Do all treatment, storage, and disposal facilities (TSDFs) have to develop waste analysis plans (WAPs)?

Any facility that treats, stores, or disposes of hazardous waste must first obtain an operating permit under the Resource Conservation and Recovery Act, and one of the requirements of the permit is to develop a WAP.

Each TSDF must verify the characteristics and hazardous constituents of incoming waste to treat, store, or dispose of it properly. A facility’s WAP details the methods, procedures, and equipment used to comply with the waste analysis requirement. It must be written and kept on-site.

The WAP, at a minimum, must include:

• The parameters for analyzing,
• Testing and analytical methods,
• Sampling methods used to obtain representative samples for analysis,
• The frequency of reevaluation of the initial analysis,
• Waste analyses for off-site TSDFs that generators agreed to supply,
• Procedures to ensure there are no discrepancies between the hazardous waste received at an off-site TSDF and the identity of the waste designated on the manifest, and
• Methods used to meet additional requirements for specific waste management methods if applicable.