WASTE ANALYSIS PLAN

Revision Date: 5/00
Process Code: Navy/Marines: ID-25-99; Air Force: HW01; Army: N/A
Usage: Navy: High; Marines: High; Army: High; Air Force: High
Compliance Impact: Low
Alternative for: Non-centralized, non-standard means of determining the
characteristics of wastes in order to determine proper disposal
Applicable EPCRA Targeted Constituents:
Various

Overview:

A waste analysis plan serves to standardize and optimize the required testing of wastes so that all wastes at a site are properly characterized prior to disposal in a simple and efficient manner. A waste analysis plan establishes the characterization frequency and analytical requirements to be satisfied for every identified waste at the installation and provides guidance for handling new wastes.

1. Responsibilities for Characterization Prior to Disposal: The personnel that make decisions regarding waste characterization and disposal must be trained in the regulatory requirements of the Resource Conservation and Recovery Act (RCRA), and must know who establishes and enforces those regulations in the generator's location. The applicable hazardous waste regulatory program could be operated by a regional office of the Environmental Protection Agency (EPA) or by an EPA-approved state agency. In this data sheet, only references to federal regulations are provided. However, additional or alternative state regulations may apply. All state programs have the same basic regulatory requirements as the federal program, but may also have additional requirements. It is critical that state-specific regulations be reviewed before waste management plans are developed.

Waste management personnel must understand the details of the characterization requirements described below so that any required testing and analysis can be integrated into the waste analysis plan. In addition to determining if a waste is covered by the RCRA hazardous waste regulations, a waste's characterization must also be sufficient to determine what waste disposal options (neutralization or other treatment, landfilling, incineration) are available for that waste.

For any waste that requires sampling and testing to determine its characteristics, the following information must be developed:

  • the required parameters for sufficient characterization,
  • the tools required for sampling,
  • the method used for sampling,
  • the holding time of the sample,
  • the laboratory analytical method to be used,
  • the degree of detail in the reporting data and quality control, and
  • the maximum allowable concentration of the parameters of interest for the desired means of disposal.

2. Characterization by Generator Knowledge of a Listed Hazardous Waste: The circumstances associated with the generation of each waste determine what means of characterization is required. First, the waste must fit the definition of solid waste stated in 40 CFR 261.2 and not fit the definition of any exclusions listed in 40 CFR 261.4. Excluded wastes may be covered by other regulatory programs, or may be allowable in the municipal solid waste stream if not prohibited by the local solid waste ordinance. Also, Appendix I of CFR 260 includes diagrams for generators to use as a basic reference to determine whether their operation is subject to control under RCRA Subtitle C rules. It is designed to help generators define with which of the regulations, if any, they should comply.

If a waste is a solid waste (by RCRA definition), it may be a "listed hazardous waste," as specifically defined in 40 CFR 261 Subpart D (Parts 261.30 through 261.35). If the waste meets the definition of a "listed waste," based on the circumstances of the generation of the waste, then documented generator knowledge may be enough for a sufficient characterization to satisfy all disposal requirements. This also applies to a mix of a "listed waste" and another type of waste (per 40 CFR 261.3 [a] [2]), and also to a waste that is derived from a "listed waste" (per 40 CFR 261.3 [c] [2]). An example of a derived waste is the ash that remains from a listed hazardous waste that burned.

Each individual listed hazardous waste is assigned one or more waste type designations, based on the criteria of being ignitable (I), corrosive (C), reactive (R), toxicity characteristic (E), acutely hazardous (H), or toxic (T). Based on these characteristics, EPA specifies four hazardous waste lists, described below.

List Name

Designation

40 CFR Citation

Non-specific Source Wastes

F List

261.31

Specific Source Wastes

K List

261.32

Discarded Commercial Chemical Products - Acutely Hazardous

P List

261.33(e)

Discarded Commercial Products - Hazardous

U List

261.33(f)

In order to determine if a specific waste is included in one of these lists, the lists provided in 40 CFR Part 261 must be referenced. Acute hazardous waste includes not only the "P List" waste chemicals, but selected "F List" waste types marked in the regulation with an (H). (Note that rules for accumulating waste often have specific requirements to address acutely hazardous waste.) The waste analysis plan should include an updated description of each specific source of listed hazardous wastes generated at the installation.

3. Characterization by Sampling and Analysis of a Characteristic Hazardous Waste: If a waste is a solid waste (by RCRA definition), but does not meet the definition of any of the "listed hazardous wastes," it may still be considered a hazardous waste if the material exhibits any of the characteristics as defined in 40 CFR 261 Subpart C (Parts 261.20 through 24). Sampling and testing are required to determine the following hazardous characteristics:

  • Ignitability (RCRA code D001)
  • Corrosivity (RCRA code D002)
  • Reactivity (RCRA code D003)
  • Toxicity (RCRA codes D004 through D0043)

The suggested sampling procedures to create a representative sample of different specific waste forms (such as drummed liquid, saturated soil, etc.) are provided in an EPA guidance manual titled Test Methods for Evaluating Solid Wastes, EPA document SW846. The specific analytical laboratory testing methods for each hazardous characteristic are specified in 40 CFR 261 Subpart C by specific references to SW846.

To develop a waste analysis plan, a standard method of sampling and laboratory analysis for each waste should be selected based on the guidance provided in SW846 (or other applicable EPA guidance manuals) and the background knowledge of the generator. Every analysis does not have to be performed for every waste if the generator can provide documented support that certain compounds are unlikely to be present.

4. Determining the Frequency of Characterization: Per 40 CFR 264.13 (a)(3), "Waste analysis must be repeated as often as necessary to ensure that it is accurate and up to date." This means that an analysis of a waste is necessary whenever any of the following circumstances occur:

  • the generator is aware of a change in the process that produces the waste,
  • the generator is aware that a waste was tainted by inadvertent mixing with another waste,
  • the receiving TSD facility determined through analysis that the waste no longer matches the expected characteristics, or
  • there is a change to the hazardous waste regulations that apply to that waste.


Compliance Benefit:

A waste analysis plan serves to standardize and optimize the required testing of wastes so that all wastes at a site are properly characterized prior to disposal in a simple and efficient manner. Therefore, the plan helps facilities comply with the requirements under RCRA 40 CFR 262.11 which requires persons who generate solid waste to determine if their waste is hazardous. In addition, the plan helps to ensure that non-hazardous waste is classified as non-hazardous and not hazardous. This may allow facilities to reduce their generator status and lessen the amount of regulations (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) they are required to comply with under RCRA, 40 CFR 262.34.

The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.

Materials Compatibility:

N/A

Safety and Health:

N/A

Benefits:

The development and correct use of a waste analysis plan can:

  • Help to avoid the unnecessary expense of disposing of non-hazardous wastes using hazardous waste disposal methods or contractors.
  • Help to avoid regulatory violations that can result in large fines and negative public exposure for the mismanagement or improper disposal of hazardous waste.
  • Minimize the time and money required for sufficient characterization of wastes and selection of proper disposal methods.


Disadvantages:
  • Personnel must be specially trained to make decisions regarding waste characterization and disposal and to develop these decisions into a plan


Economic Analysis:

Savings incurred through the use of a waste analysis plan are dependent upon site specific details.

Approving Authority:

Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.

NSN/MSDS:
Product NSN Unit Size Cost MSDS*
None Identified     $  

*There are multiple MSDSs for most NSNs.
The MSDS (if shown above) is only meant to serve as an example.

Points of Contact: Civilian:
RCRA hotline
Phone: (800) 424-9346

Hazardous Technical Information Services (HTIS)
Phone: (800) 848-4847
DSN: 695-5168

Vendors: A guide for developing a formalized, installation-specific waste analysis plan is available through the National Technical Information Service (phone [703] 487-4660) or the U.S. Government Printing Office (phone [202] 512-1800). Request the EPA Guidance Manual: Waste Analysis At Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes, document number PB94-963903, April 1994.

The EPA guidance manual titled Test Methods for Evaluating Solid Wastes, EPA document SW846, is available through the U.S. Government Printing Office (phone (202) 512-1800).

Sources:

None listed

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