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WASTE ANALYSIS PLAN

FOR

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.
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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 6

3.0 ANALYTICAL RATIONALE 8

3.1 Mandatory Analyses 8

3.2 Non-hazardous Waste Analyses 10

3.3 Supplemental Analyses 10

4.0 PROFILING PROCEDURES 14

4.1 Procedural Requirements 14

4.1.1 Information Provided by Generator 14

4.1.2 Waste Management Decision 16

4.1.3 Waste Re-evaluation 16

4.1.4 Exceptions to the Foregoing Requirements 16

4.1.5 Standard Profiles 18

4.2 Decision Evaluation Logic for Profiling Procedures 19

5.0 INCOMING WASTE SHIPMENT PROCEDURES 23

5.1 Receiving Procedures 24

5.1.1 Exceptions to Incoming Waste Analysis Procedures 25

5.2 Incoming Waste Shipment Decision Evaluation Logic 27

5.2.1 Waste Identification 27

5.2.2 The Need For Additional Analysis 28

5.2.3 An Evaluation of Whether a Waste is Found

to be in Conformance or Non-conformance 28

5.2.4 An Evaluation of Whether Wastes Found to be in

Non-conformance can be Accepted or will be Rejected 28
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6.0 PROCESS OPERATIONS PROCEDURES 31

6.1 Storage 31

6.1.1 Waste in Containers 31

6.1.2 Waste in Tanks 31

6.1.3 Bulk Solids Storage 33

6.2 Decanting 33

6.3 Incineration 33

6.3.1 Pre-treatment Analyses 33

6.3.2 Treatment Residue Evaluation 34

7.0 QUALITY CONTROL POLICY 35

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/NON-CONFORMANCE

APPENDIX WAP-E: CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURE

APPENDIX WAP-F: BIBLIOGRAPHY OF STANDARD CHEMICAL REFERENCE 

MATERIALS

APPENDIX WAP-G: HM-181 COMPATIBILITY CLASSES

PCB SCREENING POLICY

DIOXIN ANALYSIS POLICY
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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, Veolia ES Technical Solutions, LLC has developed this Waste 

Analysis Plan as an integral part of the RCRA Part B Permit Application for its 

facility located in Sauget (St. Clair County), Illinois. References to the company will 

further be known as Veolia. 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 safe management of all wastes which enter this facility for 

treatment or storage. These procedures 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 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 s

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 
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changes in regulations, customer needs, facility operations, or company policies. Veolia 

will provide notification to the IEPA-DLPC Permit Section as required by 35 IAC 703.280.

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

means the facility laboratory, any Veolia laboratory, any Veolia subsidiary laboratory, or 

any Veolia designated contract laboratory.

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 follow the new requirements such as testing 

and frequency prior to receipt and/or processing of the regulated waste as specified by

the new Regulations. 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., heterogeneous 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 
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updated and revised.

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 practical.

Certain waste materials will require deviations from 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, Veolia 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., fulldepth 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.
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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 thief is used to obtain a sample (or other appropriate device 

as listed in Table 2-1).

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 thief 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.
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TABLE 2-1

SAMPLING METHODS AND EQUIPMENT

_________________________________________________________________________

MATERIAL METHOD EQUIPMENTc

_________________________________________________________________________

Extremely viscous liquid ASTM D 140-70aor Tube samplerd, thief, 

ASTM E 300aor Coliwasa

Crushed or powdered ASTM D 346-75aor Tube samplerd, thief,

ASTM E 300ascoop, or shovel

Soil ASTM D 420-69aor Tube samplerd, thief,

ASTM E 300aauger, scoop, or shovel

Soil-like material ASTM D 1452-65aor Tube samplerd, thief,

ASTM E 300aauger, scoop, or shovel

Fly ash-like material ASTM D 2234-76aor Tube samplerd, thief,

ASTM E 300aauger, scoop, or shovel

Containerized liquids SW-846bor Coliwasa/tube 

ASTM E 300asamplerd, weighted bottle,

bomb, or tank sampling ports 

_________________________________________________________________________

a

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

recent edition.

b

-- "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).

c

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

Section 2.2.

d

-- 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.
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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 Veolia by the waste generator on the 

Waste Profile Sheet (WPS, Figure 4-1). The generator supplies Veolia 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 Veolia 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 minimum, all incoming wastes are subjected to the Mandatory 

Analyses as a 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 may 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.

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:
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-- Provide the information concerning the waste which is pertinent to the 

safe storage, processing and incineration of the waste;

-- Provide Facility Management with data which can be used to evaluate the 

consistency of information provided by the generator.

Incoming Mandatory Analysis 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 (Cl) 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 Veolia Part B 

RCRA Permit is not accepted by the facility.
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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 100oF.

6. Liquid Waste Compatibility (Water Mix) 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.

7. Cyanide 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. 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. 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

All protocols defined in this plan for the acceptability and safe management 

of hazardous waste apply to all non-hazardous waste which are candidates for

acceptance and management at the facility.

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 

rationale.

 
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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 Veolia, which have been found to be preferable for waste identification. 

These analyses will meet Veolia company performance standards. Others are standard 

analytical techniques recognized by the U.S. EPA and ASTM. The parameters which 

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

determining these parameters are in Appendix WAP-A.

 1. Liquid Waste Compatibility (Tanks) 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.

2. Gas Chromatography Scan is used to separate and identify certain 

organic compounds.

3. Metals (e.g., As, Be, Cd, Cr, K, Na, Pb, Hg) identifies metal concentrations 

in wastes to determine feedrates for compliance with Subpart EEE or for 

process control.

4. Closed Cup Flash Point identifies ignitable liquid wastes for storage 

purposes. This test may 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.

5. 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.

6. 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.

7. 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 
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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 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. 

8. Liquid Waste Compatibility (Drums) 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.

9. PCBs are run 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 the Veolia PCB Suspect Analysis Policy. Materials 

containing PCBs above 50 ppm will not be accepted. Organic extractions 

will not be performed on wastes that present a safety hazard.

10. 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 Veolia Dioxin Suspect Analysis 

Policy.

11. 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 Veolia Dioxin Suspect Analysis 

Policy.

12. Ash Content is used to determine the percent ash in liquid waste feeds.

13. Fluorine Content is used to determine the percent fluorine in liquid waste 

feeds.

14. Bromine Content is used to determine the percent bromine in liquid waste 

feeds.

15. 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

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 (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) 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.
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4.0 PROFILING PROCEDURES

Veolia 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 Veolia 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 Ill. 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 Ill. 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 Veolia facility for treatment, storage or 

disposal, a determination has previously been made by the generator (and reviewed by

Veolia) that the waste is either:

o a characteristic waste as defined in subpart C of 40 CFR 261 

and/or subpart C, 35 Ill. Adm. Code 721,

o a listed hazardous waste as defined in subpart D of 40 CFR 261 

and/or subpart B, 35 Ill. Adm. Code 721,

o a solid waste which is not a hazardous waste as defined in 40 CFR 

261.4(b) and/or 35 Ill. Adm. Code 721.104(b).

The generator's supplied characterization (Waste Profile Sheet (WPS), 

Figure 4-1 in Section 4.1) provides Veolia 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 Veolia 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:
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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;

Flammability Potential (liquids only)

PCB (if applicable to PCB Policy and Safety Policy)

Apparent Viscosity (liquids only)

pH Screen

Radioactivity Screen

Where the generator does not provide analytical data, for 

the above items, the data will be developed by Veolia 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 Veolia 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 Ill. Adm. Code 721, 

Appendix A or equivalent methods.

(4) Land Disposal Restriction (LDR) Notification/Certification I

information and/or Data (40 CFR Part 268): 

(5) Material Safety Data Sheets, for single component materials or 

commercial products. If an MSDS is not available, a sample must 

be provided.

(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.

Veolia maintains as part of its profiling information generatorsupplied and Veolia developed information. This information may be 

accessed electronically or via hard copy.
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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.

4.1.3 Waste Re-evaluation

In accordance with 40 CFR 264.13 and/or 35 Ill. Adm. Code 724.113, a 

waste profile re-evaluation will be conducted when one of the following occurs:

o A generator notifies Veolia 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 Veolia may obtain a sample from a shipment of the waste.

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 Veolia for review to ensure compliance with 
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the SQCG’s. This drum inventory sheet must be reviewed and approved for 

each container by the Facility Management prior to acceptance at the 

facility. Veolia 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. See Section 5.1.1(1) for a 

complete description of Incoming Waste Shipment procedures for small 

quantity chemical drums. Occasionally, Veolia determines that a particular 

material is not acceptable and so notifies the customer. These drums will be 

tracked on-site for the purposes of determining waste storage compatibility 

by manifest/profile/unique drum identification combination until the material 

is rejected.

(2) Empty containers as defined in 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).

(3) Pharmaceutical and commercial products or chemicals: offspecification, outdated. These materials are packaged in consumer 

quantities, unused or banned, in their original packaging or packaged as 

specified by Veolia.

(4) Aerosol cans, Lecture Bottles or Gas Cylinders.

(5) Controlled substances regulated by the Federal Government. 

These are typically generated by pharmaceutical companies, 

health care companies, state or Federal Agencies.

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

knowledge exists will require Hg analysis.

(7) Wastes which are visually identifiable through an inspection

process. Examples of these types of wastes are, PPE, 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. 

Visually identifiable material will be specified on the Waste Profile Sheet.

(8) 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.

(9) Explosive, Poison Inhalation Hazard (PIH) and Odiferous material 
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(e.g.,mercaptan) which present sampling, and analytical safety 

hazards or community nuisance odor problems, can be exempted 

by Facility Management without prior Agency approval. The list is 

inclusive.

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 Veolia 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.

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. Veolia 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 
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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. 

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 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 judgment 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.

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.
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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. 

Handling and analytical requirements will be prepared from information gathered during 

the profile process (generator name, profile number, results of profile analyses, decisions 

restrictions, etc.). A copy (photocopy or electronic) of this information will be made at the 

time the waste is scheduled to transmit profile and handling information to operations and 

the laboratory for the Incoming Waste Acceptance process. 
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FIGURE 4-1

GENERATOR'S WASTE MATERIAL PROFILE SHEET
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FIGURE 4-2

WASTE MANAGEMENT DECISION
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5.0 INCOMING WASTE SHIPMENT PROCEDURES

In accordance with 264.13(c) and/or 35 Ill. 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 Veolia personnel (or a Veolia 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 Restrictions 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.
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5.1 Receiving Procedures

Incoming waste shipment identification begins upon arrival of the waste at 

the facility. The only exception to this would be extraordinary circumstances (e.g. DEA 

drug clean-up, sensitive military waste, etc.) where the waste would be sampled or 

visually inspected on site by a Veolia representative. The trailer would be sealed and 

transported to the facility. Only then would the seal be opened. 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 (Section 

4.1.4), each container of liquids in the shipment will have its contents visually inspected 

by observing a full depth vertical sample, if possible, to verify that the contents are similar 

prior to compositing. Similar is defined as the same color and phase as it relates to the 

waste stream profile description. If the waste is residual from a process, similar means 

same color and same number of phases. If the profile description is plant debris, many 

colors and phases may be seen, however, the assessment of similar is that the material is 

debris-like in nature. 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 be 

visually inspected for color and phase (liquid, solid, semi-solid). Drums of direct charge 

packaged chemicals will be randomly opened and inspected to verify that the drum is 

packed as identified in Section 5.1.1.

After the inspection, ten percent of the containers from each waste profile 

within a shipment which are similar, will be sampled, according to Section 2.0. In the 

event that a single drum of a specific waste profile is received, or single drums within a 

profile or not similar, those individual drums will be sampled. A maximum of five 

containerized shipment samples from the same waste profile may be composited prior to 

analysis, provided the individual samples are similar.

Containers to be sampled, will be selected randomly. Drum numbers will 

be assigned randomly to the drums in a shipment upon off-loading prior to inspection or 

sampling. 

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

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

3. Broken bottle(s) and label(s) destroyed, but material identifiable 

with logical deduction and DIS review;

4. Extra containers of identified material;

5. Extra identifiable and acceptable material;

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

absorbent bags, cardboard);

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

8. Non-containerized compound but identifiable from DIS;

9. Missing label but container type/size match DIS. Processable 

drums will be accepted and processed. The generator of 

processable drums will be notified of the inaccuracies associated 

with the processable drum. The generator 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 

from sending hazardous waste to Veolia for treatment.
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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.

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 that does not meet the

 RCRA empty definition defined in 35 IAC 721.107(b). 

3) Pharmaceutical and commercial products or chemicals consumer 

quantities in their original packaging. Veolia will visually inspect 5% 

of the incoming outer containers of these materials to verify that 

the shipment contains consumer packages. 

4) Aerosol Cans, Lecture Bottles or Gas Cylinders: These wastes will 

be visually inspected upon receipt or during processing into 

burnable charges.

5) Controlled substances will not be opened or sampled by Veolia due 

to the regulations governing these materials. Veolia 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.

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

knowledge exists. Veolia will visually inspect 5% of the incoming

containers.

7) 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 PPE, batteries, cathode ray tubes, crushed glass, piping, 

filters and filter cartridges, wire or tubing, paper products, syringes, 

metal sheeting and parts, explosive components and devices. This 
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list is not meant to be all inclusive. Visually identifiable material will 

be specified on the Waste Profile Sheet.

8) 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.

9) Explosive, PIH, and odiferous material (e.g., mercaptan) which 

present sampling, and analytical safety hazards or community 

nuisance odor problems can be exempted by Facility Management 

without prior Agency approval. This list is inclusive.

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 2.0, 3.0, and 5.1 Facility Management will review 

one or more of the following: the profile information, the Mandatory Analyses, 

Supplemental Analyses, and the manifest to determine whether the material received 

conforms with the profile information, 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 will be documented (see example 

form). Determination of conformance with specific parameters will be determined as 

described in Appendix WAP-D.
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5.2.2 The Need for Additional Analyses

Facility Management may perform additional analyses according to the 

criteria in Section 3.3 when or results of the Mandatory Analyses or visual inspection do 

not conform or are inconsistent with profile information (i.e., if a waste is nonconforming 

as described in Appendix WAP-D or information gathered is mutually exclusive based on 

scientific facts and principles). 

5.2.3 An Evaluation of Whether a Waste is Found to be in Conformance or Nonconformance

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 Ill. 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 weight, 

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

count (e.g., the number of pieces listed on the manifest 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. 
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If information gathered during this evaluation can resolve the discrepancy, 

the resolution of the discrepancy will be documented 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.

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 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, Veolia 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 Veolia’s 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.
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FIGURE 5-1

PHYSICAL DESCRIPTION WORKSHEET
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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 does not apply to material which have 

been repackaged, generated, or solidified due to the fact that the material no longer 

exhibits hazardous characteristics and are solids.

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 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.
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6.1.3 Bulk Solids Storage

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

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 HCl and particulates, and other treatment 

residues (i.e., 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 next 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.
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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.

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.

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.
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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 certified to meet the 40 CFR 268 Land Disposal Standards or is 

re-incinerated and subsequently sampled, analyzed and certified to meet the 40CFR 268 

Land Disposal Standards. 

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 analytical data.

In the event that the analysis does not meet the appropriate treatment 

standard (i.e., CCWE values), Facility Management will investigate the sampling 

procedure and the analytical procedure to ensure no contamination is present. Two 

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

treatment standards in the first round 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 analysis does not meet the 

appropriate treatment standard (i.e., CCWE values), Veolia will retreat the residues in 

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

Veolia may forego additional sampling and analysis and choose to retreat the residue 

which did not initially meet the treatment standard.
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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 Veolia 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.
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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 
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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.

7.3 Conclusion

The aforementioned sampling and analytical quality practices help ensure that the 

data obtained are precise and accurate for the waste stream being sampled. The 

analytical results are used by facility management to decide whether or not to accept a 

particular waste and, upon acceptance, to determine the appropriate method of 

treatment, storage, and disposal. Results are also important to ensure that wastes are 

managed properly by the facility and that incompatible wastes are not inadvertently 

combined. The quality of these results is as important as the results themselves. Thus, 

the quality of the analytical data, the thoroughness and care with which the sampling and 

analyses are performed and reported, provides an important basis for day-to-day 

operational decision.
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WAP-A-1

APPENDIX WAP-A

ANALYTICAL PROCEDURES
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WAP-A-2

APPENDIX WAP-A 

ANALYTICAL PROCEDURES

The following analytical procedures are designed to identify or screen 

waste. They are used by Veolia ES Technical Solutions, LLC 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. 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.

II. STANDARD ANALYTICAL PROCEDURES

PARAMETER METHOD REFERENCE

Sample Work Up Techniques:

Inorganic Techniques

Acid digestion procedure for flame atomic 1-3010

absorption spectroscopy

Acid digestion procedure for furnace

absorption spectroscopy 1-3020

Acid (Parr) Bomb digestion 3-E886; E926; 6-Bulletin 4745

Acid digestion of oils, greases, or waxes 1-3030

Dissolution procedure for oils, greases,

or waxes 1-3040

Acid digestion of sludges 1-3050

Alkaline digestion (for solids) 1-3060

Organic Techniques

Separator funnel liquid-liquid extraction 1-3510

Continuous liquid-liquid extraction 1-3520

Acid-base clean-up extraction 1-3530

Soxhlet extraction 1-3540

Alumina Column Clean-up and Separation of Petroleum Wastes 1-3611

Flurosil Column Clean-up 1-3620

Silica Gel Clean-up 1-3630

Sulfur Clean-up 1-3660

Waste Dilution I-3580

Inorganic Analytical Methods:

Inductively Coupled Plasma Atomic Emission 

Spectroscopy (ICP) 1-6010

Antimony

Atomic absorption, direct aspiration method 1-7040; 4-204.1
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Atomic absorption, furnace method 1-7041; 4-204.2

Arsenic

Atomic absorption, furnace method 1-7060; 4-206.2

Atomic absorption, gaseous hydride method 1-7061; 4-206.3

Barium

Atomic absorption, direct aspiration method 1-7080; 4-208.1

Atomic absorption, furnace method 1-7081; 4-208.2

Beryllium

Atomic absorption, direct aspiration method 1-7090; 4-210.1

Atomic absorption, furnace method 1-7091; 4-210.2

Cadmium

Atomic absorption, direct aspiration method 1-7130; 4-213.1

Atomic absorption, furnace method 1-7131; 4-213.2

Calcium

Atomic absorption, direct aspiration method 1-7140; 4-215.1

Atomic absorption, furnace method 4-215.2

Chromium

Atomic absorption, direct aspiration method 1-7190; 4-218.1

Atomic absorption, furnace method 1-7191; 4-218.2

Hexavalent chromium: CO-precipitation 1-7195

Hexavalent chromium: Colorimetric 1-7196; 2-3500CrD

Hexavalent chromium: Chelation-extraction 1-7197; 4-218.4

Copper

Atomic absorption, direct aspiration method 1-7210; 4-220.1

Atomic absorption, furnace method 4-220.2

Iron

Atomic absorption, direct aspiration method 1-7380; 4-236.1

Atomic absorption, furnace method 4-236.2

Phenanthroline method (ferrous) 2-3500FeD

Lead 

Atomic absorption, direct aspiration method 1-7420; 4-239.1

Atomic absorption, furnace method 1-7421; 4-239.2

Magnesium

Atomic absorption, direct aspiration method 1-7450; 4-242.1

Manganese

Atomic absorption, direct aspiration method 1-7460; 4-243.1

Atomic absorption, furnace method 4-243.2

Mercury (manual cold-vapor technique)

In liquid waste 1-7470

In solid or semi-solid waste 1-7471

Nickel 

Atomic absorption, direct aspiration method 1-7520; 4-249.1

Atomic absorption, furnace method 1-7521; 4-249.2

Selenium 

Atomic absorption, furnace method 1-7740; 4-270.2

Atomic absorption, gaseous hydride method 1-7741; 4-270.3

Silver 

Atomic absorption, direct aspiration method 1-7760; 4-272.1

Atomic absorption, furnace method 1-7761; 4-272.2
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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 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 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-

Screening 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

Bulk Density and Apparent Specific Gravity Screen 3-D5057
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PARAMETER METHOD REFERENCE

Miscellaneous Analytical Methods:

Acidity 2-2310

Alkalinity 2-2320

Ammonia 4-350.3

Anions by Ion Chromatography 3-D4327; 4-300.0

Ash Content 3-D482, D3174

Bromides 2-4500Br-; 4-300.0, 320.1

Chlorides 2-4500Cl-; 4-300.0, 325.3

Conductivity/Conductance 3-D1125; 4-120.1

Extraction Procedure 1-1310

Flash point

Pensky-Martens closed-cup method 1-1010; 3-D93

Setaflash closed-cup method 1-1020; 3-D3278

Cleveland open-cup 3-D92

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

Free Cyanides 2-4500CN-H,I

Halogen Content 3-D808, D2361, D4327

Heat Value 3-D240, D2015

Oil and Grease 2-5520; 4-413.1, 413.2

Oxidation-Reduction (Redox) Potential (ORP) 3-D1498

Petroleum Hydrocarbons, Total Recoverable 2-5520F; 4-418.1

Phenols 2-5530, 6420; 4-420.1

pH Measurement 1-9040, 9041, 9045; 2-4500H+; 3-E70; 4-150.1

Phosphates 2-4500P; 4-300.0, 365.1-4

Radioactivity Screen

Solids

Total (TS) at 103-105oC 2-2540B; 4-160.3

Dissolved (TDS) at 180oC 2-2540C; 4-160.1

Suspended, Total (TSS) at 103-105oC 2-2540D; 4-160.2

Fixed and Volatile at 500oC 2-2540E, 2540G; 4-160.4

Specific Gravity 2-2710F; 3-D70, D891, D1217, D1429

Sulfates 2-4500SO4

2-

; 4-300.0, 375.3

Sulfur 3-D129, D3177, D4327

Total and Amenable Cyanides 1-9010A; 2-4500CN-C,G; 4-335.1

Total Chlorine Content 3-D808, D4327

Total Organic Carbon 2-5310; 3-D2579

Total Sulfides 1-9030; 2-4500S2-

Toxicity Characteristic Leaching Procedure (TCLP) 1-1311

Viscosity 3-D88, D446, D2983

Water Content 3-D95, D3173, E203
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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", EPA600/4-79-020,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.

Standard analytical procedures listed here which are revised can be implemented 

upon the effective date of the revision, without notification to the IEPA.
WAP-B-1

APPENDIX WAP-B

ASH AND DRY SCRUBBER SOLIDS
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SAMPLING PROTOCOL

APPENDIX WAP-B

ASH AND DRY SCRUBBER SOLIDS

SAMPLING PROTOCOL

1.0 PURPOSE

The Veolia 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 (or via the electronic Chain-of-Custody system) 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 Chain-of-Custody record. 

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 Veolia laboratory or Veolia 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 the facility Standard Division 

Practice 1651.
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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 Veolia. 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 Veolia approved hazardous 

waste management facilities. The manifest and Land Disposal Restriction Treatment 

Certification will be completed prior to shipment.
WAP-C-1

APPENDIX WAP-C

WASTE ACCEPTABILITY CRITERIA
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WAP-C-2

APPENDIX WAP-C

WASTE ACCEPTABILITY CRITERIA

The following restrictions apply to the acceptance of wastes exhibiting certain 

properties or specific wastes at Veolia. 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, or common names. 

The nature of the restrictions is as follows:

REJECT - These Materials may not be processed at the facility.

Radioactive Wastes

Thorium Compounds

Uranium Compounds

Radioactive materials as defined by the Veolia 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)

Regulatory Specified Treatment Technology other than Incineration

D006 NiCd Batteries
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DOO8 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 Veolia 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
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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, Veolia 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, Veolia will determine if a larger charge size is acceptable.

2) When it has been determined that a larger charge size is acceptable,

Veolia will either:

a) Determine if this type of material has been previously processed at 

Veolia 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 >100oF

> 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.

Dioxin Waste

See-Veolia’s-Dioxin-Analysis-Policy.
WAP-D-1

.

APPENDIX WAP-D

DETERMINATION OF INCOMING WASTE
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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).

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 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. 
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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.
WAP-E-1

 

APPENDIX WAP-E

CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURES
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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 sub-samples 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 its integrity. After 

opening, the container's contents will be visually inspected to determine whether or not it 

conforms to 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 Veolia 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.

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;
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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 to cut 

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-F-1

APPENDIX WAP-F

BIBLIOGRAPHY OF STANDARD CHEMICAL REFERENCE MATERIALS
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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. Computerized MSDS system, current version.

6. Farm Chemicals, Current Edition, '91, Meister Publishing Co.

7. Chemical Synonyms & Trade Names, Current Edition, 1987 Gower 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.

These references are updated to the most current revision as they are made available 

and if significant changes have been made. Facility Management is responsible to 

assess when a revised reference is needed.
WAP-G-1

APPENDIX WAP-G

HM-181 COMPATIBILITY CLASSES
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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

NOTE: The Hazard Materials Load and Segregation Chart (49 CFR 177.848) that 

Veolia will follow is included on the next page.
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HM-181 COMPATIBILITY CLASSES

DOT Class Name Incompatible Class

1.1 - 1.6 Explosives 2.1, 2.2

3

4.1, 4.2, 4.3

5.1, 5.2

6.1

8

2.1 - 2.2 Aerosol Cans 1.1 - 1.6

2.3

6.1

8

3 Flammable Liquid 1.1 - 1.6

2.3

5.1

6.1

4.1 Flammable Solids 1.1 - 1.6

4.2 Spontaneously Combustibles 2.3

4.3 Dangerous When Wet 6.1

8

5.1 Oxidizers 1.1 - 1.6

5.2 Organic Peroxides 2.3

3

6.1

8

HM-181 COMPATIBILITY CLASSES

DOT Class Name Incompatible Class

2.3 Poisonous Gas Zone A & B 1.1 - 1.6

6.1 Poisonous Liquid Zone A 2.1

3

4.1, 4.2, 4.3

5.1, 5.2

8

8 Corrosives 1.1 - 1.6

2.1, 2.3

4.1, 4.2, 4.3

5.1, 5.2

6.1

9 Miscellaneous N.O.S. Debris 1.1 - 1.6

Non-Hazardous Material
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NOTES: • 6.1 Liquid PG I Zone A only

• Ignitables stack one high only

• Repacks/Solidifications - No. HM 181 Classification

• For Consolidated Liquids, Consolidated Solids and decant batches, Lab compatibility

testing will determine DOT Hazard Class. 
1

VEOLIA

PCB SCREENING POLICY
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PCB SCREENING POLICY

I. 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 non-liquid 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 non-liquid hazardous wastes continuing 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.
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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 0.016 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 mover 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 Veolia 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.

II. POLICY

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 Veolia laboratory or a Veolia approved laboratory.

C. Any waste that will be analyzed for PCBs in accordance wit this policy shall 

not be accepted for storage, treatment, or disposal until PCB analyses have been 

completed and evaluated.
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D. Any non-TSCA waste which meets the following criteria shall be treated as 

a PCB suspect waste until demonstrated, otherwise, through chemical analysis.

III. PCB SUSPECT WASTE CRITERIA

The following criteria have been developed by Veolia 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.

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 sole judgment based on their 

analytical experience to make the final determination if a waste stream exhibits the 

visual presence of oil.

C. Sewer Clean-up Wastes* and Municipal Waste Water Treatment Facility 

Sludge

*Note: all incoming loads of sewer clean-up waste will be analyzed for PCBs.

D. Bulk Laboratory Wastes

E. Baghouse Dusts from Secondary Smelters (e.g., copper, aluminum)

F. Any Waste as Designated by the Laboratory Manager

G. All Wastes, Liquids or Soils, from the following:

1. Electrical Utility Company
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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*

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

*Unless demonstrated non-TSCA

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.

If 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).
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If a waste stream meets any of the PCB Suspect Criteria and the sales 

sample analysis indicates PCBs are less than 5 ppm1or the regulatory limit (The EPA 

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 ppm1or 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. It is a 

conservative approach to protecting the integrity of non-TSCA facilities.
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VEOLIA

DIOXIN ANALYSIS POLICY

I. Policy Statement

Veolia is implementing this policy for the screening of wastes which may contain 

dioxin. This policy will identify the types of wastes which will be analyzed for dioxin 

precursors and/or dioxin.

II. Definitions

A. Dioxin: For purposes of this policy, dioxin is 2,3,7,8-tetrachlorodibenzo-pdioxin (2,3,7,8-TCDD).

B. Dioxin precursors: Dioxin precursors are similar in chemical composition to 

dioxins. For purposes of this policy, Dioxin precursors tested for are: 2,4,5-

trichlorophenoxy acetic acid, 2-(2,4,5- trichlorophenoxy) propionic acid 

(Silvex), Pentachlorophenol.

C. Testing Procedure (See WAP Appendix A):

1. HPLC:: High Pressure Liquid Chromatography

2. GC, GC/MS: Gas Chromatography, GC/Mass Spectroscopy.

3. Immunoassay screen: Semi-quantitative method of identifying the 

presence of pentachlorophenol.

III. Preacceptance Logic

The following criteria have been developed for defining a waste as dioxin suspect. 

These criteria are intended to supplement existing requirements which may have 

been imposed through permit or other conditions with Federal or state authorities. 

Wastes which meet the criteria in this section will be screened for dioxin precursors. 

Dioxin precursors with detectable hits above 100 ppm will require dioxin testing prior 

to receipt at the facility. Waste considered under these criteria remains

subject to all existing conditions imposed by Veolia policies and environmental 

directives. Dioxin Policy suspect wastes are defined as follows:
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A. Any waste from a process or remedial clean-up for which the generator has 

indicated on the “Generator’s Waste Profile Sheet” or any other supporting 

documentation that dioxins are present at any level. These wastes are considered 

suspect if they are subject to historical contamination from dioxins 

B. Wastes from the following:

1. Process, by-product or remedial clean-ups of material from:

a) Timber/Lumber treating facilities carrying the code K001

b) Pesticide/Herbicide manufacturing facilities carrying the code 

K043.

C. Wastes bearing EPA hazardous waste codes: F039, K085, K105 due to their 

dioxin treatment standards.

IV. Non-Conforming Waste at Receipt

When non-conforming material meets the criteria in Section III of this policy, dioxin 

precursor analysis will be performed.