• The WAP should provide a description of all onsite facility processes and activities that are used to generate or manage hazardous wastes.

As a hands-on tool for ensuring compliance with applicable regulatory requirements and/or permit conditions, the waste analysis plan (WAP) should provide a description of all onsite facility processes and activities that are used to generate or manage hazardous wastes (or reference applicable sections of the permit or permit application). This information should include:

• Facility diagrams,
• Narrative process descriptions, and
• Other data relevant to the waste management processes subject to waste analysis.

Since many treatment, storage, and disposal facilities (TSDFs), especially offsite facilities, utilize the WAP as an operating manual, it is advisable to incorporate process descriptions directly into the document.

In addition to describing onsite processes and activities, offsite TSDFs should reference in their WAPs that a brief description of each generator’s processes contributing wastes to the facility will be obtained, updated, and kept on file as part of the operating record (which is reviewed by Environmental Protection Agency (EPA)/state inspectors). If a business owns or operates a TSDF, this data will enhance knowledge of offsite generation processes and, therefore, improve the ability to determine the accuracy of generator waste classification.

Clearly identify the following in a WAP:

• Each hazardous waste generated or managed at the facility,
• Each process generating these wastes,
• Rationale for identifying each waste as hazardous, and
• Appropriate EPA waste classifications (e.g., EPA waste code, classification under Land Disposal Restriction (LDR) regulations as wastewater or non-wastewater).

In addition to identifying all listed wastes generated or managed, a facility may need to conduct testing and/or analysis to determine whether the facility also generates or manages any Resource Conservation and Recovery Act (RCRA) characteristic wastes. If wastes are identified as characteristic, the facility may choose to present relevant information such as the identity of hazardous waste, process generating the waste, rationale for hazardous waste designation, EPA waste code, and land disposal restriction.