 

BTIVLB 

H Chlorine •••iHHEjiiSnrrHH:: 

PCB-tQC 

PCB's Screen 

Mercury 

Fta**iPafe*CCFP 

ACCEPT / REJECT ANALYTICAL COMMENTS: 

PROFILE REVIEWED FOR APPENDIX \*JAP-C CONSTITUENTS BY: DATE: 

PROFILE & HANOLING COMMENTS: 

THKrafMrthMbmprap ^fortweadu ^ No ta^gCTfcgcn twining ntti*wU* v wnt*jk* 
PHYSICAL DESCRIPTION WORKSHEET 

RECEIVER t DATE 

PBOFILE I i OF CONTAINERS 

DRUM # SIZE COLOR/DESCRIPTION %FULL %S0L %LIQ 

1 

2 

3 

4 

5 •• 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 
6.0 PROCESS OPERATIONS PROCEDURES 

Each movement of a waste within the facility, during which any change in its characteristics may 

occur, makes it subject to additional inspection, sampling and analyses to determine appropriate handling and 

management of the waste. Many of the analyses needed for the treatment, storage, and disposal functions are 

performed during incoming waste shipment identification. These are not repeated unless it is known or 

believed that the waste characteristics have changed during storage. 

Existing and anticipated operations at the facility, for which current and periodic sampling and 

analyses is important, include the following: 

Storage/Blending 

Decanting 

Incineration 

The analytical procedures for each of these are described separately below. 

6.1 Storage 

Before any wastes are placed into a storage unit, Facility Management will assess the compatibility 

of the waste with the storage unit materials of construction and with wastes already stored therein. 

6.1.1 Waste in Containers 

Containerized wastes are stored with respect to ignitibility, reactivity and compatibility. 

Compatibility shall be determined consistent with DOT HM-181 guidelines as summarized in the "Segregation 

Table for Hazardous Materials" listed in 49 CFR 177.848 (see Appendix WAP-G). Based on the initial DOT 

hazard class determination and analysis of the waste, the drummed waste will be segregated according to 

compatibility. These materials will be separated from incompatible materials by storage in segregated bays 

within the drum storage buildings. This is accomplished by the data from the WPS, Mandatory Analyses, and 

Supplementary Analyses requested by the Facility Management. Compatibility segregation will not apply to 

material which have been repackaged, generated, or solidified at TWI. 

To further verify that wastes are being properly categorized, TWI will institute a program of 

Containerized Storage Compatibility Testing. Compatibility will be assessed by performing a liquid waste 

compatibility on the waste received for container storage as outlined in Appendix WAP-A. The testing program 

will not apply to small quantity packaged chemicals or other material exempted under 4.1.4 and 5.1.1. In the 

event that a compatibility is performed on materials which are indicated as incompatible per DOT, the 

compatibility test will take precedence over the DOT segregation system. 

6.1.2 Waste in Tanks 

Liquid wastes delivered in bulk form (e.g., tank trucks, railroad tank cars), or pumped from drums, 

are typically placed in bulk storage tanks prior to incineration. Prior to transferring any waste into a storage 

WAP-29 REVISION 11 

9/29/94 
tank, the compatibility of the waste with the material already in the tank and the tank materials of construction 

will be determined by a liquid waste compatibility test (see Appendix WAP-A). In addition, tank farm 

compatibility will be assessed by performing a liquid waste compatibility test on the liquid waste received for 

bulk storage with a running composite of the tanks within the containment system to which the new waste will 

be added. 

6.1.3 Bulk Solids Storage 

Bulk solids will be managed as follows for unloading into the bulk solids pits: 

1) Only material which passes the paint filter test can be placed into the storage pits. 

2) The BTU and chlorine contents used will be either: (a) The higher value of the 

current pit or the incoming material, or (b) The material will be sampled after 

mixing and the sample will be analyzed for BTU and chlorine. 

6.2 Decanting 

In the decanting process, liquid wastes are decanted from drums or other small containers into larger 

bulk storage units. The applicable Mandatory Analyses will be performed on wastes to be decanted 

Prior to decanting, a Liquid Waste Compatibility Test and specific gravity test on a volume weighted 

sample will be performed to ensure that wastes to be bulked together are compatible. A volume weighted 

sample is a volume proportionate composite of the intended decant liquids. 

6.3 Incineration 

In the incineration process, liquid, semi-solid and solid wastes are destroyed by high temperature 

thermal oxidation. The resulting streams include combustion gases that are scrubbed to remove H Q and 

particulates, and other treatment residues (Le., ash, slag and scrubber sludge, scrubber solids (bag house dust) 

that are further managed. 

The treatment sampling/analysis program for incineration may be divided into two segments, each 

with a specific purpose: 

o Pre-treatment analyses confirm that the waste falls within the facility permit and operating 

constraints and allow fine tuning of the process operational constraints; 

o Treatment Residue Evaluations confirm successful treatment and that the characteristics of 

the process effluent are such that it can be sent to the nest step (discharge, disposal, or 

further treatment) based upon permit or process constraints. Residues from on-site 

treatment of land disposal restricted wastes will be analyzed and/or evaluated, as needed, 

against the appropriate treatment standards or prohibitions. Any residues or wastes sent 

off site for storage, further treatment, and/or disposal will have appropriate notification 

forms (in accordance with 40 CFR Part 268). 

The application of these segments is discussed below. 

WAP-30 REVISION 11 

9/29/94 
The application of these segments is discussed below. 

6.3.1 Pre-treatment Analyses 

All wastes fed to the incinerator are blended to meet permit constraints and to maintain steady state 

(normal) operation of the incinerator. Liquid waste is blended in bulk tanks prior to incineration. Pretreatment Analyses (6.3.1 numbers 1-6) are optional for liquid waste in tanks which will imdergo further 

blending prior to incineration. Prior to incineration, a sample is drawn from the tank to be fed and analyzed 

for the following parameters: 

1. Heat Value - Heat value is measured to control the feed rates of waste fed into the 

incinerators. The mayi'mnm heat value which can be burned per hour is established in the 

operating permit. 

2. Ash Content - Ash content is measured to control percent ash of waste fed into the 

secondary chamber waste burners of the incinerators. The maximum ash content for waste 

fed into the secondary chamber is established in the operating permit. Where the permit 

has not established a limit, this analysis will not be performed. 

3. Total Chlorine Content - Chlorine content is measured to control the percent chlorine in 

waste fed into the incinerators. The maximum chlorine content for waste fed into the 

incinerator is established in the operating permit. 

4. Fluorine Content is measured and used in conjunction with chlorine and bromine content to 

determine the halogen content in waste feeds to the secondary chamber waste burners of 

the incinerators. The maximum halogen content for waste fed into the secondary chamber 

is established in the operating permit. 

5. Bromine Content is measured and used in conjunction with chlorine and fluorine content to 

determine the halogen content in waste feeds to the secondary chamber waste burners of 

the incinerators. The maximum halogen content for waste fed into the secondary chamber 

is established in the operating permit. 

6. pH Screen is used to protect the integrity of tank farm materials of construction and provide 

management data for proper blending. 

7. Specific Gravity - This information is used to assure that the specific gravity of bulk or 

decant composite liquid is less than the design specific gravity for the storage tanks (s.g. = 

1.5). 

The permit operating values were established through a trial burn. The permit operating values may 

be changed if it is demonstrated through a trial burn that the new permit guidelines allow the incinerator to 

operate within the permit constraint and at a steady state (normal) operation. 

WAP-31 REVISION 11 

9/29/94 
The Facility Management will review the blend analyses to assure permit compliance and to assure 

that the blend will allow steady state (normal) operation of the incinerator. The blend will be readjusted 

whenever necessary to meet all permit specifications. This is accomplished through tank-to-tank blending with 

additional wastes. A Liquid Waste Compatibility Test will be performed prior to all tank-to-tank transfers of 

liquid waste. This new blend is then tested for the blend parameters, which are used to determine optimum 

blend characteristics as mentioned in the previous paragraph. 

Containerized waste is sequenced for incineration through careful indexing of container feed. The 

parameters necessary for selection of proper feed sequence (Heat Value, Chlorine Content) are evaluated based 

on the Mandatory Analyses. For the materials identified in Section 5.1.1, the values of the above parameters 

are categorized based on physical and chemical composition information obtained per Section 4.1 and 5.1. 

Container feed sequences reflect an ongoing evaluation of operating experience. 

6.3.2 Treatment Residue Evaluation 

Post-treatment analyses and evaluation will confirm successful treatment and that the characteristics 

of the process effluent are such that it can be sent to the next step (discharge, disposal or further treatment) 

based on permit or process constraints. In accordance with 40 CFR 268.7(b), residues (or wastes) resulting 

from on-site treatment of land disposal restricted wastes are analyzed and/or evaluated, as needed, against the 

appropriate treatment standard (e.g., Constituent Concentration in Waste Extract (CCWE) values) or 

prohibition. The incineration process results in the generation of the following residues: ash, slag and scrubber 

system solids. Each residue has been thoroughly evaluated to develop a sampling frequency that is consistent 

and independent of the original wastes accepted for incineration. Wastes or treatment residues sent off-site 

for further treatment will be accompanied by the appropriate notification (or certification) forms. 

Incinerator ash and slag generated in the rotary kiln and dry scrubber solids generated in 

incineration units numbers 2, 3 or 4 are sampled, analyzed and evaluated on a regular basis (See Appendix 

WAP-B, Section 2.2.1) in accordance with analytical procedures required to analyze against the appropriate 

treatment standard or prohibition (See Appendix WAP-B). 

Incinerator ash generated in the fixed hearth incineration units is either sampled, analyzed and 

evaluated on a load-by-load basis or is retreated and subsequently evaluated. 

The Facility Management will review the analytical results and determine the disposition of the 

treatment residue. If the analytical results meet the appropriate treatment standard (e.g., CCWE value), the 

treatment residue is then approved for shipment. Each shipment is accompanied with the following 

documentation: 

Waste Manifest; 

Land Disposal Restriction Treatment Certification; 

Analytical Report or reference to such analytical data. 

WAP-32 REVISION 11 

9/29/94 
In the event that the analysis does not meet the appropriate treatment standard (Le., CCWE values), 

the Facility Management will investigate the sampling procedure and the analytical procedure to ensure no 

contamination. Two additional samples will be submitted for analysis of the parameters which exceeded 

treatment standards in the first rotmd of analysis. If the second analyses pass, the residue will be approved 

for disposal. If the source of the contamination can be determined, it will be documented. However, if the 

second analyses does not meet the appropriate treatment standard (i.e., CCWE values), TWI will retreat the 

residues in order to meet the appropriate treatment standard (i.e., CCWE values). Alternatively, TWI may 

forego additional sampling and analysis and choose to retreat the residue which did not initially meet the 

treatment standard. 

WAP-33 REVISION 11 

9/29/94 
7.0 QUALITY CONTROL POLICY 

TWI has developed a program of quality control practices and procedures to ensure that precision 

and accuracy are maintained throughout all of its laboratories. All site laboratories are required to participate 

in this program. Contract laboratories employed by the company are subject to inspection and audit while 

performing analysis for CWM. A review of the contract laboratory is conducted to ensure that the quality 

control of CWM data is maintained. 

The quality control program is based on "Handbook for Analytical Quality Control in Water and 

Wastewater Laboratories" EPA, March 1979. Good laboratory practices which encompass sampling, sample 

handling, housekeeping and safety are maintained at all laboratories. The following practices must be 

implemented at all site laboratories: 

All instrumentation must be evaluated through the use of an instrument check standard. 

Divergence from acceptable benchmark criteria requires correction. The instrument check 

standard results are recorded. The record may also contain evaluation parameters, 

benchmark criteria and maintenance records. 

Eeagent blanks are typically prepared with each batch of samples and analyzed to ensure 

sample contamination has not occurred. If blank analyses do not fall within acceptable limits, 

modification of reagents or modification of the analytical method is implemented. 

A sample is analyzed in duplicate typically for each twenty samples being analyzed for a 

particular parameter. A blind duplicate sample will be submitted to the laboratory on a 

monthly basis. Results of these duplicate analyses will be reviewed for consistency. 

A quality control solution or sample material will be analyzed at least once for each day or 

each batch run to show that calibration and standardization of instrumentation is within 

acceptable limits. This procedure informs the laboratory that prescribed precision and 

accuracy are being maintained Results of these analyses are reported for review. 

Fortifications are employed to monitor recoveries and maintain extraction and/or 

concentration techniques at acceptable levels. This procedure provides information about 

the effect of the sample matrix on the analyte in question. Typically, a ratio of one 

fortification for each twenty samples analyzed will be maintained. Usually, the same sample 

used for the duplicate analysis will be fortified. 

WAP-34 REVISION 11 

9/29/94 
When available, reference materials from the National Institute of Standards and 

Technology, or reference materials from any other recognized source, will be obtained and 

analyzed according to normal laboratory methodology to indicate accuracy of the methods. 

These materials will be analyzed at least quarterly if the parameter has been performed 

during that quarter. Reference materials are not required for screening methods. 

All CWM laboratories participate in "round robin" sample analyses. These samples will be 

submitted by the QA/QC Group and will be for the analysis of normal parameters. Results 

must be reported to the group. Digressions from the norms established by the majority of 

laboratories participating will be investigated and corrected. 

At least one sample per month is sent to a CWM designated laboratory or a designated and 

approved contract laboratory for parallel analyses. These split samples or a report of both 

results are sent to the Quality Control Unit when an outside laboratory is employed. 

Samples sent to the designated laboratory will be logged in and analyzed without analysts' 

knowledge of site lab results. 

- The facility reports the following information on a monthly basis: 

o Number of samples analyzed 

o Number and results of duplicates 

o Number and results of fortifications 

o Instrument used 

o Frequency of occurrence for quality control check sample within acceptable 

limits 

o Mean and standard deviation of analyte in question. 

The facility also reports intra-lab and round robin results as they occur and references 

material analysis at least quarterly. 

A written copy of any third party contract laboratory's quality control procedures is submitted to 

CWM prior to approval A quality assurance inspection is conducted to ensure that proper records and 

documents are present and maintained. All laboratories are subject to inspection and audit of all procedures 

while under contract to CWM. A review of the contract laboratory is conducted to ensure that the quality 

control is being maintained. 

WAP-35 REVISION 11 

9/29/94 
APPENDIX WAP-A 

ANALYTICAL PROCEDURES 
APPENDIX WAP-A 

ANALYTICAL PROCEDURES 

The following analytical procedures are designed to identify or screen waste. They are used by CWM, 

based upon its operating experience, as rapid but effective means for establishing key decision parameters 

pertinent to proper waste management. The analyses described in the sections below are based on ASTM and 

"Standard Methods" approved by EPA or are based on procedures and protocol formulated by CWM and meet 

CWM performance standards. Analytical procedures not listed below may be added as necessary with prior 

IEPA approval. 

It should be noted that the information presented in this appendix is generic in character. Therefore, 

certain test methods are discussed which may pertain to treatment or disposal processes that are excluded from 

the facility for which the foregoing waste analysis plan is presented. 

I. UNIQUE ANALYTICAL PROCEDURES 

The following analytical procedures have been found by CWM to provide important quantitative information 

pertinent to certain processes. In some cases, these tests have been developed by CWM to provide information 

not available from "Standard Methods" in Section II which follows. In other cases, these tests are substituted 

for "Standard Methods" where they provide sufficient equivalent information. 

Bench-Scale Treatment Evaluation - Samples of wastes are combined with samples of other wastes or reagents 

at predetermined ratios. Further testing may be required in order to confirm that the desired reaction has 

occurred. 

Chlorophenoxy Herbicides by High Performance Liquid Chromatography (HPLC) - This method (CWM 92-78) 

is for the analysis of 2,4-dichlorophenoxyacetic acid (2,4-D), 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), and2,4,5-

trichlorophenoxypropionic acid (Silvex) in liquids and solids using HPLC/UV. The chlorophenoxy acids and 

esters are hydrolyzed to their respective salts by heating and stirring the sample with aqueous alkali The salts 

are then converted to their respective acids by the addition of HCL. The aqueous solutions of the free acids 

are then analyzed using HPLC using ultraviolet detection. 

Dissolved Sulfides - An aliquot of waste is mixed with distilled water. The solution/slurry is filtered through 

filter paper and the resultant filtrate is then analyzed for sulfide. Saturated antimony potassium tartrate and 

1:1 hydrochloric acid are added and the color produced is visually compared with standards. 

WAP-A-1 REVISION 11 

9/29/94 
Heat Value by Near Infrared Reflectance (NIR) Spectroscopy - Heat of combustion is determined by Near 

Infrared spectroscopy in a diffuse reflectance mode by placing a properly mixed sample in a diffuse reflectance 

cell. The instrument produces NIR absorbance spectrum which are converted to a heat of combustion value 

using a previously defined calibration curve. The method first screens for samples to extract qualitative 

spectroscopic features from the NIR spectra and then produces quantitative data for heat of combustion using 

multivariate calibrations. 

Metals Screen by X-Rav Fluorescence (XRF) - Waste samples may be prepared, if necessary, by grinding to a 

specified mesh size. The prepared sample is placed in a sample holder and positioned for reading. Instrument 

output identifies the presence of several metals for screening purposes. Semi-quantification of selected metals 

is then possible relative to matrix matched standards. 

Microwave Aided Digestion - A portion of sample is weighed into an appropriate microwave digestion vessel and 

digested using a mixture of nitric and hydrochloric acids. The vessel is heated in a microwave oven using 

programmed steps to minimize the possibility of venting. After cooling, the contents are diluted to volume, 

filtered and analyzed by the appropriate method. 

Organics Screen by Immunoassay - A portion of the waste sample is prepared for immunoassay screening 

(SW-846 4010) by using appropriate separation procedures (e.g., extraction, filtration, and/or thin layer 

chromatography). The extract is then mixed and incubated in a step-wise process inside antibody-coated tubes. 

The mechanics of mixing, incubating and measuring takes about 30 minutes and results in a color change in 

each tube. The color development is inversely proportional to the concentration of the antibody-specific 

analyte(s) of interest, e.g., herbicides, pentachlorophenol (PCP), pesticides, polyaromatic hydrocarbons (PAHs), 

or total petroleum hydrocarbons (TPHs). 

PCB Screen by Immunoassay - A portion of the waste sample is prepared for immunoassay screening 

(CWM 93-81 and 94-82) by performing an extraction with methanol followed by filtration. The sample extract 

is then mixed and incubated in a step-wise process inside the antibody-coated tubes. The mechanics of mixing, 

incubating and measuring takes about 30 minutes and results in a color change in each tube. The color 

development is inversely proportional to the concentration of PCBs and is detected by a photometer. 

Percent Acidity - Results are reported as percent of CaC03 equivalent or the particular specific species if 

known. 

Percent Alkalinity - Results are reported as a percent of the specific alkaline species (e.g., CaOH, NaOH, etc.). 

WAP-A-2 REVISION 11 

9/29/94 
Quick Leach Extraction Procedure - A designated amount of sample is mixed with the appropriate extraction 

fluid and stirred for a designated time period. After filtration, the pH and/or metals content are determined 

using the appropriate approved methods. 

Radioactivity Screen - A sample of waste material is passed by a geiger counter or survey meter. Radioactivity 

levels above background are noted, recorded and investigated 

Solvent Screen - Uses "standard methods" tailored to the compound class being analyzed. 

Tank Farm Compatibility - Assessed by performing a Liquid Waste Compatibility Test on the liquid waste 

received for bulk storage with a composite sample of the tanks within the containment system to which the 

waste will be added. Containment area master composite will be made up once per week. The incoming 

material will be checked against this master composite. 

Viscosity - The viscosity of the material is visually evaluated using water as a reference for low viscosity. 

Viscosity is reported as low, medium, high or non-flowable, etc. 

Containerized Storage Compatibility - Will be assessed by performing a Liquid Waste Compatibility Test on 

the waste received for container storage as follows: 

a The test program applies only to material that fails the paint filter test. 

b. A master composite for each of the DOT hazard class categories will be maintained at the site. 

c. The master composite will be made up initially by adding 100 mil. of each receiver in the category 

to an appropriately sized container. 

d. When the need for compatibility verification has been determined, a compatibility test will be 

performed with the appropriate DOT hazard class category. 

e. The compatibility test will be performed as follows: 

1. In order to ensure that the master composite represents the actual plant-wide inventory in 

each category, the master composite will be maintained in an appropriately sized container. 

2. A 100 mil sample of the incoming receiver will be checked with a 100 mil sample of the 

appropriate DOT hazard class master composite using the liquid compatibility test. 

3. If the receiver passes the compatibility test, the entire 200 mil mixture is added to the 

master composite. The receiver is then approved to be stored within any of the existing 

bays containing drums of that DOT hazard class category. 

4. If the receiver fails the compatibility test, the sample will not be added to the master 

composite. 

5. The receiver will be re-tested against one of the remaining DOT hazard class categories. 

WAP-A-3 REVISION 11 

9/29/94 
6. If the receiver is not compatible with any existing DOT hazard class master composite, the 

drums will be segregated in storage until such time that they can be moved directly to a 

process area for treatment. 

The testing program will not apply to small quantity packaged chemicals, material that has been repackaged 

or solidified, or other material exempted under 4.1.4 and 5.1.1. In the event that a compatibility is performed 

on materials which are indicated as incompatible per DOT hazard class, the compatibility test will take 

precedence over the DOT hazard class system. 

n . STANDARD ANALYTICAL PROCEDURES 

PARAMETER METHOD REFERENCE 

Sample Work Up Techniques: 

Inorganic Techniques 

Acid digestion procedure for flame atomic 

absorption spectroscopy 

Acid digestion procedure for furnace 

absorption spectroscopy 

Acid (Parr) Bomb digestion 

Acid digestion of oils, greases, or waxes 

Dissolution procedure for oils, greases, 

or waxes 

Acid digestion of sludges 

Alkaline digestion (for solids) 

Organic Techniques 

Separatory funnel liquid-liquid extraction 

Continuous liquid-liquid extraction 

Acid-base clean-up extraction 

Soxhlet extraction 

Sonication extraction 

Alumina Column Clean-up and Separation of Petroleum Wastes 

Flurosil Column Clean-up 

Silica Gel Clean-up 

Sulfur Clean-up 

Inorganic Analytical Methods: 

Inductively Coupled Plasma Atomic Emission 

Spectroscopy (ICP) 

Antimony 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Arsenic 

Atomic absorption, furnace method 

Atomic absorption, gaseous hydride method 

1-3010 

8-84-07; 1-3020 

8-91-61; 3-E886; E926; 6-Bulletin 4745 

1-3030 

1-3040 

8-84-08; 1-3050 

1-3060 

8-84-22; 1-3510 

1-3520 

1-3530 

1-3540 

1-3550 

1-3611 

8-84-22; 1-3620 

1-3630 

8-84-22; 1-3660 

1-6010 

1-7040; 4-204.1 

1-7041; 4-204.2 

8-84-10; 1-7060; 4-206.2 

1-7061; 4-206.3 

WAP-A-4 REVISION 11 

9/29/94 
PARAMETER METHOD REFERENCE 

Barium 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Beryllium 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Cadmium 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Calcium 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Chromium 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Hexavalent chromium: Co-precipitation 

Hexavalent chromium: Colorimetric 

Hexavalent chromium: Chelation-extraction 

Copper 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Iron 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Phenanthroline method (ferrous) 

Lead 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Magnesium 

Atomic absorption, direct aspiration method 

Manganese 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Mercury (manual cold-vapor technique) 

In liquid waste 

In solid or semi-solid waste 

Nickel 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

Selenium 

Atomic absorption, furnace method 

Atomic absorption, gaseous hydride method 

Silver 

Atomic absorption, direct aspiration method 

Atomic absorption, furnace method 

1-7080; 4-208.1 

1-7081; 4-208.2 

1-7090; 4-210.1 

1-7091; 4-210.2 

1-7130; 4-213.1 

1-7131; 4-213.2 

1-7140; 4-215.1 

4-215.2 

1-7190; 4-218.1 

1-7191; 4-218.2 

1-7195 

1-7196; 2-3500CrD 

1-7197; 4-218.4 

1-7210; 4-220.1 

4-220.2 

1-7380; 4-236.1 

4-236.2 

2-3500FeD 

1-7420; 4-239.1 

1-7421; 4-239.2 

1-7450; 4-242.1 

1-7460; 4-243.1 

4-243.2 

8-84-12; 1-7470 

8-84-05; 8-84-12; 1-7471 

1-7520; 4-249.1 

1-7521; 4-249.2 

8-84-13; 1-7740; 4-270.2 

1-7741; 4-270.3 

1-7760; 4-272.1 

1-7761; 4-272.2 

WAP-A-5 REVISION 11 

9/29/94 
PARAMETER METHOD REFERENCE 

Thallium 

Atomic absorption, direct aspiration method 1-7840; 4-279.1 

Atomic absorption, furnace method 1-7841; 4-279.2 

Zinc 

Atomic absorption, direct aspiration method 1-7950; 4-289.1 

Atomic absorption, furnace method 4-289.2 

Organic Analytical Methods: 

Gas Chromatographic Methods 

Halogenated Volatile Organics 1-8010 

Non-halogenated Volatile Organics 1-8015 

Aromatic Volatile Organics 1-8020 

Acrolein, Acrylonitrile, Acetonitrile 1-8030 

Phenols 1-8040 

Phthalate Esters 1-8060 

Organochlorine Pesticides and PCBs 8-84-22; 1-8080 

Nitroaromatics and Cyclic Ketones 1-8090 

Polynuclear Aromatic Hydrocarbons 1-8100 

Chlorinated Hydrocarbons 1-8120 

Organophosphate Pesticides 1-8140 

Chlorinated Herbicides 1-8150 

GC Scans 8-86-02; 3-E260 

Gas Chromatographic/Mass Spectroscopy Methods 

GC/MS Method for Dioxin 1-8280, 8290 

GC/MS Method for Volatile Organics 1-8240; 7-624 

GC/MS Method for Semi-Volatile Organics 1-8250; 8270; 7-625 

Infrared Spectroscopy Methods 3-D2621, D4053; 5-

creening Methods: 

Physical Description 3-D4979 

Flammability Potential Screen 3-D4982 

Water Compatibility 3-D5058C 

pH Screen 3-D4980 

Sulfide Screen 3-D4978 

Cyanide Screen 3-D5049 

Commingled Waste Compatibility 3-D5058A 

Polymerization Potential 3-D5058B 

Oxidizer Screen 3-D4981 

Paint Filter Test 1-9095 

Bulk Density and Apparent Specific Gravity Screen 3-D5057 

WAP-A-6 REVISION 11 

9/29/94 
PARAMETER METHOD REFERENCE 

Miscellaneous Analytical Methods: 

Acidity 

Alkalinity 

Ammonia 

Anions by Ion Chromatography 

Ash Content 

Bromides 

Chlorides 

Conductivity/Conductance 

Extraction Procedure 

Flash point 

Pensky-Martens closed-cup method 

Setaflash closed-cup method 

Cleveland open-cup 

Fluoride 

Free Cyanides 

Halogen Content 

Heat Value 

Oil and Grease 

Oxidation-Reduction (Redox) Potential (ORP) 

Petroleum Hydrocarbons, Total Recoverable 

Phenols 

pH Measurement 

Phosphates 

Radioactivity Screen 

Solids 

Total (TS) at 103-105°C 

Dissolved (TDS) at 180°C 

Suspended, Total (TSS) at 103-105°C 

Fixed and Volatile at 500°C 

Specific Gravity 

Sulfates 

Sulfur 

Total and Amenable Cyanides 

Total Chlorine Content 

Total Organic Carbon 

Total Sulfides 

Toxicity Characteristic Leaching Procedure (TCLP) 

Viscosity 

Water Content 

8-91-68; 2-2310 

2-2320 

4-350.3 

8-87-40; 3-D4327; 4-300.0 

8-91-69; 3-D482, D3174 

2-4500Br'; 4-300.0, 320.1 

2-4500C1"; 4-300.0, 325.3 

3-D1125; 4-120.1 

1-1310 

8-84-19; 1-1010; 3-D93 

1- 1020; 3-D3278 

3-D92 

2-4500F"; 4-300.0, 340.2, 340.3 

2- 4500CN"H,I 

3-D808, D2361, D4327 

8-87-37; 3-D240, D2015 

2-5520; 4-413.1, 413.2 

3-D1498 

2- 5520F; 4-418.1 

2-5530, 6420; 4-420.1 

1-9040, 9041, 9045; 2-4500H+; 3-E70; 4-150.1 

2-4500P; 4-300.0, 365.1-4 

8-87-36 

2-2540B; 4-160.3 

2-2540C; 4-160.1 

2-2540D; 4-160.2 

2-2540E, 2540G; 4-160.4 

2-2710F; 3-D70, D891, D1217, D1429 

2-4500SO4

2

"; 4-300.0, 375.3 

8-87-40; 3-D129, D3177, D4327 

1-9010A; 2-4500CN"C,G; 4-335.1 

3- D808, D4327 

2-5310; 3-D2579 

1-9030; 2-4500S2" 

1-1311 

8-86-35; 3-D88, D446, D2983 

3-D95, D3173, E203 

WAP-A-7 REVISION 11 

9/29/94 
The above-referenced procedures are described in the following publications. The first digit of the 

reference numbers above are keyed to the numbers shown below: 

1- "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods", SW-846, Third Edition, 1986 

as amended by Update I (July 1992), U.S. Environmental Protection Agency, Office of Solid Waste 

(NTIS, 5285 Port Royal Road, Springfield, VA 22161) or more recent edition or revision (GPO, Supt. 

of Documents, Washington, DC 20402). 

2- "Standard Methods for the Examination of Water and Wastewater", 18th Edition, American Public 

Health Association (1015 Fifteenth Street, NW, Washington, DC 20005), American Water Works 

Association, Water Environment Federation, 1992, or more recent edition or update. 

3- "Annual Book of ASTM Standards", American Society for Testing and Materials (1916 Race Street, 

Philadelphia, PA 19013-1187), 1992, or more recent edition or revision. 

4- "Methods for Chemical Analysis of Water and Wastes", EPA-600/4-79-020, U.S. Environmental 

Protection Agency, Environmental Monitoring and Support Laboratory (Cincinnati, OH 45268), as 

revised March 1983, or more recent revision or technical edition. 

5- Infrared Analysis Method in IERL-RTP Procedures Manual: Level 1 Environmental Assessment 

(2nd Edition), EPA-600/7-78-201, October, 1978, or more recent edition. 

6- "Acid Digestion Bombs", Bulletin 4745, Parr Instrument Company (Moline, IL 61265), or more recent 

bulletin. 

7- "Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater", Appendix A of 

Title 40 Code of Federal Regulations Part 136, U. S. Environmental Protection Agency, 

Environmental Monitoring and Support Laboratory-Cincinnati, as amended June 1986 or more recent 

revision. 

8- "CWM Analytical Methods Manual", Chemical Waste Management, Inc., Analytical Programs, 

September 1992. 

Standard analytical procedures listed here which are revised can be implemented upon the effective date of 

the revision, with notification to the IEPA-DLPC Permit Section. 

WAP-A-8 REVISION 11 

9/29/94 
APPENDIX WAP-B 

ASH AND DRY SCRUBBER SOLTOS 

SAMPLING PROTOCOL 
APPENDIX WAP-B 

ASH AND DRY SCRUBBER SOLIDS 

SAMPLING PROTOCOL 

1.0 PURPOSE 

The TWI Incinerators destroy hazardous wastes in high temperature thermal oxidation processes. This 

procedure provides assurance that a representative sample of ash or dry scrubber solids (DSS) is collected for 

analysis. 

2.0 SAMPLING 

2.1 Sample Identification 

2.1.1 Each sample container is labeled with date, time of day, sampler, and container identification number. 

The samples are logged into the laboratory Production Chain-of-Custody logbook upon delivery to the 

laboratory. 

2.2 Sample Collection 

2*2.1 Ash and DSS samples are collected, analyzed and evaluated on a quarterly basis to ensure the 

residuals met the LDR treatment standards. 

2.2.2 Samples are collected as outlined in Section 2.2.1 of the WAP. An auger is typically used to obtain 

a representative sample of the ash or DSS. Each sample jar must be filled with ash or DSS. 

2.2.3 Trained operations personnel will collect the sample and subsequently acknowledge custody by 

completing applicable sections of the laboratory Production Chain-of-Custody logbook. Sample 

preparation and analysis will be performed as soon as practicable following which the disposition of 

the ash (Section 4.0) will be determined. 

2.3 Sampling Personnel 

2.3.1 It is the responsibility of Facility Management to assign only qualified personnel to perform the ash 

or DSS sampling. Personnel that have been trained in the implementation of this procedure are 

considered to be qualified 

3.0 SAMPLE ANALYSIS 

3.1 Each sample will be sent to a CWM or CWM approved lab for analysis of LDR constituents by the 

appropriate method. 

3.2 The tracking of waste codes through the incineration process to the incinerator residuals will be done 

in accordance with TWI Standard Division Practice 1651. 

WAP-B-1 REVISION 11 

9/29/94 
4.0 DISPOSITION OF ASH AND DRY SCRUBBER SOLIDS (DSS) 

4.1 Any container of ash or DSS that was sampled for testing in accordance to the appropriate treatment 

standard or prohibition, will be retained by the facility until results are available for evaluation. 

4.2 The analysis results are evaluated against the LDR treatment standards for the codes in the container. 

The container is released if all treatment standards are met. 

4.3 The analysis results are evaluated against the LDR treatment standards for all codes accepted by 

TWI. Meeting the treatment standards is demonstrated through the process. 

4.4 When compliance with the LDR standards has been demonstrated, the material will be stabilized and 

subsequently disposed of at CWM approved hazardous waste management facilities. The manifest and 

Land Disposal Restriction Treatment Certification will be completed prior to shipment. 

WAP-B-2 REVISION 11 

9/29/94 
APPENDIX WAP-C 

WASTE ACCEPTABILITY CRITERIA 
APPENDIX WAP-C 

WASTE ACCEPTABILITY CRITERIA 

The following restrictions apply to the acceptance of wastes exhibiting certain properties or specific wastes 

at TWI. Prior to acceptance (see Section 5.2), the Mandatory Analyses and the Waste Profile Sheet will be 

evaluated against this appendix. Any restrictions identified will be documented on the waste management 

decision. The list of items under each of these headings is not meant to be exhaustive. The profiling process 

will include a review of the MSDSs and a search of the other bibliographic resources (see Appendix WAP-F) 

for synonyms, product names, common names. The nature of the restrictions are as follows: 

REJECT - These Materials may not be processed at the facility. 

Radioactive Wastes 

Thorium Compounds 

Uranium Compounds 

Radioactive materials as defined by the TWI Part B RCRA Permit, or greater than 0.5 millirads per hour 

(per Section 3.1.4) 

Permit Limited Wastes 

F020 

F021 

F022 

F023 

F026 

F027 

F028 

PCBs > 50 ppm (or other TSCA regulated PCBs) 

WAP-C-1 REVISION 11 

9/29/94 
Regulatory Specified Treatment Technology other than Incineration 

D006 NiCd Batteries 

D008 Lead acid Batteries 

K069 Non-Calcium Sulfate 

Other Unacceptable Wastes 

Asbestos 

SPECIAL PACKAGING - Wastes exhibiting the properties listed below (water/air 

reactive, malodorous, rapid heat release) during the profiling process may be accepted if they are shipped 

in special packaging, repackaged on site or if the material conforms to specifications allowing processing in 

existing TWI facilities. 

Water/Air Reactive Wastes 

Isocyanates 

Nitrates 

Chlorates 

Perchlorates 

Thionyl chloride 

Metal turnings 

Phosphorous 

Metal hydrides 

Silanes 

Chloroformates 

Methylamine 

Oleum 

Other water or air reactive wastes 

WAP-C-2 REVISION 11 

9/29/94 
Malodorous Compounds 

Mercaptans 

Sulfides 

Waste which exhibits energetic characteristics 

Waste which exhibits energetic characteristics (e.g., propellants, explosives, pyrotechnics, flammable liquids, 

etc.) will either be accepted per the Small Quantity Chemical guidelines or will be accepted per the following 

procedure. 

When the volume of a waste stream or changes in incinerator performance indicates that a larger charge size 

is warranted, TWI will follow the following procedure: 

1) The material will be reviewed using reference information, MSDSs where 

available, generator discussions or previous experience. Based on this 

review, TWI will determine if a larger charge size is acceptable. 

2) When it has been determined that a larger charge size is acceptable, 

TWI will either: 

a) Determine if this type of material has been previously processed at TWI in larger charge sizes 

and thereby establish a charge size; or 

b) Conduct a test burn of the material to determine what charge size would be acceptable. This 

test burn will start with the quantity specified in the SQCG's of the energetic component and 

be increased by no more than double the previous charge from this starting point based on the 

incinerator operations. The incinerator operations parameters which will be evaluated to 

determine if charge size can be increased will be as 

follows: 

> Vacuum decrease in the primary or secondary chamber. 

> Temperature increase in the primary chamber of > 100°F 

> Visual interruption of the primary flame 

> Non-steady state gas flow. 

NOTE: This test protocol may be utilized to establish revised charge sizes for all materials previously limited 

in the SQCG's. Test burn documentation will be provided to the IEPA-DLPC prior to implementing 

larger charge sizes. 

WAP-C-3 REVISION 11 

9/29/94 
DIOXIN TESTING - Wastes which contain greater than 0.01% of these constituents require dioxin 

analysis at a 1 ppm threshold before acceptance. 

Erbon (2-(2,4,5-tricWorophenoxy)-ethyl 2,2-dichloropropanate)) 

Hexachlorophene (2,2-methylene-bis [3,4,6-trichlorophenol]) 

2.4.5- trichlorophenol 

2.4.6- trichlorophenol 

2,4,5-T (2,4,5-trichlorophenoxy acetic acid) 

2,4,5-TP (2-(2,4,5-trichlorophenoxy) propanoic acid, Silvex) 

2,3,4,6-tetrachlorophenol 

Pentachlorophenol (PCP) 

Ronnel (0,0-dimethyl 0-(2,4,5-trichlorophenyl)phosphorothioate) 

Debris from fire involving PCBs or the compoimds listed above 

Some of these wastes (Silvex, 2,4,5-T, and PCP) are detected by the screening tests which will be employed 

on dioxin suspect waste streams per the TWI Dioxin Suspect Waste Policy. Additional wastes listed above, if 

indicated by the generator on the profile information, will be tested using gas chromatograph techniques; 

The following are brand name products which include the compoimds listed above (this list is not intended to 

be all inclusive): 

AMCHEM FARMCO FENCE RIDER SPONTOX 

AMINE 2,4,5-T FENOPROP SUPER D WEEDONE 

AQUA-VEX FORRON T-NOX 

BRUSH-RHAP FRUTTONE T TORMANA 

BRUSHTOX INVERTON 245 TRANSAMLNE 

DACINE KURON TRIBUTON 

DED-WEED KUROSAL TRINOXOL 

DOUBLE STRENGTH LINE RIDER U46 

DOWCIDE 3 PENCHLOR VEON245 

DOWCIDE 6 PENTACON VERTON 2T 

DOWCIDE 2S PENWAR VISKO RHAP LOW 

DOWCIDE EC-7 PRILTOX VOLATILE ESTER 

DOWCIDE G-ST REDDON WEEDAR 

ENVERT DT SANTOBRFTE WEED-B-GONE 

ENVERT T SANTOPHEN WEEDBEADS 

EMULSAMTNE BK SILVI-RAP WEEDONE 

ESTERONE snsnruHO 

WAP-C-4 REVISION 11 

9/29/94 
APPENDIX WAP-D 

DETERMINATION OF INCOMING WASTE 

CONFORMANCE/NONCONFORMANCE 
APPENDIX WAP-D 

INCOMING WASTE CONFORMANCE/NON-CONFORMANCE 

Incoming waste may vary from the information determined during the profiling phase due to the variability in 

the process generating the waste or in collection of the waste material. In order to determine whether a 

particular incoming waste stream conforms to the profile, the following criteria will be used. All other 

Mandatory and Supplemental analysis data collected will be used to allow TWI to determine the best method 

for processing the waste material. 

1. pH Screen: A variation in the pH from the range specified in the profile documents may indicate 

a change in the waste stream. If a pH variation beyond the range specified on the liquid profile 

sheet, the procedures outlined in Section 5.2.4 will be initiated (e.g., a waste which is normally 

neutral is found to be corrosive). Materials will be evaluated for conformance as follows: 

Profiling Analytical Result Acceptable Range 

<2 <2 

2-12.5 2-12.5 

>12.5 >12.5 

Wastes profiled as pH 2 to pH 12.5 but shipped with an accompanying LDR form for D002 will be 

considered conforming at pH <2 or pH > 12.5 if supported by the profiled chemical constituents. 

2. Flammability Potential Screen: A variation in the thermal activity from the indicators specified in 

the profile documents will indicate a change in the waste stream. If the variation causes a change 

in the hazard class of the waste, the procedures outlined in Section 5.2.4 will be initiated (e.g. a 

material which did n6t exhibit flammability potential in the profiling phase does during the incoming 

shipment procedures). 

3. PCBs: The unexpected presence of PCBs > 50 ppm contrary to that specified in the profile 

documents will indicate a change in the waste stream, which would initiate the procedures outlined 

in Section 5.2.4. TWI is not permitted to accept PCBs > 50 ppm or TSCA derived PCB wastes. 

4. Radioactivity Screen: The presence of radioactive materials as determined by the radioactivity screen 

(see Section 3.1.4) will initiate the procedures as outlined in Section 5.2.4, leading to rejection of the 

material. 

WAP-D-1 REVISION 11 

9/29/94 
Apparent Viscosity: A significant variation in the apparent viscosity from that specified in the profile 

documents will indicate a change in the waste stream that would initiate the procedures outlined in 

Section 5.2.4. 

WAP-D-2 REVISION 11 

9/29/94 
APPENDIX WAP-E 

CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURES 
APPENDIX WAP-E 

CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURES 

1.0 PURPOSE 

This procedure provides assurance that representative samples of the following containerized wastes 

are collected for analysis. Specifically, these are containerized wastes of debris and like material, 

adhesives and other highly elastic substances, and resins and other hard materials. Representative 

samples are collected by using multipoint sampling. 

2.0 DEFINITIONS 

2.1 Debris and like material - includes wood, bricks, concrete, vegetation, plastic sheeting, 

protective clothing, etc. 

2.2 Adhesives and other highly elastic materials - sticky, glue-like, gummy, stretchable materials. 

2.3 Resins and other hard materials - plastics and plastic components, epoxies and other physically 

similar materials that have hardened or cured. ? 

2.4 Multipoint sample - A sample composed of subsamples collected from the same container that 

is representative the contents of the container. 

3.0 INSPECTION 

Each container will be evaluated prior to opening to determine it's integrity. After opening, the 

container's contents will be visually inspected to determine whether or not it conforms with its 

profiled description. 

4.0 PERCENT SAMPLED 

See Waste Analysis Plan Section 5.1. 

5.0 SAMPLING 

Multipoint samples based on inspection will be collected from containers selected for sampling. 

Sampling equipment will be selected based on results of the inspection. Samples will be in CWM 

custody from sample collection until transfer of custody to the analytical laboratory. Sampling 

equipment will be decontaminated prior to and after sampling each waste stream. 

WAP-E-1 REVISION 11 

9/29/94 
5.1 HIGHLY ELASTIC SUBSTANCES 

Adhesives and other highly elastic substances will be sampled with a scoop or shovel and 

scissors or tongs. The procedure is to: 

5.1.1 dip the shovel or scoop into the material to the depth of the blade and rotate; 

5.1.2 lift the scoop or shovel with the sample and cut with the scissors or tongs, as 

appropriate; 

5.1.3 wind the hanging portion of the sample onto the scoop or shovel and transfer the 

sample to the sample container by scraping the material from the shovel or scoop into 

the sample container. 

5.2 DEBRIS AND LIKE MATERIAL 

Debris and like materials will be sampled with scissors, hammer, chisel and tongs as 

appropriate. The procedure is to: 

5.2.1 use hammer and chisel to collect samples of wood, brick or other hard material from the 

top of the container and place in the sample container with tongs; 

5.2.2 use scissors to cut sample of tyvek and other easily cutable materials (padding, rubber, 

plastic sheeting, etc.) and place in sample container with tongs. 

5.3 RESINS AND/OR OTHER HARD MATERIALS 

Resins and/or other hard materials will be sampled with a hammer, chisel and tongs or scoop. 

The procedure is to: 

5.3.1 Use hammer and chisel to reduce material(s) size so that it can easily be placed in a 

sample container and place the sample in the container with tongs or scoop. 

6.0 SAMPLING PERSONNEL 

It is the responsibility of Facility Management to assign only qualified personnel to perform 

specialized sampling of containerized waste. Personnel that have been trained in the implementation 

of this procedure are considered to be qualified. 

7.0 SAMPLE ANALYSIS 

Samples will be analyzed as specified in Sections 3.1, 3.2, and 3.3, and Figure 3-1 of the WAP. 

Additional analysis will be performed at the request of the Facility Management. 

WAP-E-2 REVISION 11 

9/29/94 
APPENDIX WAP-F 

BIBLIOGRAPHY OF STANDARD CHEMICAL REFERENCE MATERIALS 
APPENDIX WAP-F 

BIBLIOGRAPHY OF STANDARD CHEMICAL REFERENCE MATERIALS 

1. The Merck Index, Current Edition, 1983 Merck & Co. Inc., Rahway, NJ. 

2. Dangerous Properties of Industrial Chemicals, Current Edition 1989, Van Nostrand Reinhold, NY 

NY. 

3. Handbook of Reactive Hazards, Current Edition, 1987, Butterworths, London. 

4. Condensed Chemical Dictionary, Current Edition, 1987 Van Nostrand Reinhold,NY NY. 

5. CWM AS-400 computerized MSDS system, current version. 

6. Farm Chemicals HI, Meister Publishing Co. 

7. Chemical Synonyms & Trade Names, Current Edition, 1987 Grower Technical Press. 

8. Lange's Handbook of Chemistry, Current Edition, 1985 McGraw-Hill. 

9. Handbook of Reactive Chemicals, Current Edition, 1985 L. Bretherick. 

10. Handbook of Chemistry & Physics, Current Edition, 1976 CRC Press. 

WAP-F-1 REVISION 11 

9/29/94 
APPENDIX WAP-G 

HM-181 COMPATIBILITY CLASSES 
APPENDIX WAP - G 

HM-181 COMPATIBILITY CLASSES 

DOT Class NAME 

1.1 - 1.6 Explosives 

2.1 - 2.2 Aerosol Cans 

3 Flammable Liquid 

4.1 Flammable Solids 

4.2 Spontaneously Combustibles 

4.3 Dangerous When Wet 

5.1 Oxidizers 

5.2 Organic Peroxides 

2.3 Poisonous Gas Zone A & B 

6.1 Poisonous Liquid Zone A 

8 Corrosives 

9 Miscellaneous N.O.S. Debris 

Non-Hazardous Material 

WAP-G-1 REVISION 11 

9/29/94 
CHEMICAL WASTE MANAGEMENT 

PCB SCREENING POUCY 
CWM PCB SCREENING POUCY 

INTRODUCTION 

The Toxic Substances Control Act (TSCA) is the primary source of federal 

regulations affecting the management of Polychlorinated Biphenyls (PCBs). Most 

of the provisions of the TSCA regulations specified in 40 CFR Part 761 apply to 

PCBs only if PCBs are present in concentrations above specified levels. The 40 

CFR Part 761 subpart D Storage and Disposal provisions apply generally to 

material at concentrations of 50 parts per million (ppm) and above. However, no 

provision specifying a PCB concentration may be avoided by diluting PCB 

containing materials unless otherwise specifically provided. 

Furthermore, the Resource Conservation and Recovery Act (RCRA) is an 

additional source of federal regulations affecting the management of hazardous 

waste containing PCBs. The land disposal of liquid hazardous wastes containing 

PCBs at concentrations greater than or equal to 50 ppm is prohibited under the 

provisions of 40 CFR Part 268.32 (a)(2). The land disposal of liquid or nonliquid hazardous waste containing halogenated organic compounds (HOCs) 

including PCBs (see 40 CFR Part 268 Appendix III for a listing of HOCs) at 

concentrations equal to or greater than 1000 mg/L or 1000 mg/kg, respectively, 

is prohibited under the provisions of 40 CFR Part 268.32 (a)(3), (e)(1), and (e)(2) 

the "California List." In addition, the management of liquid hazardous waste 

containing PCBs at concentrations of 50 ppm or above as well as liquid or nonliquid hazardous wastes containing HOCs including PCBs (see 40 CFR Part 268 

Appendix III for list of HOCs) in total concentrations equal to or greater than 

1000 mg/L or 1000 mg/kg for liquid or solid, respectively, are specified under the 

provisions of 40 CFR Part 268.42. Finally, the land disposal of hazardous waste 

containing PCBs and identified by the listed hazardous waste code numbers 

K085 and F039 (multi-source leachate) is regulated under Specific Land Disposal 

Restrictions (LDR) provisions under 40 CFR Part 268.43. These regulations 

require PCBs to be treated to the following levels (Table I) prior to land disposal. 

2 

Revision 1 

October 1991 
PCB Screening Policy 

TABLE I 

Waste Water Non-Waste Water 

K085 & F039 mg/L mg/kg 

Aroclor 1016 0.013 0.92 

Aroclor 1221 0.014 0.92 

Aroclor 1232 0.013 0.92 

Aroclor 1242 0.017 0.92 

Aroclor 1248 0.013 0.92 

Aroclor 1254 0.014 1.8 

Aroclor 1260 0.014 1.8 

State and local agencies and permits may also regulate the management of 

PCBs. Compliance with these regulations is required wherever they are more 

stringent than federal regulations (e.g., certain states require that the PCBs be 

reported on a dry weight basis). 

Additionally, TSCA addresses PCBs, not Aroclors. This includes incidentally 

produced PCBs and foreign produced materials that include Clophen®, 

Phenoclor*, Pyralene*. Kanechlor*, and Fenclor* 

In order to assure that the appropriate practices are being applied consistently 

throughout Chemical Waste Management, Inc. (CWM) regarding the management 

of wastes which may potentially contain PCBs, it is important to define 

procedures to be employed throughout the company. Therefore, the following 

Policy and Procedures has been developed. 

3 

Revision 1 

October 1991 
PCB Screening Policy 

//. POUCY 

A. The treatment, storage, and disposal of any TSCA regulated waste shall 

occur only at a TSCA approved treatment, storage, or disposal facility. 

B. All PCB analyses required as a result of the application of this policy shall 

be performed by a CWM laboratory or a CWM approved waste laboratory. 

C. Any waste that will be analyzed for PCBs in accordance with this policy 

shall not be accepted for storage, treatment, or disposal until PCB 

analyses have been completed and evaluated. 

D. Any non-TSCA waste which meets the following criteria shall be treated as 

a PCB suspect waste until demonstrated otherwise, through chemical 

analysis. 

///. PCB SUSPECT WASTE CRITERIA 

The following criteria have been developed by Chemical Waste Management, Inc. 

through its extensive operating experiences as well as through review of various 

sources of literature for defining a waste as being PCB Suspect. These criteria 

are intended to supplement existing requirements which may have been imposed 

through permit conditions, administrative orders, or other agreements with federal 

or state regulatory agencies. 

A. Generator-Defined PCB Waste 

Any waste for which the generator has indicated on the "Generator's Waste 

Material Profile Sheet" or any other supporting documentation that PCBs 

are present below regulated levels. 

4 

Revision 1 

October 1991 
PCB Screening Policy 

B. Oil Bearing Waste 

NOTE: . Oil bearing wastes are defined as any material (liquid, solid, 

organic, or aqueous) containing oil as described on the "Generator's Waste 

Material Profile Sheet" (other supporting documentation) OR any material 

which exhibits the visual presence of oil. The visual presence of oil may 

include, but is not limited to, an oil emulsion, oil film, oil phase, or water 

soluble oil. It is the responsibility of the Laboratory Manager at each 

division to use sound judgment based on their analytical experience to 

make the final determination if a waste stream exhibits the visual presence 

of oil. 

C. Municipal Waste Water Treatment Facility Sludge 

D. Bulk Laboratory Wastes 

E. Baghouse Dusts from Secondary Smelters (e.g., copper, aluminum) 

F. Any Waste as Designated by the Laboratory Manager 

G. AH Wastes, Liquids or Solids, from the following: 

1. Electrical Utility Company 

2. Natural Gas Pipeline Transmission Company 

3. Solvent Recovery, Reuse or Recycling Unit 

4. Oil Recovery, Reuse or Recycling Unit 

5. Oil Maintenance Centers 

6. Pond Closures (including Pond Sludges and Dredgings) 

7. Remedial Action Superfund Sites 

8. RCRA Corrective Action Project* 

9. Timber/Lumber Treating Facility 

10. Hydraulic Equipment 

11. ENRAC Remedial Action Projects* 

* Unless demonstrated non-TSCA 

5 

Revision 1 

October 1991 
PCB Screening Policy 

12. Heat Transfer Units 

13. Metal Machining (Cutting) Operations 

14. Pesticide/Herbicide Manufacturing 

15. Ink and Pigment Manufacturing 

16. Oil Based Paint Manufacturing 

17. Paper Recycling Operations 

18. Roofing Felt Manufacturing or Processing 

19. Auto Fluff 

20. Non-WMI Waste Treaters 

21. Chlorobenzene Manufacturing 

IV. PROCEDURES 

A. Pre-Acceptance Samples 

Pre-acceptance samples are to be analyzed for PCBs by a laboratory if 

the waste stream meets any of the criteria specified in section III above. 

B. Incoming Waste Shipment Samples 

The need to analyze incoming waste shipment samples for PCBs will be 

established by the results of the sales sample analysis and evaluation of 

the sales sample Waste Profile Sheet information against this policy. 

Table II describes the overall requirements discussed below. 

ff a waste stream does not meet any of the PCB suspect criteria, then 

there is no specific requirement to perform PCB analyses on the incoming 

shipments of this waste stream unless specifically required under a Waste 

Analysis Plan (WAP). 

6 

Revision 1 

October 1991 
PCB Screening Policy 

ff a waste stream meets any of the PCB Suspect Criteria and the sales 

sample analysis indicates PCBs are less than 5 ppm1 or the regulatory limit 

(The ERA TSCA office has recently specified concentrations of less than 

2 ppm PCBs in treatment residues for approval and refer to Table I for 

listed code specifications), whichever is lower, then the laboratory/technical 

manager must specify on the Waste Management Decision (WMD) whether 

PCB analyses on incoming waste shipments are required and, If so, the 

frequency of analyses. 

If a waste stream meets any of the PCB Suspect Criteria and the sales 

sample analysis indicates PCBs are above 5 ppm1 or the regulatory limit, 

whichever is lower, then the laboratory/technical manager must specify on 

the WMD that PCB analyses on incoming waste shipments are required 

and the frequency at which that analysis is to be performed. 

If the receipt material demonstrates a change in the waste from the preacceptance sample and it now meets the PCB suspect criteria, then PCB 

analysis must be performed before treatment, storage, or disposal. 

1

 The specific criterion of 5 ppm is the typical laboratory reporting limit for PCB 

analysis, ft is a conservative approach to protecting the integrity of non-TSCA facilities. 

7 

Revision 1 

October 1991 
PCB Screening Policy 

TABLE II 

WPS 

Not a Suspect 

( WMD) 

No Action 

Required 

^1 PCB Suspect I 

I

 1 

Lab Data 

CWM or Generator 

( WMD) 

Frequency 

of Testing 

) 

< 5 ppm PCB 

( Yes or No ) 

( WMD)if Yes 

Frequency 

of Testing ) 

Meets PCB Suspect 

Criteria 

*Sales Sample 

PCB Results Receiving Procedures 

No 

Yes 

Yes 

<5 ppm 

>5 ppm 

No specific actions required. 

Specify in Waste Management Decision 

(WMD) whether PCB analyses on 

incoming waste shipments are required 

and, if so, the frequency of analyses. 

WMD must specify that PCB analyses 

are required on incoming waste shipments 

and must specify the frequency of those 

analyses. 

* or the regulatory limit, whichever is lower. 

8 

Revision 1 

October 1991 
Trade Waste Incineration 

7 Mobile Avenue 

Sauget. IL 62201-1069 

618/271-2804 

TRADE HASTE I MCI HERAT I OH 

DIOXIN SUSPECT ANALYSIS POLICY ' 

SEPTEMBER 28, 1994 

a division of CJk Chemical Waste Management, Inc. 

Printed or recycled pap 
TWI DIOXIN ANALYSIS POLICY 

INTRODUCTION 

Trad e Waste Incineratio n i s implementin g thi s polic y fo r th e 

screenin g of wastes whic h may contai n dioxins . Thi s polic y 

wil l identif y th e type s o f waste s whic h must he analyse d fo r 

dioxin s o r dioxi n precursor s prio r t o approva l fo r acceptanc e 

as a waste strea m a t TWI. Implementatio n of thi s polic y wil l 

provid e a means of ensurin g tha t potentiall y dioxi n 

contaminate d waste s ar e analyze d fo r dioxi n conten t and 

subsequentl y managed appropriatel y accordin g t o applicabl e 

stat e and federa l regulations . The fina l decisio n t o manage 

a dioxi n bearin g waste must be made accordin g t o _ th e 

condition s and restriction s o f th e governin g facilit y Wa§£e 

Analysi s Pla n and operatin g permits . » 

POLICY 

A. Waste stream s contemplate d fo r management a t TWI wil l be 

subjecte d t o th e Dioxi n Suspec t Waste Criteri a durin g th e 

decisio n evaluatio n proces s of th e profilin g procedure . 

B. Wastes whic h ar e determine d t o meet th e Dioxi n Suspec t 

Waste Criteri a wil l requir e analysi s fo r dioxi n 

precursor s prio r t o acceptanc e and management fo r 

treatmen t and disposa l a t th e facility . 

C. Wastes whic h ar e foun d t o contai n dioxi n precursor s a t o r 

above th e sit e actio n leve l fo r precursor s wil l requir e 

dioxi n analysi s prio r t o acceptanc e and management fo r 

treatmen t and disposa l a t th e facility . 

D. Wastes whic h ar e foun d t o contai n dioxin s a t or above th e 

sit e actio n leve l wil l no t be accepte d fo r management fo r 

treatmen t and disposa l a t th e facilit y unti l suc h tim e 

tha t treatmen t and disposa l ar e allowe d accordin g t o th e 

condition s and restriction s o f th e governin g facilit y 

Waste Analysi s Pla n and operatin g permits . 
III . DIOXIN SUSPECT HASTE CRITERIA 

The followin g criteri a has been develope d fo r definin g a waste 

as dioxi n suspect . These criteri a ar e intende d t o supplement 

existin g requirement s whic h may have been imposed throug h 

permi t conditions , administrativ e orders , o r othe r agreements 

wit h federa l o r stat e authorities . Haste s considere d under 

thes e criteri a remai n subjec t t o al l existin g condition s 

imposed by Chemica l Waste Management policie s and 

environmenta l directives . 

A. Generato r Define d Dioxi n Waste. 

Any waste fo r whic h th e generato r has indicate d on th e 

"Generator' s Waste Materia l Profil e Sheet n o r any othe r 

supportin g documentatio n tha t dioxin s o r dioxij a 

precursor s ar e presen t a t any level . i 

B. Wastes Prom th e Following : 

These wastes wil l be considere d as suspec t i f the y may 

have been subjec t t o historica l contaminatio n fro m 

dioxin s o r dioxi n precursors , o r i f th e waste s contai n a 

known dioxi n o r dioxi n precurso r material . 

1. Timber/Lumber Treatin g Facilities . 

2. Pesticide/Herbicid e Manufacturin g Facilities . 

3. Manufacturer s o r Processe s Using : 

a) mono-, di* , tri- , o r tetrachlorophenols , and 

thei r chloro-phenox y derivativ e acids , esters , 

amine, and othe r salts . 

b) pentachloropheno l 

c ) mono-, di- , tri- , tetra- , penta- , o r 

hexachlorobenzenes . 

d) trichlorophenoxypropioni c aci d (silvex ) 

e) trichlorophenoxyaceti c aci d (2,4,5-T) 

f ) hexachlorophen e 

4. Combustion product s fro m source s outsid e o f th e 

CWM/WMX Technologie s famil y of companies where suc h 

combustio n occurre d under uncontrolle d condition s 

and th e formatio n of dioxin s o r dioxi n relate d 

compounds i s suspecte d t o have occurre d (i.e . th e 

combustio n o f PVC, CPVC, etc.) . 

C. Wastes bearin g EPA hazardou s wast e numbers F032, F039, 

K001, K015, K016, K030, K042, K043, K085, K099, K105, 

K149, K150, and K151. 
I V. PROCEDURES 

A. Precurso r Analysis : 

Dioxi n precurso r analysi s may be conducte d by HPLC, GC o r 

GC/MS, o r immunoassay scree n technique s followin g 

approve d EPA methods o r CHM modification s o f suc h 

methods. 

1. Profil e Approva l Samples: Profil e approva l sample s 

a r e t o be analyse d fo r dioxi n precursor s i f th e 

waste strea m meets any o f th e criteri a specified?±n 

sectio n II I above. Haste s whic h ar e bein g 

reprofile d o r recertifie d due t o changes i n th e 

proces s generatin g th e waste , o r as a resul t o f 

generato r informatio n gathere d durin g th e nonconformance resolutio n durin g incomin g analysi s lir e 

als o subjec t t o th e criteri a specifie d i n sectio n 

III .

 ? 

2. Incoming Hast e Shipment Samples: 

a) The need t o analys e incomin g waste shipmen t 

samples fo r dioxi n precursor s wil l be 

establishe d by th e result s o f th e profil e 

approva l sample analysi s and an evaluatio n o f 

t h e waste profil e shee t informatio n agains t 

t h e criteri a establishe d i n thi s policy . 

b) I f a wast e strea m does no t meet any o f th e 

criteri a establishe d i n sectio n III o f thi s 

policy , the n ther e i s no specifi c requiremen t 

t o perfor m dioxi n precurso r analysi s on th e 

incomin g shipmen t samples of th e waste stream . 

c ) I f th e receip t materia l demonstrate s a change 

i n th e waste fro m th e profil e approva l sample 

(i.e . informatio n provide d by th e generato r 

durin g th e non-conformance resolutio n 

process) , and i t now meets th e criteri a 

establishe d i n sectio n II I o f thi s policy , 

the n dioxi n precurso r analysi s must be 

performe d as par t o f th e incomin g analysis . 

d) Haste s whic h meet th e criteri a establishe d i n 

sectio n II I of thi s polic y and whic h exhibite d 

negativ e scree n result s fo r dioxi n precursor s 

durin g profil e approva l analysi s wil l no t be 

screene d upon receipt . 
e) Wastes whic h meet th e criteri a establishe d i n 

sectio n II I of thi s polic y and whic h exhibite d 

positiv e scree n result s fo r dioxi n precursor s 

durin g profil e approva l analysi s wil l be 

screene d upon receip t i f th e profil e approva l 

scree n indicate d dioxi n precursor s above th e 

precurso r threshol d value , and subsequen t 

dioxi n analysi s confirme d dioxin s below th e 

dioxi n threshol d valu e (o r no t present) . The 

incomin g scree n wil l be limite d t o onl y thos e 

precursor s whic h were detecte d durin g profil e 

approva l analysis . 

I f th e incomin g scree n indicate s th e presenc e 

of dioxi n precursors , incomin g dioxi n 

confirmatio n analysi s wil l be conducte d i f th e 

level s o f precursor s i n th e incomin g scree n 

excee d th e level s of precursor s i n th e profil e 

approva l analysi s wit h th e followin g 

guidelines : * 

i ) Profil e approva l precurso r scree n was 

positive , dioxi n confirmatio n analysi s 

was negative , none detected . 

- and -

The incomin g scree n indicate s precurso r 

level s greate r tha n a facto r of 10 time s 

above th e profil e approva l results . 

i i ) Profil e approva l precurso r scree n was 

positive , dioxi n confirmatio n analysi s 

was negative , bu t dioxi n was detecte d 

below threshol d value . 

- and -

The incomin g scree n indicate s precurso r 

level s greate r tha n a prorate d leve l 

above th e profil e approva l results . The 

prorate d leve l i s determine d as follows : 

(DTL / DLD) X PPL 

where: DTL = dioxi n threshol d leve l 

DLD ~ dioxi n leve l detecte d 

(profil e approval ) 

PPL = profil e approva l 

precurso r leve l 

Dioxi n Analysis : 

Dioxi n analysi s wil l be performed , wit h th e concurrenc e 

of th e generato r o f th e waste , followin g a dioxi n 

precurso r scree n whic h indicate s a precurso r presen t a t 

o r above 0.01% by weight . Detectio n limit s fo r dioxi n 

analysi s wil l be se t a t a 1 par t pe r millio n threshold . 
DEFINITIONS 

A. Dioxin : Genera l famil y name fo r compounds known as 

polychlorinate d dibenzo-p-dioxin s (PCDDs) . Specifically , 

"dioxin " i s typicall y used t o refe r t o 2,3,7,8-

tetrachlorodibenzo-p-dioxin , o r 2,3,7,8-TCDD. 

B. Dioxi n precursors : Chemical s whic h when manufacture d 

have been shown t o contai n dioxin s as a waste o r byproduct * Dioxi n precursor s ar e o f simila r chemica l 

compositio n t o dioxins . Some examples ar e 2,4,5-

trichlorophenol , silvex , and hexachlorophene . 

C. HPLC: Hig h Pressur e Liqui d Chromatography. Thi s 

analysi s techniqu e i s use d i n CWM method #92-78, "The 

Analysi s o f Chlorophenox y Herbicide s usin g HPLC". 

D. GC. GC/MS: Gas Chromatography, GC/Mass Spectroscopy . 

Analysi s instrumentatio n use d fo r th e specifi c 

identificatio n of numerous organi c compounds. Typically , 

t h e methods fo r quantificatio n o f specifi c dioxin s o r 

dioxi n precursor s use GC o r GC/MS techniques . 

E. Immunoassay screen : A quick , semi-quantitativ e method o f 

identifyin g th e presenc e o f a specifi c chemica l o r 

chemica l family . Specifically , SW-846 Method 4010, 

Immunoassay Tes t fo r th e Presenc e o f Pentachlorophenol . 

B:\TWIDIOX.TXT 
POL ICY REV IEW OF PROF ILE CONSTITUEMTS 

Suspect per polic y 

I 

N ot suspec t per polic y 

->>-

Conduct dioxi n 

precurso r 

analysi s 

Dioxi n precursor s 

foun d 

i 

Procee d wit h decisio n 

process , no pre -

curso r analysi s 

Precursor s no t foun d 

->>-

Does generato r want 

t o have dioxi n test -

i n g performed ? 

T 

No 

Deny 

decisio n 

1 

No dioxi n testin g 

No precurso r testin g 

on incomin g waste 

Y es 

Conduc t dioxi n 

analysi s 

Was dioxi n 

detected ? 

T 

V No 

Y es Was th e dioxi n 

—>>H leve l > 1 ppm? 

Approv e decision , 

conduc t precurso r 

analysi s on incomin g 

wast e shipment s 

I 

I s incomin g waste 

shipmen t precurso r 

leve l > 10 time s th e 

profil e analysi s 

pre-curso r level f 

T 

V No 

Y es Deny decisio n o r 

>>—(reject shipmen t 

Approve decisio n (o r accep t 

waste shipments) , conduc t pre -

curso r analysi s on incomin g 

wast e shipment s 

->>-

No Accep t th e 

wast e shipmen t 

Y es 

Does th e generato r 

Hwant to have dioxi n 

testing performed ? 

No Rejec t th e 

wast e shipmen t 

V Ye s 

. j 

Conduc t dioxi n 

analysi s 

T 

V 

Was dioxi n detected ? 

Y es 

h-» H 

V No 

Accep t th e waste 

shipmen t 

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i : : 

l i - th e pr<$^\. 

r a t el l incomin g 

waste., shipmen t 

pri^u^ib ^ 

screen-' d$ok1# 

level ' •'<•- V -P0i'; 

(seer'^61 1£y 

sectio n IV, Av 

Zi»m,\ ill ? 

1 r 

V m V Yes 

Modif y decisio n 

analysi s result ! 

f o r rati o o f pre -

cursor s t o dioxin ^ 

i f necessar y 

Accept -

wast e 

shipment