Hazardous waste management units

- The facility description portion of the WAP should include a description of each hazardous waste management unit at the facility.
- In the WAP, the description of the hazardous waste management units at the facility should be provided in narrative and schematic form.
The facility description portion of the waste analysis plan (WAP) should include a description of each hazardous waste management unit at the facility. As a supplement to generic facility process and activity discussions, these descriptions should provide more detailed information regarding the specific operating conditions and process constraints for each hazardous waste management unit.
A hazardous waste management unit is defined in the Resource Conservation and Recovery Act (RCRA) regulations as a contiguous area of land on or in which there is significant likelihood of mixing hazardous waste constituents in the same area. Examples given in the regulations include:
- Container storage areas [Note: A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed.]
- Tanks and associated piping and underlaying containment systems
- Surface impoundments
- Landfills
- Waste piles
- Containment buildings
- Land treatment units
- Incinerators
- Boilers and industrial furnaces
- Miscellaneous units
In the WAP, the description of the hazardous waste management units at the facility should be provided in narrative and schematic form. The narrative description should include the following:
- A physical description of each management unit, including dimensions, construction materials, and components;
- A description of each waste type managed in each unit;
- The methods for how each hazardous waste will be handled or managed in the unit; Process/design considerations necessary to ensure that waste management units are operating in a safe manner and are meeting applicable permit-established performance standards; and
- Prohibitions that apply to the facility (e.g., polychlorinated biphenyls (PCBs) in the incinerator feed, storage of corrosive basic waste, unpermitted RCRA hazardous waste codes).