Waste Analysis Plan Guidance - Ohio EPA

1 THIS POLICY DOES NOT HAVE THE FORCE OF LAW Waste Analysis Plan GuidanceA guide for preparing and reviewing Waste Analysis plans submitted with Part B of theOhio Hazardous Waste Facility Installation and Operation permit applicationOhio Environmental Protection AgencyDivision of Hazardous Waste ManagementEngineering and Risk Assessment SectionStreet Address:Lazarus Government Center122 S. Front Street, Columbus, Ohio 43215-1099 Mailing Address: Box 1049, Columbus, Ohio 43216-1049 FINALJune 2000 Table of ContentsTable of ContentsSectionSectionSection 1 Section 2 Section and 3 Section Analysis Plan of Waste Generating Processes and and Classification of Hazardous Wastes of Hazardous Waste Management Analysis Parameters OAC Rule 3745-54-13(B)(1).

2 Page of Waste Analysis Information Regarding Selection of Fingerprint Mandatory and Supplemental Procedures OAC Rule 3745-54-13(B)(3)..Page and Decontaminating Sampling Preservation, Holding Times, and Quality Assurance and Quality Control and Safety and Analytical Methods OAC Rule 3745-54-13(B)(2)..Page and Analytical Quality Assurance and Quality Control of Acceptable Generator Knowledge in TSDF Waste Re-evaluation Frequencies OAC Rule 3745-54-13(B)(4)..Page Procedural for Off-Site Facilities OAC Rule 3745-54-13(C); OAC Rule 3745-54-13(B)(5).

3 Page for Ignitable, Reactive, and Incompatible WastesOAC Rule for Complying with LDR Waste Analysis requirements OAC Rule Requirements for Bulk and Containerized Liquids OAC Rule 3745-54-13(C)(3); OAC Rule Analysis for Incineration Facilities OAC Rule Impoundments OAC Rule 3745-54-13 (B)(7)..Page 28 Section List of Analysis Plan containers, preservation, holding Page Analysis Page 67 Waste Analysis Plan GuidanceFinal June 2000-1-Section IntroductionSection IntroductionWaste Analysis involves identifying or verifying the chemical and physical propertiesof Waste , either by testing or, in certain situations, by applying knowledge of the Analysis Plans (WAPs)

4 Are written plans which document the procedures used toperform Analysis of Waste generated, treated, stored, or disposed at hazardous wastemanagement facilities. WAPs are submitted as a requirement of Part B of the OhioHazardous Waste Facility Installation and Operation Permit application, and as suchbecome an enforceable part of the permit. A WAP is required of every permittedTreatment, Storage, or Disposal Facility (TSDF) in the State of Ohio. The primary purpose of this Guidance is to assist State of Ohio hazardous wastefacility permit writers in the review of WAPs submitted with Part B of the permitapplication.

5 It may also be used by the regulated community in the preparation of Guidance has two parts: a narrative portion and a checklist. The narrativeportion of this Guidance describes the level of detail expected and provides technicalsupport for key elements of WAPs. It provides the Ohio Administrative Code (OAC)regulatory citation, and specific requirements permit writers should look for when reviewingWAPs. The checklist should also be used in the actual review of WAPs. Using thechecklist, the permit reviewer will be able to determine if the plan is complete andtechnically adequate.

6 Included here as Appendix I, this checklist may also be found in thereview tool for Part B applications. Waste Analysis Plan GuidanceFinal June 2000-2-Section ApplicabilitySection ApplicabilityThis Guidance is applicable to all facilities subject to the permitting requirements ofOAC Chapter 3745-50. The specific requirement for submittal of a Waste Analysis plan isdetailed in OAC Rule 3745-50-44 (A)(3), Contents of the Part B Permit Application . Facilities accumulating hazardous Waste under OAC Rule 3745-52-34 that alsotreat hazardous wastes in tanks or containers to meet applicable treatment standardsunder OAC Rule 3745-59-40 to OAC Rule 3745-59-44 are required to develop andmaintain a written WAP in accordance with OAC Rule 3745-59-07(A)(4).

7 While notspecifically focused on this portion of the regulated community, certain parts of thisguidance may apply to facilities preparing these plans. Additionally, non-permitted facilities that do not conduct treatment of hazardouswaste in tanks or containers may opt to use this Guidance to develop a WAP. WAPs,though not required of these facilities, offer many advantages, including promotion ofwaste management consistency, demonstration of compliance, and reduction of potentialliabilities associated with mis-characterization of wastes.

8 Waste Analysis Plan GuidanceFinal June 2000-3-Section Definitions and AcronymsSection Definitions and Methods for Evaluating Solid Waste , Physical/ChemicalMethods. SW-846, EPA (most recent revision)DQOData Quality ObjectiveIRII gnitable, Reactive, or IncompatibleQA/QCQuality Assurance / Quality ControlOSHAO ccupational Safety and Health Act / AdministrationLDRLand Disposal RestrictionTSDFT reatment, Storage, or Disposal Analysis - abbreviated Waste Analysis conducted for Waste parameterswhich may verify that a Waste received from an off-site source matches the expectedcharacteristics for that Waste .

9 Facility - a facility that receives and manages hazardous Waste from anotherfacility that is not geographically on site. Facility - a facility that manages only those hazardous wastes which aregenerated on it s geographically contiguous Analysis Plan - a written plan which documents the procedures used toperform Waste Analysis Profile Sheet - a written form completed by the generator as a Waste pre-acceptance condition with the TSDF. The Waste profile sheet contains detailedinformation on the physical and chemical characteristics of the Waste .

10 Conditions - the expected high and low values of a characteristic based onhistorical average Analysis . Limits - the high and low values of a characteristic between which a wastemanagement unit can manage Waste and still meet permit, process, or Analysis Plan GuidanceFinal June Sample - a sample of a universe or whole ( Waste pile, lagoon,ground water) which can be expected to exhibit the average properties of theuniverse or - the information collection process where a complete physical andchemical Analysis (sufficient to treat, store, or dispose of the Waste )