Selecting waste analysis parameters

• Waste analysis parameters must be selected to represent those characteristics necessary for safe and effective waste management.
• Along with identifying waste analysis parameters, the RCRA regulations require that the WAP provide the rationale for the selection of each parameter.
• Sampling, analytical, and procedural methods that will be used to meet additional waste analysis requirements for specific waste management units must be included, where applicable, in the WAP.

An accurate representation of a waste’s physical and chemical properties is critical in determining viable waste management options. Accordingly, facility waste analysis plans (WAPs) must specify waste parameters that provide sufficient information to ensure:

• Compliance with applicable regulatory requirements (e.g., land disposal restriction regulations, newly identified or listed hazardous wastes);
• Conformance with permit conditions (i.e., ensure that wastes accepted for management fall within the scope of the facility permit, and process performance standards can be met); and
• Safe and effective waste management operations (i.e., ensure that no wastes are accepted that are incompatible or inappropriate given the type of management practices used by the facility).

Criteria for parameter selection

Waste analysis parameters must be selected to represent those characteristics necessary for safe and effective waste management. Due to the diversity of hazardous waste operations and the myriad of operating variables, the identification of the most suitable parameters to be sampled and analyzed can be complex. To this point, relevant waste analysis parameter selection criteria can be developed and reviewed systematically to efficiently identify parameters of interest. Generally, these selection criteria may be organized into the following categories:

• Waste identification;
• Identification of incompatible/inappropriate wastes; and
• Process and design considerations.

Parameter selection process

Waste identification — Identify and classify hazardous wastes generated or managed according to Environmental Protection Agency (EPA) waste codes. Determine any additional responsibilities for waste analysis under Land Disposal Restrictions (LDRs) (i.e., verify whether wastes are restricted).

Identify incompatible/inappropriate wastes — Identify appropriate waste analysis parameters to measure ignitability, reactivity, and incompatibility, as well as to identify inappropriate wastes based on facility operations and the profile of waste being managed.

Then, identify the universe of parameters that may be required to evaluate the range of process and design limitations — Determine the specific parameters necessary to identify waste acceptability with respect to process and design limitations, preferably for each management unit. For pre-process, in-process, and post-process operating variables, select parameters which indicate changes in waste composition that may affect waste management (e.g., pH, specific gravity).

Next, evaluate — Eliminate parameters which are duplicate parameters selected during previous parameter selection process elements or cannot be measured due to technological or other limitations.

Rationale for parameter selection

Along with identifying waste analysis parameters, the Resource Conservation and Recovery Act (RCRA) regulations require that the WAP provide the rationale for the selection of each parameter. The rationale must describe the basis for the selection of the waste analysis parameter and how it will measure necessary physical and chemical waste properties to afford effective waste management within regulatory, permit, process, and design conditions. This information will provide EPA permit reviewers and WAP users with critical information regarding the viability of parameter selection.

Special parameter selection requirements

WAPs must also include procedures and parameters for complying with the specialized waste management regulatory requirements established for particular hazardous waste management units. These regulatory requirements include special waste analyses for the following:

• Facilities managing ignitable, reactive, or incompatible wastes;
• Landfills;
• Incinerator;
• Treatment, storage, and disposal facility (TSDF) process vents and equipment; and
• Boilers and industrial furnaces.

Sampling, analytical, and procedural methods that will be used to meet additional waste analysis requirements for specific waste management units must be included, where applicable, in the WAP.