EPA WAP Issues

 Section 1.0 indicates that procedures apply to hazardous and non-hazardous waste. Agency 

wants it also to apply to all material entering the incinerator including fuels (natural gas).

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 safe 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"), and fuels (natural gas will be excluded but specification sheets will 

be obtained form the supplier) 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 wastes 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.

 Section 2.2 How does Veolia assure that all layers are analyzed? Explain methodology. 

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, except for PCBs, where only the suspect layer is analyzed. 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.

Samples (sub-samples for analysis) are collected in the laboratory in the same manner as the container 

sample is collected. For liquids, a full depth sample is collected then analyzed. For solids and sludges, 

proportionate amounts of the sample are sub-sampled for analysis. 

 Section 5.2.3 Add conformance with color, phase and odor.

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 not 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.

5. 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.

6. Color: A significant variation in the color ranges specified in the profile documents may indicate a change in 

the waste stream. Wastes assigned a color on the profile due to generator knowledge or literature during preacceptance will be compared to the color of the sample or visual description at receipt. Some wastes types may be 

described as “varies” due to the type and variability of the constituents. For example, debris wastes may include blue 

gloves, white rocks, green leaves, and brown absorbent. Significant variations in color ranges would initiate the

procedures outlined in Section 5.2.4. 

7. Phases: A significant variation in the number and type of phases specified in the profile documents may 

indicate a change in the waste stream. Wastes are typically described as solid, sludge, or liquid. If the waste is profiled 

as one or any combination of the phases, the waste will be compared to the profile information. Variations would initiate 

the procedures outlined in Section 5.2.4.

8. Incidental Odor: Any incidental odor noticed by the samplers and/or laboratory analysts not specified on the 

profile documents may indicate a change in the waste stream and would initiate the procedures outlined in Section 5.2.4. 
 Section 3.1 Add Hg to the Mandatory Analysis List (mandatory analysis may also be 

performed on a generator supplied sample if the generator supplied information is not 

sufficient).

FIGURE 3-1

SUMMARY OF ANALYSIS

INCOMING

PARAMETER PROFILE WASTE

Physical Description X

pH Screen X X

Cyanide Screen (1) X

Oxidizer Screen X

Radioactivity Screen X X

Flammability Potential Screen X X

Liquid Waste Compatibility (Water Mix)(2) X

Heat Value (BTU) X(4)

Chlorine Content X(4)

Ash Content S(5)

Specific Gravity S(6)

PCBs (3) X S

GC Scan (3) S

Acidity/Alkalinity S

Sulfide Screen (1) X

Liquid Waste Compatibility S

Apparent Viscosity (5) X S

Pentachlorophenol Screening S

Chlorophenoxy Herbicides HPLC S

Mercury X(7) S(7)

Fluorine S

Bromine S

Metals S

Confinement Test S

X = Mandatory Analysis

S = Supplemental Analysis

(1) Does not apply to waste with pH <=2

(2) Does not apply to waste already in 

contact with excess water.

(3) Performed on suspect waste only, 

according to PCB Policy. Not

performed on waste that present a safety

hazard.

(4) Not performed on waste to be 

blended.

(5) Liquids only.

(6) Bulk liquids only.

(7) Mercury analysis will be completed 

during profiling on suspect waste only.
 

 Section 4.1.4 Exceptions to Profiling Requirements (1) Packaged chemicals and debris, 

need to better define what debris is. (2) Empty Containers, need to define the entire 

definition of RCRA empty including requirement for containers that are over 119 

gallons. (6) Single Source Spill Material, expand definition and need to address when 

Hg analysis will be completed. 

4.1.4 Exceptions to the Foregoing Requirements

The following waste types will be exempt from the foregoing sampling requirements for 

preacceptance:

(1) Packaged chemicals and lab packing debris (e.g., glassware, syringes, lab coats, tyveks, 

gloves, etc.)from laboratories, hospitals, household clean sweeps, manufacturing facilities, 

etc., including scintillation vials packed in accordance with Small Quantity Chemical 

Guidelines (SQCG's). 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. Technician(s) packaging the waste complete the drum inventory sheets 

and provide to TWI for review to ensure compliance with the SQCG’s. This drum inventory 

sheet must be reviewed and approved for each container by the TWI Facility Management 

prior to acceptance at the facility.

(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 that does not meet the RCRA empty definition defined 

in 35 IAC 721.107(b).

(6) Single source spill material on undefined media where no generator knowledge exists.

 Section 4.1.5 Standards Profiles, expand on the definition and address what analysis 

including metals will be done on like processes from different locations and companies.

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. ONYX ENVIRONMENTAL SERVICES 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 Standard Profile 

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

generator will submit a separate, unique waste profile sheet for approval. TWI approval personnel 

will review the unique profile and match it to a standard profile and complete a separate decision. 

The approval decision will be completed, providing the generator’s waste is a subset of the 

chemical composition of the standard template.

An example of a standard profile would be K040, Wastewater Treatment Sludge from the 

Production of Phorate. A historical database of preacceptance analytical would be collected for 

random generators of K040 waste. Since the chemical composition and analytical results of these 

wastes is very similar, no new information would be gained from additional analysis of a K040 

waste. Much in the same manner as how the EPA developed the Phorate treatment standard for 
K040 (0.021 mg/l for wastewaters and 4.6 mg/l for non-wastewaters) through repeated analytical 

for LDR constituents, Veolia would develop and standardize an analytical database. Mercury for 

K040 would not be an issue since repeated analysis by EPA indicated the absence of this metal, 

hence the absence of a treatment standard for Mercury in K040 waste. When a new profile for 

K040 is submitted for approval, it will be approved under the K040 standard profile based on the 

previously developed knowledge of this waste. 

 Section 5.1.1 Exceptions to Incoming Waste Analysis Procedures (same comments as 

those addressed in 4.1.4)

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) Direct Charge packaged chemicals and lab packing debris (e.g., glassware, syringes, lab 

coats, tyveks, gloves, etc.) packed by Veolia ES Technical Solutions, LLC (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-conforming and processable, or non-conforming and discrepant. 

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

does not meet RCRA empty definition defined in 35 IAC 721.107(b) 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.

6) Single Source Spill Material on undefined media where no generator knowledge exists. 

TWI will visually inspect 5% of the incoming containers.

 Section 5.2.3 An Evaluation of Whether a Waste is Found to be in Conformance or Nonconformance, address expanded pH ranges defined in WAP Appendix D and also 

address phase, color, odor differences in Section 5.2.3. Also add more detail to this

section.

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.

6. Color: A significant variation in the color ranges specified in the profile documents may 

indicate a change in the waste stream. Wastes assigned a color on the profile due to generator 

knowledge or literature during pre-acceptance will be compared to the color of the sample or visual 

description at receipt. Some wastes types may be described as “varies” due to the type and
variability of the constituents. For example, debris wastes may include blue gloves, white rocks, 

green leaves, and brown absorbent. Significant variations in color ranges would initiate the 

procedures outlined in Section 5.2.4. 

7. Phases: A significant variation in the number and type of phases specified in the profile documents 

may indicate a change in the waste stream. Wastes are typically described as solid, sludge, or 

liquid. If the waste is profiled as one or any combination of the phases, the waste will be compared 

to the profile information. Variations would initiate the procedures outlined in Section 5.2.4.

8. Incidental Odor: Any incidental odor noticed by the samplers and/or laboratory analysts not 

specified on the profile documents may indicate a change in the waste stream and would initiate 

the procedures outlined in Section 5.2.4. 

 Section 6.3.1 Pre-treatment Analyses, need to add Hg analysis to list of required 

analysis.

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. Pre-treatment Analyses (6.3.1 numbers 1-6) are optional for liquid waste in tanks 

which will undergo 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 maximum heat value which 

can be burned per hour is established in the operating permit.

2. 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.

3. pH Screen is used to protect the integrity of tank farm materials of 

construction and provide management data for proper blending.

4. 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).

5. Metals values are calculated based on profile information.

 Section 7.0 QA/QC plan defined in WAP section 7 needs to be more detailed.

7.0 QUALITY ASSURANCE/QUALITY CONTROL

The following quality assurance/quality control (QA/QC or "quality") information for this facility is 

being provided as required by 40 CFR Part 270.30(e) and in accordance with the following EPA 

guidance documents. 

The company quality control program is based on the National Environmental Laboratory 

Accreditation Program (NELAP) as well as:

Handbook for Analytical Quality Control in Water and Wastewater Laboratories, EPA 

600/4-79-019, March 1979, U.S. Environmental Protection Agency (U.S. EPA), Environmental 

Monitoring and Support Laboratory (EMSL), Cincinnati, OH, March 1979, or most recent addition . 

Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Third 

Edition, Final Update III, U.S. EPA, Office of Solid Waste, Washington, DC, Chapter One, or most 

recent addition.

Quality procedures are applicable to both sampling procedures and analytical techniques. 

This section does not provide specific performance standards of quality procedures for individual 

sampling and analysis techniques. Such specifics are defined on a corporate-wide basis for all 

company facilities. The specific performance standards are dynamic and are revised as warranted 

to reflect technological advances in sampling and analytical techniques. These performance 

standards are described in corporate policies, which are maintained and used at this facility and 
which are available for regulatory review. Portions of these policies have been summarized in the 

following sections.

7.1 Sampling Program

Sampling procedures for facility operations are described in Section 2.0 and Table 2-1 of 

this WAP. The selection of the sample collection device depends on the type of sample, the 

sample container, the sampling location and the nature and distribution of the waste components. 

In general, the methodologies used for specific materials correspond to those referenced in 40 CFR 

Part 261, Appendix I. The selection and use of the sampling device is supervised or performed by 

a person thoroughly familiar with the sampling requirements.

Sampling equipment is constructed of non-reactive materials, such as, glass, PVC plastic, 

aluminum, or stainless steel. Care is taken in the selection of the sampling device to prevent 

contamination of the sample and to ensure compatibility of materials. For example, glass bottles 

are not used to collect hydrofluoric acid wastes.

With some exceptions, all bulk and containerized waste shipments are sampled (see 

Section 5.1.1 of this WAP. Individual container samples may be composited prior to analysis.

7.2 Analytical Program

The company has developed a program of analytical quality practices and procedures to ensure 

that precision and accuracy are maintained throughout its laboratories. Company facility 

laboratories are required to participate in this program. Non-company laboratories employed by the 

company demonstrate quality control practices that are comparable to the company's program.

Good laboratory practices which encompass sampling, sample handling, housekeeping and safety 

are maintained at all laboratories.

The following quality control practices are implemented at all laboratory operations:

I Instrument Performance Materials

Each day of operation, analytical systems are evaluated through the use of instrument performance 

materials before sample analysis is initiated. Divergence from acceptance criteria specified in the 

Quality Control Procedures requires corrective action before analyses can be performed. 

Calibration blanks, instrument performance materials, instrument manual requirements and 

maintenance records are maintained in an organized manner.

II Contamination Evaluation

Method blanks are prepared each day of sample analysis and analyzed to ensure that sample 

contamination has not occurred. Whenever appropriate, a field blank is taken and analyzed 

accordingly. If blank analyses do not fall within acceptable limits, as specified in the Quality Control 

Procedures, corrective action is required before analyses can be performed.

III Laboratory Control Sample

A quality control check sample is analyzed each day an analytical result is determined for a specific 

parameter. These results show that analytical procedures are performed 

properly and the calibration and standardization of the instruments are within acceptable limits. 

Acceptable performance demonstrates that prescribed precision and accuracy are being 

maintained. 

IV Duplicate Analysis

A sample or spiked sample is analyzed in duplicate for each twenty (20) samples analyzed for a 

particular parameter to monitor analytical precision. Selection of the duplicate samples is specified 

in the Quality Control Procedures. Precision is periodically assessed using Relative Percent 

Difference. 

V Spike Analysis
Spiked samples are employed to monitor recoveries, to maintain extraction, digestion and 

concentration techniques at acceptable levels, and to assess analytical accuracy. Spiking samples 

provides information about the effect of the sample matrix on the analyte of interest. A ratio of one 

spike for each twenty (20) samples analyzed is maintained. The sample used as the duplicate is 

spiked as specified in the Quality Control Procedures. The Percent Recovery results are tabulated 

periodically and reviewed for trend analysis.

VI Performance Evaluation Testing

Annually, at a minimum, each laboratory must participate in a performance evaluation testing 

program. Results must be reported during each calendar year. The company’s Quality Assurance 

Officer or designee reviews results and generates a report summarizing performance. Each 

laboratory receives a copy of the results and must investigate any outliers and undertake corrective 

action measures and report on 

investigations and corrective actions to the QA Officer. Summaries of performance are provided to 

company management.

VII Reports

On a quarterly basis, each laboratory must submit a Quality Control Statistical Summary to the QA 

Officer. This summary includes: LCS summary data, Duplicate or Matrix Duplicate summary data, 

and Spike or Matrix Spike summary data.