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Waste analysis plans (WAPs)
  • The facility description is an important element of an effective waste management program (including a WAP).
  • Include procedures for receiving wastes generated offsite.

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, whether a generator or TSDF, many advantages, including:

  • Allowing for planning and analyzing several waste analysis options before making a selection;
  • Establishing a reliable and consistent internal management mechanism for properly identifying wastes onsite;
  • Ensuring that all participants in waste analysis have identical information (e.g., a hands-on operating manual), thereby promoting consistency and decreasing the likelihood that errors will be made;
  • Ensuring that facility personnel changes or absences do not lead to lost information; and
  • Reducing liabilities by decreasing the instances of improper handling or management of wastes.

Developing the plan

The facility description is an important element of an effective waste management program (including a WAP). The facility description should provide sufficient, yet succinct, information so that implementing officials and WAP users can clearly understand the type of:

  • Processes and activities that generate or are used to manage the wastes,
  • Hazardous wastes generated or managed, and
  • Hazardous waste management units.

If the facility has an existing Resource Conservation and Recovery Act (RCRA) permit or is in the process of developing a permit application, the majority of facility description information will be available from other sections of the permit. However, it is useful to include a summary of this information in the WAP. At a minimum, the WAP should reference where in the permit (or permit application) facility description information may be obtained.

Special procedural requirements

Also include procedures for receiving wastes generated offsite; procedures for ignitable, reactive, and incompatible wastes; and provisions for complying with LDR requirements, if applicable.