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Waste Analysis Plan (WAP) Checklist

A Waste Analysis Plan (WAP) is required for all treatment, storage, and disposal facilities (TSDFs), as well as generators treating hazardous waste in tanks, containers, or containment buildings to meet Land Disposal Restriction (LDR) standards. Formal documentation of waste analysis procedures in a WAP offers every facility that handles hazardous waste, whether a generator or TSDF, many compliance advantages.

This checklist will help you ensure that you are addressing all the key elements necessary for an effective WAP.

YesNoComments
1. Facility Description
Are all processes that generate hazardous waste identified?
Is sufficient information provided for each process to confirm that all hazardous wastes are identified?
Have all hazardous waste management units been identified?
Are descriptions of all hazardous management units provided?
Have all hazardous and solids wastes been identified for each unit?
Have the methods of waste management (e.g., stabilization) been described for each unit?
Are process design limitations defined for each hazardous waste management unit?
Have operational acceptance limits been established for each hazardous waste management unit?
Are procedures in place to determine whether wastes are outside of their respective acceptance ranges?
Do operational acceptance limits include applicable regulatory restrictions?
2. Systematic Parameters
Does the WAP incorporate a process for systematic planning, such as the Data Quality Objectives (DQO) process?
Do personnel training records (located in the permit application) demonstrate that facility personnel supervising and conducting waste sampling and analysis have received appropriate training in systematic planning?
3. Selecting Waste Parameters
Are parameters for waste analysis identified (and, if applicable, included in the WAP)?
Does WAP identify a rationale for the selection of each waste analysis parameter?
Does the WAP include parameters for the special waste analysis requirements 40 CFR 264/265.314, 264/265.341, 264-264.1034(d), and 266.102(b), if applicable?
Have operational acceptance limits been defined as they relate to waste properties and process?
Do operational acceptance limits include regulatory restrictions?
Do waste analysis parameters address applicable operational acceptance limits?
4. Selecting Sampling Procedures
Has the number of sampling locations been identified?
Are sampling procedures for each waste type identified?
Are descriptions and justifications provided for any modified or non-standard procedures approved by the EPA?
Have decontamination procedures for sampling equipment been developed?
Have sampling strategy techniques (e.g., grab, composite) been specified?
Are procedures for sampling multi-phase wastes addressed, if applicable?
Has all sampling equipment been identified?
Have the number and types of sampling containers been specified?
Have sample preservation techniques been specified?
Have sampling quality assurance and quality control procedures been documented?
Are proper packing and shipping procedures documented?
Have procedures for the maintenance of all sampling equipment been documented?
Have the precision and accuracy of all sampling equipment been documented?
Are health and safety procedures for the protection of sampling personnel specified?
5. Selecting a Laboratory and Laboratory Analytical Methods
Are laboratory analytical methods specified for each waste managed at the facility? If not, is other information (i.e., acceptable knowledge) used to demonstrate waste analysis?
Has a rationale been specified for each analytical method?
Do the selected analytical methods meet all regulatory requirements for the identification of each hazardous waste (e.g., each hazardous waste characteristic)?
Are descriptions and justifications provided for any modified or non-standard methods, as approved by the EPA?
Have chain-of-custody procedures for samples been specified, if necessary?
Does the laboratory have an adequate QA/QC program?
Have QA/QC procedures for each analytical procedure been identified?
6. Quantifying Data Uncertainty
Does the WAP incorporate a process for quantifying data uncertainty so that the laboratory results are capable of supporting the facilities’ waste management decisions (i.e., is there an appropriate level of certainty in the results)?
7. Selecting Waste Re-Evaluation Frequencies
Have site-specific criteria for waste re-evaluations been specified?
Is re-evaluation accomplished with adequate frequency?
Are mechanisms in place for re-evaluations of the sampling program each time the waste generating processes change?
Do the re-evaluation procedures specify criteria for the acceptance of wastes received from off-site generators?
Do you notify off-site facilities of changes in waste characterizations due to process changes and other factors?
8. Special Procedural Requirements, Where Applicable
Are procedures in place to verify the sources of the information provided from off-site generators or TSDFs?
Have criteria been established for the pre-acceptance procedures of wastes based on information from off-site generators of TSDFs?
Are procedures for waste inspections in place?
Have fingerprint analysis parameters been developed?
Have criteria been established for the acceptance of wastes based on the results of fingerprint analysis?
Is there methodology for identifying ignitable, incompatible, or reactive wastes?
Are procedures in place to conduct testing to determine whether wastes are incompatible with each hazardous waste management unit on site?
Have all wastes restricted under the LDRs been identified?
Are procedures in place to ensure that wastes meet applicable LDR treatment standards prior to land disposal?
9. Discrepancy Policy
Are procedures in place to resolve discrepancies between an incoming shipment and its manifest?
Are the procedures in compliance with applicable manifest discrepancy regulations. (Part 264/265, Subpart E)?
Are procedures in place to resolve discrepancies between an incoming shipment and its waste profile?
Do these procedures include a process for re-characterizing the waste and revising or preparing a new profile when needed?
10. Rejection Policy
Are procedures in place to reject a waste in accordance with applicable RCRA regulations (Part 264/264, Subpart E)?
Are these procedures coordinated with the discrepancy policy as necessary?
11. Recordkeeping
Does the WAP clearly identify all the types of records that will be kept?
Does the WAP indicate the length of time that records will be kept and are the timeframes in compliance with applicable regulations?
Will the facility produce summary-level reports based on its records to describe its compliance with applicable WAP requirements (e.g., on LDR compliance testing)?
Will the facility’s recordkeeping systems produce records to on-site inspectors in a timely and organized fashion?
12. Corrective and Preventative Action
Is a corrective and preventative action program in place to identify and eliminate the cause(s) of nonconformities and undesirable situations due to deficiencies in current laboratory practice?
Does the WAP describe how deficiencies will be reported and remedies determined?
Does the WAP spell out the timeframes for reporting and resolving problems?
Are responsible personnel identified? (e.g., by position)?