## EPA WAP Issues

 **Section 1.0 indicates that procedures apply**  **to hazardous and non -**  **hazardous waste. Agenc**  **y w** **ants it also to**  **appl y**  **to all material entering the incinerator including fuels (natural gas)**

**. 1.0**  **INTRODUCTION** The purpose of this Waste Analysis P lan (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. T hese proced ures shall apply to all hazardous and non hazardous 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 d efined 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 assu**  **re that all lay ers are analy**  **zed? Explain methodology** 

**. 2.2**  **Ty pe of Containment** 

In addition to American Society for Te sting Materials (ASTM) and other EPA

-approved sampling procedures, TW I has instituted specific methodologies for ensuring that samples taken from various types of containers are representative. T he type of container may be transportable such as drums, por table transport units (e.g. small tanks, roll off boxes), and tanker trucks; or stationary (e.g., tanks) and in

- process sources. T he sampling devices are selected, depending on the size and type of containment and on the specific material involved. Becaus e 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). W hen 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. I n 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 sludg es, proportionate amounts of the sample are sub

- sampled for analysis.

 **Section 5.2.3 Add**  **conform ance 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. I n order to determine whether a particular incoming waste stream conforms to the profile, the following criteria will be used. All oth er Mandatory and Supplemental analysis data collected will be used to allow TW I 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. I f 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 con formance as follows:Profiling Analytical Result Acceptable Range <2 <2 2

- 12.5 2

- 12.5 >12.5 >12.5 Wa stes 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 i f 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 i n 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 t he profiling phase does during the incoming shipment procedures). 3. PCBs: The unexpected presen ce 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. T WI i s 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 signifi cant 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

s ignificant variation in the color ranges speci fied 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. Som e wastes types may be described as “varies” due to the type and variability of the constituents. F or example, debris wastes may include blue gloves, white rocks, green leaves, and brown absorbent. S ignificant variations in color ranges would initiate the procedures outlined in Section 5.2.4.
7. Phases : A

s ignificant variation in the number and type of phases specified in the profile documents may indicate a change in the waste stream. W astes 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 sample rs 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**  **A naly** **sis List (mandatory analy** **sis may**

**al so be**  **performed on a generator supplied sample if the generator supplied information is not sufficient).**  **FIGURE 3 -**  **1 SUMMARY OF ANALYSIS**  **INCOMING PA** **RAMETER PROFILE**  **WASTE**
**Ph ys**  **ical Description X**  **pH Screen X**  **X Cy** **anide S creen (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**  **Acidit y/** **Alkalinity S**  **Sulfide Screen (1) X**  **Liquid Waste Compatibility S**  **Apparent Viscosity**

**(5) X**  **S Pentachlorophenol Screening**  **S Chlorophenox** **y Herbicides HPLC**  **S Mercury**  **X(7) S**  **(7) Fluorine**  **S Bromine**  **S Metals**  **S Confinement Test**  **S**
**X = Mandatory** 

**A naly**  **sis S = Supplemental Anal**  **ys is**  **(1) Does not apply**  **to waste with pH <=2 (2)**  **Does not**  **apply**

**t o**  **waste alread**  **y in**  **contact with excess water. (3)**  **Performed on**  **suspect wa** **ste only** **, according to PCB Polic** **y. Not**  **performed on**  **waste that**  **pr esent**  **a s**  **afety hazard.**  **(4) Not performed on waste to be**  **blended. (5)**  **Liquids only**

**. (6)**  **Bulk liquids only**

**. (7)**  **Mercury**

**a naly**  **sis will**  **be completed**  **during profiling on suspect waste only**

**.** **Section 4.1.4 Exceptions to Profili**  **ng 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 Mat** **erial, expand definition and need to address when Hg analy** 

**sis 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 la b 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 (S QCG'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 T

WI for review to ensure compliance with the SQCG’s. This drum inventory sheet must be reviewed and approved for each container by the T WI 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 d oes 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 analy** **sis includi**  **ng 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 process es, 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 s imilar 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 Pro file 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, W astewater Treatment Slu dge 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 b e gained from additional analysis of a K040 waste. Much in the same manner as how the EPA developed the Phorate treatment standard forK040 (0.021 mg/l for wastewaters and 4.6 mg/l for non

-wastewaters) through repeated analytical for LDR constituents, Veo lia 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. Wh en 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 Analy** **sis Procedures (same comments as those addressed in 4.1**  **.4)**
5.1.1 Exceptions to Incoming W aste 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 n ot 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, syringe s, lab coats, tyveks, gloves , etc.) packed by Veolia E S 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 vi sually 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 3 5 IAC 721.107(b) in quantities greater th an 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. TW I will visually inspect 5% of the incoming con tainers.

 **Section 5.2.3 An Evaluation of Whether a Waste is Found to be in Conformance or Non**  **** **conformance, 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 stre am conforms to the profile, the following criteria will be used. All other Mandatory and Supplemental analysis data collected will be used to allow TW I 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 normal ly 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 Wa stes profiled as pH 2 to pH 12.5 but shipped with an accompanyi ng 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. W astes 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 andvariability 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. Wa stes are typically described as solid, sludge, or liquid. If the waste is profiled as one or any combination of the phases, the wa ste 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 ind icate a change in the waste stream and would initiate the procedures outlined in Section 5.2.4.

 **Section 6.3.1 Pre**  **- treatment Anal**  **ys es, need to add Hg analy** **sis to list of required analy** **sis.**
6.3.1 Pre

-treatment Analyses All wastes fed to the incinerato r 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 wh ich 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. T he 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 i nto the incinerators. The maximum chlorin e 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 informa tion is used to assure that the specific gravity of bulk or decant compos ite 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 defin**  **ed 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 accordanc e 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 W ater and W astewater 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 Wa ste: Physical/Chemical Metho ds, SW

- 846, Third Edition, Final Update III, U.S. EPA, Office of Solid Wa ste, Washington, DC, Chapter One, or most recent addition. Quality procedures are applicable to both sampling procedures and analytical techniques. This section does not provide sp ecific 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 andwhich are available for regulatory review. Portions of these p olicies 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 WA P. 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 sa mpling 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 selectio n 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. Wi th some exceptions, all bulk and containerized waste shipments are sa mpled (see Section 5.1.1 of this WA P. 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 ma intained 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 anal yses 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. W henever 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 perform ed
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 P ercent Difference.

V Spike AnalysisSpiked 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 t he 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 investi gations 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.