“THIS POLICY DOES NOT HAVE THE FORCE OF LAW”
W
aste
A
nal
y
sis
P
lan Guidance
A guide for preparing and reviewing waste analysis plans submitted with Part B of the
Ohio Hazardous Waste Facility Installation and Operation permit application
Ohio Environmental Protection Agency
Division of Hazardous Waste Management
Engineering and Risk Assessment Section
Street Address: Lazarus Government Center
122 S. Front Street, Columbus, Ohio 43215-1099
Mailing Address: P.O. Box 1049, Columbus, Ohio 43216-1049
FINAL
June 2000
Table of ContentsTable of Contents
SectionSection
Section 1.0 Introduction ..............................................................Page 1
Section 2.0 Applicability ..............................................................Page 2
Section 3.0 Definitions and Acronyms ...................................................Page 3
Section 4.0 Waste Analysis Plan Requirements ............................................Page 5
4.1 Facility Description ........................................................Page 6
4.1.1 Description of Waste Generating Processes and Activities ......................Page 7
4.1.2 Identification and Classification of Hazardous Wastes Managed .................Page 8
4.1.3 Description of Hazardous Waste Management Units ..........................Page 9
4.2 Waste Analysis Parameters OAC Rule 3745-54-13(B)(1) ........................... Page 11
4.2.1 Selection of Waste Analysis Parameters ..................................Page 11
4.2.2 Additional Information Regarding Selection of Fingerprint Parameters ............Page 13
4.2.3 “Mandatory” and “Supplemental” Parameters ...............................Page 13
4.3 Sampling Procedures OAC Rule 3745-54-13(B)(3) ...............................Page 16
4.3.1 Sampling Strategies ................................................. Page 17
4.3.2 Sampling Equipment ................................................. Page 17
4.3.3 Maintaining and Decontaminating Sampling Equipment ....................... Page 18
4.3.4 Sample Preservation, Holding Times, and Containers ........................Page 18
4.3.5 Sampling Quality Assurance and Quality Control Procedures ..................Page 18
4.3.6 Health and Safety Protocols ........................................... Page 19
4.4 Testing and Analytical Methods OAC Rule 3745-54-13(B)(2) ........................Page 19
4.4.1 Laboratory .........................................................Page 19
4.4.2 Testing and Analytical Methods .........................................Page 20
4.4.3 Laboratory Quality Assurance and Quality Control Procedures .................Page 20
4.4.4 Use of Acceptable Generator Knowledge in TSDF Waste Analysis ............... Page 21
4.5 Waste Re-evaluation Frequencies OAC Rule 3745-54-13(B)(4) ......................Page 24
4.6 Special Procedural Requirements ............................................ Page 24
4.6.1 Procedures for Off-Site Facilities
OAC Rule 3745-54-13(C); OAC Rule 3745-54-13(B)(5) .......................Page 24
4.6.2 Procedures for Ignitable, Reactive, and Incompatible Wastes
OAC Rule 3745-54-17 ................................................ Page 26
4.6.3 Provisions for Complying with LDR waste analysis requirements
OAC Rule 3745-59-07 ................................................ Page 26
4.6.4 Special Requirements for Bulk and Containerized Liquids
OAC Rule 3745-54-13(C)(3); OAC Rule 3745-57-14 .........................Page 28
4.6.5 Waste Analysis for Incineration Facilities
OAC Rule 3745-57-41 ................................................ Page 28
4.6.6 Surface Impoundments
OAC Rule 3745-54-13 (B)(7) ...........................................Page 28
Section 5.0 List of References .......................................................... Page 29
Appendices
I. Waste Analysis Plan Checklist ...................................................Page 30
II. Sample containers, preservation, holding times ..................................... Page 61
III. Waste Analysis Regulations .................................................... Page 67
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Section 1.0 IntroductionSection 1.0 Introduction
Waste analysis involves identifying or verifying the chemical and physical properties
of waste, either by testing or, in certain situations, by applying knowledge of the waste.
Waste Analysis Plans (WAPs) are written plans which document the procedures used to
perform analysis of waste generated, treated, stored, or disposed at hazardous waste
management facilities. WAPs are submitted as a requirement of Part B of the Ohio
Hazardous Waste Facility Installation and Operation Permit application, and as such
become an enforceable part of the permit. A WAP is required of every permitted
Treatment, Storage, or Disposal Facility (TSDF) in the State of Ohio.
The primary purpose of this guidance is to assist State of Ohio hazardous waste
facility permit writers in the review of WAPs submitted with Part B of the permit
application. It may also be used by the regulated community in the preparation of WAPs.
This guidance has two parts: a narrative portion and a checklist. The narrative
portion of this guidance describes the level of detail expected and provides technical
support for key elements of WAPs. It provides the Ohio Administrative Code (OAC)
regulatory citation, and specific requirements permit writers should look for when reviewing
WAPs. The checklist should also be used in the actual review of WAPs. Using the
checklist, the permit reviewer will be able to determine if the plan is complete and
technically adequate. Included here as Appendix I, this checklist may also be found in the
review tool for Part B applications.
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Section 2.0 ApplicabilitySection 2.0 Applicability
This guidance is applicable to all facilities subject to the permitting requirements of
OAC Chapter 3745-50. The specific requirement for submittal of a waste analysis plan is
detailed in OAC Rule 3745-50-44 (A)(3), “Contents of the Part B Permit Application”.
Facilities accumulating hazardous waste under OAC Rule 3745-52-34 that also
treat hazardous wastes in tanks or containers to meet applicable treatment standards
under OAC Rule 3745-59-40 to OAC Rule 3745-59-44 are required to develop and
maintain a written WAP in accordance with OAC Rule 3745-59-07(A)(4). While not
specifically focused on this portion of the regulated community, certain parts of this
guidance may apply to facilities preparing these plans.
Additionally, non-permitted facilities that do not conduct treatment of hazardous
waste in tanks or containers may opt to use this guidance to develop a WAP. WAPs,
though not required of these facilities, offer many advantages, including promotion of
waste management consistency, demonstration of compliance, and reduction of potential
liabilities associated with mis-characterization of wastes.
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Section 3.0 Definitions and AcronymsSection 3.0 Definitions and Acronyms
1. Acronyms
SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846, EPA SW-846.3.3 (most recent revision)
DQO Data Quality Objective
IRI Ignitable, Reactive, or Incompatible
QA/QC Quality Assurance / Quality Control
OSHA Occupational Safety and Health Act / Administration
LDR Land Disposal Restriction
TSDF Treatment, Storage, or Disposal Facility
2. Fingerprint Analysis - abbreviated waste analysis conducted for waste parameters
which may verify that a waste received from an off-site source matches the expected
characteristics for that waste.
3. Off-site Facility - a facility that receives and manages hazardous waste from another
facility that is not geographically on site.
4. On-site Facility - a facility that manages only those hazardous wastes which are
generated on it’s geographically contiguous property.
5. Waste Analysis Plan - a written plan which documents the procedures used to
perform waste analysis requirements.
6. Waste Profile Sheet - a written form completed by the generator as a waste pre-
acceptance condition with the TSDF. The waste profile sheet contains detailed
information on the physical and chemical characteristics of the waste.
7. Boundary Conditions - the expected high and low values of a characteristic based on
historical average analysis.
8. Tolerance Limits - the high and low values of a characteristic between which a waste
management unit can manage waste and still meet permit, process, or regulatory
criteria.
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9. Representative Sample - a sample of a universe or whole (e.g. waste pile, lagoon,
ground water) which can be expected to exhibit the average properties of the
universe or whole.
10. Pre-acceptance - the information collection process where a complete physical and
chemical analysis (sufficient to treat, store, or dispose of the waste) of a
representative sample of waste is obtained before the waste is accepted for
management. The purpose is to determine if a waste can be accepted for
management by the facility within permit, process, or regulatory constraints.
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Section 4.0 Waste Analysis Plan RequirementsSection 4.0 Waste Analysis Plan Requirements
The following is a discussion of information to be included in waste analysis plans
submitted with the Part B permit application. It is important to note that WAPs are facility
specific, and as such, there is flexibility in the content and level of detail required.
The information presented in the guidance is meant to be sufficient for most of the
facilities in Ohio; however, there may be facilities where additional information
requirements are not addressed. Also, there may be situations where not all of the
guidance is applicable. All WAPs must be carefully prepared and reviewed to determine
facility-specific waste analysis requirements are met.
Purpose of the Plan
The purpose of a WAP is to describe how a TSDF will collect the information
necessary to manage waste. The WAP documents the procedures used to obtain
information on the chemical and physical properties needed to effectively treat, store, or
dispose of the waste in accordance with permit, process, or regulatory considerations. For
example, storage facilities must know waste properties to ensure proper storage container
selection. Treatment facilities will have information needs to ensure safe and effective
waste treatment. All forms of waste management at a TSDF require accurate waste
analysis.
Content and Organization of the Plan
Required content of the WAP can be found in OAC Rule 3745-54-13 “General Waste
Analysis”. Paragraph (A) requires that TSDFs obtain a detailed chemical and physical
analysis of a representative sample of a waste, before managing the waste, which
includes all the information necessary to comply with OAC Chapters 3745-54 to 57 and 59,
and with permit terms and conditions. Paragraph (B) of this rule requires a written plan that
“describes the procedures to be implemented in order to comply with paragraph (A) of this
rule”. Paragraph (B) also specifies certain other minimum requirements for the plan.
Ohio EPA believes that there are six major elements of an effective WAP. These six
elements are the facility description, waste analysis parameters, sampling procedures,
testing and analytical methods, re-evaluation frequencies, and special procedural
requirements. Each of these elements are described in detail throughout this guidance.
There is no required format for the WAP. An important consideration when
organizing the WAP is that information is presented in a logical fashion. While narrative
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is necessary to describe waste analysis procedures at the facility, the most effective
means of communicating this information to Ohio EPA is through the use of tables and flow
charts to summarize and highlight key information. Where it is believed that a table
and/or flowchart would aid in clarifying the information presented, that is noted in this text,
and an example is provided
For off-site facilities, waste analysis can generally be seen as a three phase process:
pre-acceptance, acceptance, and post-acceptance/management. Pre-acceptance is the
collection of waste information before it is accepted by the facility. Typically, this happens
prior to waste ever being shipped to the TSDF, and may include such activities as
completing the waste profile sheet, collection of a representative sample to generate
laboratory analytical data, and compiling documentation of generator knowledge, or some
combination thereof. The purpose of this phase is to determine if the waste is acceptable
by the facility based on comparison of the waste characteristics to permit, process, and
regulatory constraints. The acceptance phase of waste analysis includes making the
determination that wastes arriving at the facility are the same as those characterized
during pre-acceptance. Typically this is done through fingerprint sampling, as described
later in this document. The post-acceptance/management phase should include any
necessary waste analysis that occurs after wastes have been accepted into the facility.
This phase may include such items as testing treatment residues to determine if land
disposal restriction (LDR) treatment standards have been met. Off-site TSDFs may find
it helpful to organize the WAP into the phases of waste analysis as described above.
Each phase could be described in terms of the waste analysis parameters, sampling
procedures, testing and analytical methods, etc., as those elements are described in this
document. Such an organization may clearly describe the waste analysis occurring during
each phase at the facility.
.
4.1 Facility Description
The facility description portion of the WAP describes the wastes managed, the waste
generating processes, and the hazardous waste management units. This section of the
WAP should answer the questions: What are the wastes to be managed in each unit at the
facility? What are the characteristics of that waste? What are the characteristic of the unit
that control the ability to safely store or manage the waste? The information in this section
is used throughout the remainder of the WAP to select and evaluate waste analysis
parameters, sampling and analytical methods, and re-evaluation frequencies.
The requirements for a description of the facility, waste management units, and
wastes to be managed are not explicitly stated in the waste analysis regulations, however,
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this information is considered vital to ensuring the remainder of the WAP is technically
adequate. Where this information is provided for in another section of the Part B
application this information need not be duplicated in the WAP; however, it should be
referenced and relevant points summarized to justify waste analysis decisions. This
summarization may take the form of a list or a table, and should contain the information
upon which the remaining waste analysis decisions were made. Consider for example a
large facility with multiple waste streams and hazardous waste management units. The
facility description must be of sufficient detail and clarity to discern which waste streams
are managed in which units. Based on that information, the facility can select relevant
acceptance and rejection criteria for each parameter of each waste stream.
4.1.1 Description of Waste Generating Processes
and Activities
Knowledge of the waste generating process is essential to waste analysis. This
knowledge is used to help develop and evaluate the list of parameters specified in the
WAP. It may also help to determine waste re-evaluation frequencies. For on-site
generated waste the information is easy to collect and document. All on-site process and
activities which generate hazardous waste to be managed in permitted units should be
described in the WAP. Additional waste streams generated on-site but treated, stored, or
disposed off-site could optionally be included in the WAP.
For waste generated off-site, waste generating process information can be collected
as part of the pre-acceptance process. These off-site waste generating processes should
be briefly described, and procedures should be in place for the facility to obtain updated
waste generating process information for wastes to be managed on-site (collection and
documentation of this information is vital where TSDFs rely in part or in whole on generator
knowledge. Refer to section 4.4.4 for proper documentation where generator knowledge
is used and section 4.5 regarding waste analysis re-evaluation). Detailed descriptions of
each generators process should be included in the generator’s customer file at the facility.
These descriptions should include generating process information to the degree that it is
relevant to waste analysis. For example, use of degreasing solvents for parts washing
could be a generating process description. However, enough detail about the process
should be provided to evaluate the potential of additional constituents to be present in the
waste, for example metals. This information will of course affect the selection of
parameters.
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4.1.2 Identification and Classification of Hazardous
Wastes Managed
A detailed description of the wastes managed should be provided. For on-site
facilities, very specific descriptions of the waste managed can be provided because these
facilities will manage waste with little variation. For off-site facilities which accept waste
from numerous generators, where appropriate waste stream types can be described
instead of individual waste streams. The descriptions of waste stream types should
account for the variation in waste between generators. For example, an on-site storage
facility may generate paint waste containing only cadmium pigments, and may describe
that waste with the D006 waste code. An off-site facility may be permitted to accept paint
waste containing cadmium or chromium pigments from several generators, and may
describe that waste stream type as D006 and D007 even though an individual generator’s
waste would likely only carry one of the codes. Detailed descriptions of each waste stream
must be included in each generators customer file. This description of the wastes will give
valuable information on what parameters to select, sampling methods, and selection of
sampling equipment. The waste description should include, at a minimum, the following:
‘ identity of the waste this is the common name of the waste as it is called at the
facility. It may be a brief description (e.g., parts washer solvent) a waste profile
number (e.g., Q99-0612) or the chemical name or abbreviation (e.g., trichloroethylene
(TCE)). The name must be unique for each waste stream or waste stream type at the
facility.
‘ the waste generating process this would be the name of the process (as described
in the above section 4.1.1) generating the waste stream
‘ rationale for designating the waste hazardous is the waste listed or does it exhibit
a characteristic?
‘ chemical and physical characteristics this should include information necessary
to sample, treat, store, or dispose of the waste. It also should indicate the source of
the information (i.e. generator supplied knowledge or laboratory analysis)
‘ appropriate OEPA hazardous waste classifications such as OEPA hazardous
waste codes and LDR treatment standards
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4.1.3 Description of Hazardous Waste Management
Units
The description of the hazardous waste management units (HWMUs) aids in the selection
of parameters by identifying any possible waste-unit incompatibilities, and permit,
regulatory, or process constraints of the unit. An example is storage of strong corrosives
in steel tanks. The HWMU description would tell us that the tanks are constructed of steel
and therefore we would add corrosivity as a characteristic of concern in the WAP for
wastes managed in that HWMU. A brief description of all hazardous waste management
units at the facility should be provided to justify or identify unit limitations. This description
may be provided in other sections of the Part B application and referenced and
summarized in the WAP. The description should include the following information
regarding the units:
‘ a physical description of the units;
‘ a list of wastes managed in each unit;
‘ waste management methods in the units (such as mixing, etc.);
‘ permit, regulatory, or process constraints of the unit (permitted waste codes,etc.)
‘ and any additional limitations to be considered when conducting waste analysis.
An efficient way to communicate these limitations is through use of a table, such as the
example below:
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Hazardous Waste Management Unit
Characteristic
Tanks 01 - 09 Tanks 10 - 99 Container Storage Waste Pile
Corrosive pH > 3 No limitations Bay 1 only No corrosives
Flammable No limitations No limitations Bay 3 only No flammables
Reactive No Reactives No Reactives Bay 2 only No reactives
Toxic No limitations No limitations Bay 4 only No toxics
Waste Codes F002, F003 only D008, D010 only all listed on part A
application
D008 only
Capacity <10,000 gal at
any one time
<25,000 gal at
any one time
195 55-gal drums
at any one time
100 cu. yds.
Other S.G. < 1.3 S.G. <1.3 No limitations no liquids
For additional clarity, the entire facility description information contained in Section 4.1
may be summarized in a table, such as in the example below:
Waste
Identity
Waste
Code
HWMU
1
Generating
Process
2
Rationale Chemical /Physical
Characteristics
Drycleaning
solvent
(PERC)
Q99-022374
F002
F003
Tanks
01-09
off-site
drycleaning
equipment
clean-out
Toxic 1. Miscible with alcohol, oils
2. Liquid
3. Colorless
4. No flash point
Lead Water
Q99-070274
D008 Tanks
10-99
off-site lead
abatement
Toxic 1. Liquid
2. 1<s.g.<1.2
3. Colorless to turbid
4. No flash point
5. 6<pH<8
6. Typ. 100 - 200 ppm
1 HWMU limitations are provided in Table 4.1.3
2 Generating process descriptions are provided in Section 4.1.1
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4.2 Waste Analysis Parameters
OAC Rule 3745-54-13(B)(1)
The waste analysis parameters portion of the WAP specifies the parameters used to
represent physical and chemical characteristics of the waste to be managed. Facilities
must specify waste parameters which ensure compliance with regulatory requirements
(e.g. LDR), permit conditions (e.g. permitted waste codes), and safe and effective waste
management operations (e.g. incompatible wastes).
The parameters section must include information on the rationale (how the
parameters ensure compliance with OAC Rule 3745-54-13(A)(1)) for parameter selection,
and should include acceptance and rejection criteria for each parameter.
Parameters for all phases of waste management for each waste stream may be
discussed in this section. For example, treatment and disposal facilities which must test
waste for compliance with LDR regulations may specify those parameters in this section.
The permit reviewer must ensure that the applicant lists the rationale for each parameter
of each waste stream during all phases of management (pre-acceptance, acceptance, and
post-acceptance/management) if applicable.
4.2.1 Selection of Waste Analysis Parameters
Facilities should consider several data needs when selecting parameters to define
waste which is capable of being managed at the facility. Selection of these parameters is
facility specific. Facilities must propose which parameters they will use, and provide the
rationale for selection of those parameters in the WAP. The permit writer must review the
proposed parameters to determine their sufficiency in meeting the intent of OAC Rule
3745-54-13(A)(1). Generally, TSDFs will need information regarding the following :
‘‘ waste identification - all generators must evaluate (through testing or knowledge)
waste for parameters which establish the waste identification under OAC Chapter
3745-51. When a TSDF generates and manages waste on-site, parameters relating
to waste identification may be included in the WAP.
‘‘ identification of incompatible, reactive, or ignitable (IRI) waste - as discussed
in section 4.6.2, OAC Rules 3745-54-13 and 3745-54-17 require that IRI wastes are
identified and methods to make that determination must be presented in the WAP.
Facilities may include parameters to meet these requirements.
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‘‘ permit or regulatory considerations - permit or regulatory acceptance limits, such
as PCB content of incoming waste streams, may warrant additional parameters which
must be monitored. These parameters should be selected based on permit conditions
or regulatory restrictions.
‘‘ Land Disposal Restrictions (LDR) - under OAC Chapter 3745-59 generators and
TSDFs have various responsibilities for characterizing restricted waste. This
includes treatment facilities which must test treatment residues to demonstrate that
LDR standards have been achieved. A TSDF combining wastes in tank storage will
need to obtain information regarding concentrations of hazardous constituents to
avoiding dilution as a form of treatment, as specified in OAC Rule 3745-59-03. As
a result of compliance with LDR Rules, several parameters may be specified to meet
these requirements.
‘‘ Special Parameter Selection Requirements - these may include special waste
analysis required by regulations for specific hazardous waste management units,
including incinerators, landfills, surface impoundments, and miscellaneous units.
‘‘ Process considerations - the facility description should specify the range of waste
characteristics a process can accept and still operate safely, effectively, and in
accordance with applicable regulations. These limits are called Tolerance Limits, and
may or may not exist for various waste characteristics. These tolerance limits are
then used to select parameters which can monitor the characteristics with tolerance
limits. For example, a waste oil stream may have to be of such viscosity that it can be
pumped through process lines. A tolerance limit for that waste stream would then be
set at the required range of viscosities. Additionally, special considerations should
be given to pre-process, in-process, or post-process changes in the waste which may
require that additional parameters be specified at intermediate points of treatment
processes.
‘ Fingerprinting - fingerprint sampling is used to determine if a waste is inconsistent
with the data collected during pre-acceptance. Fingerprint parameters are selected
from the larger set of pre-acceptance parameters. Generally, the rationale presented
for selection of fingerprint parameters will be to determine if the waste arriving on-site
is the same as the waste agreed to during pre-acceptance. However, some facilities
may elect to perform additional analysis, such as PCB screening, on each shipment
although the waste characterization data (pre-acceptance data) indicates PCBs are
not present.
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At a minimum, facilities should consider these above criteria when selecting
parameters. Not all of the above criteria may apply to any individual facility; likewise, there
may be other facility specific considerations that are not addressed above. The
parameters which have been selected must be listed in the WAP for each waste stream
(or waste stream type), along with the rationale for each parameter. The rationale must
describe why the parameter was chosen and how it will ensure waste management is
within permit, process, and regulatory limits or otherwise meets the intent of OAC Rule
3745-54-13(A).
4.2.2 Additional Information Regarding Selection of
Fingerprint Parameters
Selection of fingerprint parameters should focus on a specific subset of the pre-
acceptance parameters. Boundary conditions, or expected range of a characteristic, for
fingerprint parameters should be established and included in the WAP. These are
established through knowledge of the average characteristics of the waste stream. When
boundary conditions are exceeded, that is an indication to the TSDF that the waste is
atypical, and a more detailed analysis or shipment rejection may be warranted.
Specific parameters chosen for fingerprinting are waste stream specific, and should
be based upon the fingerprint parameter selection criteria described in section 4.2.1. In
general, several parameters should be chosen, both quantitative and qualitative. Usually
they are taken from the larger set of pre-acceptance parameters, so that fingerprint results
can be compared to the expected characteristic ranges indicated in the pre-acceptance
characterization. The focus should be on fingerprint parameters which can give reliable
indications that an incoming shipment is or is not the waste expected.
The number of fingerprint parameters specified in the WAP can be considered a
function of the quality of the pre-acceptance data acquired. When the TSDF collects
analytical data or thoroughly documented generator knowledge for a waste stream, a less
rigorous fingerprinting program may be acceptable. The level of information obtained
within certain fingerprinting programs may resemble a complete laboratory analysis in
situations involving a generator with a history of mis-characterizing their waste.
4.2.3 “Mandatory” and “Supplemental” Parameters
In some instances, TSDFs have listed “mandatory” and “supplemental” parameters
for their waste streams in the WAP. This may be especially useful when the mandatory
analysis is used as a screen to determine the need for more accurate supplemental
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analysis. An example of this is the use of detector tubes to screen incoming waste
shipments for methylene chloride. If the detector-tubes indicates the presence of
methylene chloride above a pre-determined action level, then the supplemental analysis
is performed, consisting of a traditional analytical laboratory technique. The use of these
“mandatory” and “supplemental” analysis can save time and money when compared to
straight laboratory analysis.
Where a facility elects to specify “Mandatory” and “Supplemental” analyses, the
specific circumstances when each analysis will be performed must be included in the WAP
in an “If X then Y” format. Using the above detector tube example, the WAP could state
“Wastes containing methylene chloride greater than 50 ppm cannot be accepted at this
facility, therefore, all incoming waste streams will be screened using a detector tube
capable of detecting methylene chloride in concentrations from 5 to 100 ppm. If the
detector tube indicates a methylene chloride concentration above the action level of 25
ppm, then a full laboratory analysis of the sample using SW-846 method 624 will be
performed. If the detector -tube does not exceed the action level of 25 ppm, then no
further methylene chloride analysis is necessary”. Note how the rationale, action level, and
the next steps in the process are clearly stated. Also, note that the action level must be
below the tolerance limit for that characteristic / parameter, and be conservative enough
to account for sampling and instrument error. For additional clarity, it is suggested that
the decision logic be presented in a flow chart format, such as the example in Figure 4.1.
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Figure 4.1. Example Flowchart Showing Mandatory and Supplemental
Analysis.
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4.3 Sampling Procedures
OAC Rule 3745-54-13(B)(3)
When sampling and laboratory analysis is used to determine the physical and
chemical characteristics of a waste, the methods to obtain a representative sample must
be provided. A representative sample is defined as a sample of a universe or whole (e.g.
waste pile, lagoon, groundwater) which can be expected to exhibit the average properties
of the universe or whole. Two options available for collecting a representative sample
include use of the methods listed in the Appendix I to OAC Rule 3745-51-20, or use of an
equivalent method. Methods listed in the Appendix I to OAC Rule 3745-51-20 include:
Material Type Method
extremely viscous liquid ASTM D140-70 (revised to D140-88)
crushed or powdered material ASTM D346-75 (revised to D346-90)
soil or rock-like material ASTM D420-69 (revised to D420-93)
soil-like material ASTM D1452-65 (revised to D1452-80)
fly-ash like material ASTM D2234-76 (revised to D2234-89)
containerized liquid waste SW-846 “COLIWASA”
liquid waste in pits, ponds, lagoons, or
similar reservoirs
SW-846 “Pond Sampler”
The methods and equipment used for sampling waste materials will vary with the form and
consistency of the waste materials to be sampled. Samples collected using the sampling
protocols listed above, for sampling waste with properties similar to the indicated materials,
will be considered by Ohio EPA to be representative of the waste.
When using the above methods, modifications to the method may be required to meet
other sampling requirements. For example, changes to allow use of proper container type,
size, and preservative for the selected laboratory analysis may be required. These
changes must be reflected in the WAP, preferably by documentation in a standard
operating procedure (SOP). Also, additional standard methods may be available for use
from organizations such as ASTM. These methods may be appropriate and should be
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referenced in the plan when used.
Whether or not standard sampling methods are used, important aspects of the
sampling to be performed by the TSDF should be described in the WAP. The purpose of
including this information is to describe how representative samples are collected. This
description should include a discussion of sampling strategies, sampling equipment,
maintenance and decontamination of sampling equipment, sample preservation and
storage, quality assurance and quality control, and health and safety considerations. Off-
site TSDFs which accept sampling and laboratory analysis data from generators should
encourage generators to use sound sampling and analysis procedures. Specific technical
adequacy for each of these areas is currently beyond the scope of this document. For
additional information on sampling, ASTM offers several sampling related guides which
may be appropriate, SW-846 contains RCRA sampling guidance, or consult the DHWM
sampling manual.
When specifying sampling procedures for off-site facilities, the WAP must include
information for both pre-acceptance sampling and fingerprint sampling, when used. On-site
facilities must describe how they collect samples, when sampling is used.
4.3.1 Sampling Strategies
A description of the sampling approach, i.e. random or judgmental, and sample type,
i.e. grab or composite, should be provided in the plan. The sampling objective, sample
location, and number of samples should also be provided. For example, a decription of
fingerprint sampling may read:”For waste shipments which arrive in lots of X drums or less,
Y drums will be selected at random and grab samples will be collected for fingerprint
analysis”.
The evaluation of the appropriateness of various sampling strategies is beyond the
scope of this document. Further guidance may be found in the DHWM sampling manual
or various texts on sampling. Facilities may also consider using the Data Quality Objective
(DQO) process in design of a sampling strategy to comply with the requirements of this
rule.
4.3.2 Sampling Equipment
The WAP should clearly list all sampling equipment to be used for collection of each
sample. The equipment chosen should be appropriate based on physical and chemical
characteristics of the waste, the sampling method, and any additional waste-specific or
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site-specific factors. Descriptions of sampling equipment and their applicability are
provided in chapter nine of SW-846.
4.3.3 Maintaining and Decontaminating Sampling
Equipment
Maintenance and decontamination procedures for all sampling equipment should be
described. Decontamination must be such that sample cross-contamination from
equipment re-use is eliminated. Facilities should specify a standard method (e.g., ASTM)
and/or provide a standard operating procedure for decontamination of sampling equipment
between samples. Equipment maintenance should generally follow the equipment
manufacturer’s specifications. Additionally, field equipment calibration procedures should
be discussed, if applicable.
4.3.4 Sample Preservation, Holding Times, and
Containers
All sample preservation methods and holding times should be provided, as well as
type of sample containers used. Typically sample preservation and holding times will not
be necessary for samples which will be analyzed immediately, for example, fingerprint
samples. Preservation methods, holding times, and sample containers must be consistent
with the analytical method requirements. Table 7-1 from chapter seven of the DHWM
sampling manual has been included as Appendix II to this document for use in determining
proper containers, holding times, and preservation methods for samples to be analyzed
with SW-846 methods. Commercial laboratories may also provide information regarding
container selection, and sample preservation and holding times.
4.3.5 Sampling Quality Assurance and Quality Control
Procedures
Quality assurance and quality control procedures for each sample collected should
be specified. The WAP portion dealing with QA of sampling should include information on
chain of custody procedures, personnel training, and use of standardized sampling
procedures.
QC during the sampling process includes the collection of blank, duplicate, and split
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samples to measure the effectiveness of the QA program. The WAP should specify QC
sample number, location, objective, and frequency, when applicable. Typically, blank,
duplicate, or split samples will not be collected for fingerprint samples. They also may not
be necessary for all pre-acceptance samples. Procedures for documenting deviations
from the sampling QA/QC procedures should also be specified. More information about
sampling QA/QC can be found in chapter one of SW-846 or other sampling guidance.
4.3.6 Health and Safety Protocols
While not trying to integrate health and safety requirements into the WAP, it should
be recognized that these are important considerations when developing sampling
procedures. When the WAP is used as an operational manual at the facility, it makes
sense that sampling SOPs provided in the WAP include health and safety protocols. This
may include use of personal protective equipment, lock-out tag-out procedures, or
confined space entry procedures. These provisions will not be reviewed for compliance
with applicable laws or regulations by Ohio EPA, however, permit writers should not
require their removal if the facility chooses to incorporate health and safety protocols into
the sampling SOPs. The Occupational Safety and Health Administration (OSHA) regulates
worker health and safety and should be consulted for specific requirements.
4.4 Testing and Analytical Methods
OAC Rule 3745-54-13(B)(2)
4.4.1 Laboratory
The WAP should specify if the laboratory chosen to perform analytical services is on-
site or a commercial environmental testing laboratory. If the facility elects to utilize an off-
site commercial laboratory, laboratory selection should be based on the following:
‘ laboratory’s comprehensive QA/QC program, including chain-of-custody procedures
and treatment of blanks, spikes, and duplicate samples used to measure precision
and accuracy;
‘ the laboratory’s technical analytical expertise in achieving required detection limits
and using quality technicians and equipment;
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‘ and effective information management providing clear, concise, and accurate data
reports and QA/QC documentation for data validation.
When using an off-site laboratory, the WAP should state that the off-site laboratory will
utilize the analytical methods specified in the WAP and appropriate QA/QC procedures.
4.4.2 Testing and Analytical Methods
Testing and analytical methods for each parameter must be specified. Analytical
methods should be chosen by considering the physical state of the waste, analyses of
interest, and required detection limits. Sample preparation and clean-up methods should
also be specified, if required.
Generally, all testing and analytical methods should be standard methods, such as
ASTM or U.S. EPA SW-846 methods. When this is the case, it is sufficient to only
reference the method by name, number, and source. However, any changes to the
standard methods, or other methods used (e.g., facility specific methods), must be
accompanied with a standard operating procedure for the method in the waste analysis
plan or the laboratory quality document. Deviations from the methods presented in the
WAP should be documented in the operating record. Table 7-1 included in Appendix II
to this document contains analytical method numbers of some common SW-846 analytical
methods.
4.4.3 Laboratory Quality Assurance and Quality Control
Procedures
OAC Rule 3745-50-58(E)
To ensure that waste analysis decisions are based on data of known quality, and to
document that appropriate laboratory quality assurance/quality control (QA/QC)
procedures are used, each WAP must include or incorporate by reference a laboratory
quality assurance plan which contains the elements of appropriate laboratory QA/QC
procedures. Where QA/QC for sampling operations are provided elsewhere (e.g., in the
sampling procedures section of the WAP) only the elements relating to laboratory QA/QC
need to be presented here. Additionally, analytical method-specific QA/QC should be
discussed, either in the laboratory quality assurance plan or included in standard operating
procedures (SOPs) for each method. General elements relating to appropriate laboratory
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operations include at least the following:
‘‘ facilities - a general description of the laboratory facility should be provided, and
should address any items which may affect analytical data quality
‘‘ equipment and instrumentation - a list of available equipment and the method
capabilities for the equipment
‘‘ operating procedures - all activities in the laboratory should be described,
preferably in the form of SOPs. SOPs to be documented might include sample
management, preparation of reagents or standards, general lab techniques, test
methods, equipment and calibration, QC samples, corrective action, data validation,
reporting, records management, and laboratory waste disposal.
‘‘ laboratory QA/QC procedures a description of how laboratory QA/QC procedures
are implemented should be provided, including method proficiency, control limits, lab
control procedures, deviations, corrective action, and data handling.
‘‘ quality assurance review - provide a description of internal and external review of
laboratory QA/QC procedures. This includes a complete description of responsibility
for data quality assurance review conducted by the laboratory.
‘ laboratory records- a description of the management system in place for the storage
and handling of sampling and analysis records should be provided. This should
include custody procedures for shipping samples to an off-site laboratory. Also, in
accordance with OAC Rule 3745-50-58(J)(2), a statement should be included which
provides for a minimum three year retention of these records in the operating record.
Addressing only the six elements listed above may not be sufficient detail to meet the
requirements for use of appropriate laboratory QA/QC. TSDFs are strongly urged to
consult appropriate guidance when preparing a quality assurance plan to determine the
complete scope required for their facility. Such guidance may include chapter one of SW-
846, or Chapter five “Quality Systems” of the National Environmental Laboratory
Accreditation Conference guidance document.
4.4.4 Use of Acceptable Generator Knowledge in TSDF
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Waste Analysis
TSDFs must obtain a detailed chemical and physical analysis of a representative
sample of a waste. The analysis must contain all the information necessary for the TSDF
to treat, store, or dispose of the waste in accordance with the hazardous waste rules, OAC
chapters 3745-54 to 57 and 3745-59, and the conditions of the facility permit. Such an
analysis can consist of representative waste sampling and laboratory analysis, and/or
detailed waste specific information provided to the TSDF by the waste generator. This
latter waste analysis method is commonly known as “acceptable generator knowledge”.
DHWM prefers that a TSDF use representative sampling and laboratory analysis to
meet waste analysis requirements. This is because analytical data provides the most
definitive information regarding the concentration levels of hazardous constituents in a
waste and other characteristics of a waste when waste sampling and laboratory analysis
are done appropriately.
However, a TSDF’s waste analysis to comply with OAC Rule 3745-54-13 can be
based, in whole or in part, on detailed waste specific information the TSDF obtains from
the generator of the waste. If a TSDF uses acceptable generator knowledge to accomplish
any part of its requirement to perform waste analysis, the TSDF needs to list, in its WAP,
all the types and sources of information and documentation it may obtain from a generator
for evaluation.
A TSDF’s waste analysis can consist of a combined use of acceptable generator
knowledge and waste sampling/laboratory analysis by the facility. The TSDF can use the
information obtained from the generator to determine what hazardous constituents and
characteristics could not be present or exhibited by the waste, and then sample and
analyze the waste for the hazardous constituents and/or characteristic(s) that could be
present.
In addition, the information and documentation comprising the acceptable generator
knowledge needs to be accurate and complete in order to correctly identify the waste. The
TSDF must objectively review the information provided by the generator. Therefore, it is
recommended that the TSDF explain in its WAP how it will ensure the generator’s
information is valid.
Types and Sources of Information
The types and sources of information listed below can be obtained from a generator
and used by a TSDF to substantiate and document a waste analysis that is based in part
or in whole on acceptable generator knowledge. Generally, a combination of the following
types of information to make a waste analysis should be used. The information that can
be used for waste analysis is not limited to this list; but these are the more common forms
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Final June 2000
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of information that should be collected from generators.
‘ Laboratory analysis data of a representative sample of the waste;
‘ Description of the process that generated the waste;
‘ Applicable waste identification codes and waste codes for the purposes of complying
with LDR requirements;
‘ Applicable LDR treatment standards;
‘ Facility specific process flow diagram of the process generating the waste;
‘ Chemical makeup of all ingredients or materials used in the process that generates
the waste;
‘ List of constituents which the generator knows or has reason to believe are
byproducts or side reactions to the process that produces the waste;
‘ MSDS sheet and/or product label of substances used in a process that generates the
waste;
‘ Data obtained from properly performed representative sampling and laboratory
analysis of wastes generated from same process using same ingredients/materials;
‘ Data obtained from literature regarding waste produced from same process using
same ingredients or materials; and
‘ Documentation of product specifications of input materials and output products.
OAC Rules 3745-52-40 and 3745-59-07 require generators to retain records and
documentation of waste analyses for a period of three years from the last date that the
waste was sent to an on-site or off-site treatment, storage, or disposal facility.
Furthermore, the generator is required to submit waste analysis data, where available, to
the TSDF. This submittal is in addition to completing a TSDF’s waste profile sheet.
DHWM takes the position that a profile sheet is only summary of a waste analysis. In
order to complete a profile sheet, specific information regarding the waste must be
developed. It is this information that is the waste analysis data. Therefore, a TSDF should
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Final June 2000
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require generators’ records of waste analyses (when available) as a condition of pre-
acceptance. The evaluations should be kept in the facility’s file for each generator and
updated in accordance with the frequency specified in the waste analysis plan.
4.5 Waste Re-evaluation Frequencies
OAC Rule 3745-54-13(B)(4)
The frequency with which the initial waste analysis will be reviewed or repeated to
ensure accuracy must be specified in the WAP for each waste stream. At a minimum, the
waste analysis must be reviewed or repeated when the generating process changes, or
when the waste arriving at the TSDF does not match the pre-approved waste
characterization information supplied by the generator.
For off site facilities which accept generator knowledge as waste analysis, the waste
analysis plan must specify the mechanism to ensure that updated information (process
information, etc.) is received from the generator each time the waste must be re-evaluated.
This includes regular re-evaluations to ensure that the waste analysis is accurate and up
to date.
When initial shipments of a waste stream include laboratory analysis, each
subsequent re-evaluation does not necessarily require a new laboratory analysis. The
generator and/or TSDF must re-evaluate the waste stream as necessary, which may only
include a review of the generating process for changes. Significant changes that may
impact waste stream characteristics could be further evaluated through sampling and
laboratory analysis.
4.6 Special Procedural Requirements
Facilities may have special procedural requirements which must be discussed in the
WAP. These may include procedures for wastes generated off-site, waste incineration
facilities, ignitable, reactive, and incompatible wastes, and provisions for complying with
LDR requirements.
4.6.1 Procedures for Off-Site Facilities
OAC Rule 3745-54-13(C); OAC Rule 3745-54-
13(B)(5)
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Off-site facilities have additional waste analysis requirements which must be
addressed in the WAP. The WAP must specify what waste analysis information the
generator has agreed to supply, and also must specify the procedures used to confirm the
identity of waste arriving on-site.
When collecting waste analysis information from generators, TSDFs should
remember that the information collected must include a detailed chemical and physical
analysis of a representative sample of the waste, including all the information required to
treat, store, or dispose of the waste in accordance with OAC Chapters 3745-54 to 57 and
3745-59. TSDFs should require generators to submit, at a minimum, the following
information: description of the waste generating process, a chemical and physical
description of the waste, laboratory analytical procedures and results (or acceptable
generator knowledge) used to characterize the waste, OEPA hazardous waste codes, and
all LDR information required under OAC Chapter 3745-59. When a generator uses
sampling and laboratory analysis to meet the requirements of OAC Chapter 3745-59, the
generator is required to submit the results of the analysis to the TSDF, in accordance with
OAC Rule 3745-59-07(A)(1)(d) . When a generator bases the analysis on knowledge of
the waste, all supporting information must be retained in the generator’s file, in accordance
with OAC Rule 3745-59-07(A)(5). The TSDF WAP should specify that when a generator
performs laboratory analysis or uses knowledge of the waste to comply with OAC Chapter
3745-59, that analysis or documentation of generator knowledge will be supplied to the
TSDF as part of pre-acceptance.
Typically, waste analysis information is provided to the TSDF by use of a waste
profile sheet. A waste profile sheet is a written form summarizing detailed information on
the physical and chemical characteristics of the waste. It is commonly completed by the
generator as a waste pre-acceptance condition with the TSDF. It should be noted that a
waste profile sheet is not a substitute for waste analysis. The waste profile sheet simply
summarizes relevant information for ease of use. The underlying information, for example
laboratory analysis results or documentation supporting generator knowledge, that was
used to complete the form is the actual waste analysis. When waste profile sheets are
used to collect information from generators, the TSDF may either provide a blank waste
profile sheet in the WAP showing all the information collected, or may list in the WAP all
the information collected. When a blank waste profile sheet is included in the WAP, all
changes (format and content) will be considered permit modifications. When the
information is listed in the WAP, only changes to the content will be permit modifications.
Completed waste profile sheets for each waste managed from each generator must be
kept in the facilities operating record or generator file.
The WAP must specify the procedures used to inspect, and if necessary, analyze
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Final June 2000
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each movement of hazardous waste received at the facility to ensure that it matches the
identity of the waste designated on the manifest and agreed to during pre-acceptance.
Typically, this is done by fingerprinting as discussed in section 4.2. Fingerprint sampling,
or another identification procedure, must be described in the waste analysis plan.
4.6.2 Procedures for Ignitable, Reactive, and
Incompatible Wastes
OAC Rule 3745-54-17
When using waste analysis to document compliance with the general requirements
for ignitable, reactive, or incompatible (IRI) wastes, that waste analysis information must
appear in the WAP. If a waste will be mixed with any other waste or material, a TSDF has
the responsibility to obtain enough information to evaluate all such wastes and/or mixtures
for potential incompatibilities. There are several sources of information for identifying IRI
wastes. Ignitable wastes must be identified by one of the methods listed in OAC Rule
3745-51-21. Reactivity and compatibility have no specified testing methods, however
there is guidance available. Design and Development of a Hazardous Waste Reactivity
Protocol may be used to aid in identifying reactive wastes. Guidance for determining
hazardous waste compatibilities may be found in A Method of Determining the
Compatibility of Hazardous Waste or Standard Test Methods for Compatibility of Screening
Analysis of Waste. TSDFs should either reference standard test methods or supply
standard operating procedures for test methods specified in the WAP.
4.6.3 Provisions for Complying with LDR waste
analysis requirements
OAC Rule 3745-59-07
Both Generators and TSD facilities are subject to additional waste analysis
requirements to satisfy land disposal restriction rules. The WAP for any facility must
include all the information required to meet land disposal restriction requirements. The
specific information required will vary dependant upon the type of facility (i.e., on-site
storage facility or land disposal facility). The discussion below is intended to briefly touch
on some basic requirements of waste analysis as it pertains to the LDRs. Please note that
subsequent to the last Ohio EPA LDR rule revisions (1992) the U.S. EPA has revised and
promulgated additional LDR requirements. Facilities are required to follow these
new/revised requirements where they are more stringent than the current state rules.
Clarification on the applicability of specific portions of the LDR rules should be directed to
Waste Analysis Plan Guidance
Final June 2000
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the Ohio EPA DHWM Technical Support Unit, Central Office.
Generators of listed hazardous wastes must test their waste, or waste extract using
the TCLP, or use knowledge of the waste to determine if the waste is restricted from land
disposal. Generators of characteristic hazardous wastes must test their wastes using EP
toxicity test, or use knowledge of the waste to determine if the waste is restricted from land
disposal. If the generator determines that the waste is restricted from land disposal (a
“restricted” waste) and does not meet applicable treatment standards under OAC Rule
3745-59-40 to 44 or prohibition levels under OAC Rule 3745-59-32, then they must fulfill
certain notification requirements to the TSDF with each shipment of the waste (see OAC
Rule 3745-59-07(A)(1)). This notification must include the treatment standard or
prohibition level, or the specified treatment technology if listed in Table 1 of OAC Rule
3745-59-42, and waste analysis data, if available. If the generator determines that the
waste is restricted but does meet the treatment standard or prohibition level, then they
must fulfill certain notification and certification requirements with each shipment of the
waste (see OAC Rule 3745-59-07(A)(2)). This notification must also include the specified
treatment standard, prohibition level, or specified treatment technology and any available
waste analysis data. All notifications, certifications, waste analysis data, and information
supporting knowledge of any waste treated, stored or disposed of on-site or off-site must
be maintained in the facility file for at least five years.
There are a few additional waste analysis requirements for generators of liquid
wastes Generators must test or use knowledge of the waste to determine if the pH is less
than or equal to 2. If the pH is less than or equal to 2, it is restricted from land disposal.
If a generators liquid waste contains polychlorinated biphynels (PCBs) or is primarily water
containing hazardous organic constituents (HOCs) listed in the Appendix to OAC Rule
3745-59-32, the generator must test the waste or use knowledge of the waste to determine
if it equals or exceeds prohibition levels.
Treatment facilities must test their treatment residues in accordance with the
frequency specified in the WAP. Pursuant to OAC Rule 3745-59-07(B), for wastes with
treatment standards expressed as concentrations in the waste extract, the facility must test
the treatment residue with the TCLP to determine if the treatment residue or extract meet
treatment standards. For wastes with treatment standards expressed as concentrations
in the waste, the facility must test treatment residues to ensure treatment standards are
meet. For wastes prohibited under OAC Rule 3745-59-32 but without treatment standards
under OAC Rule 3745-59-40 to 44, the facility must test the treatment residue in
accordance with the generator testing requirements in OAC Rule 3745-59-32 to determine
if the treatment residues meet treatment standards of OAC Rule 3745-59-32. If the waste
is to be further managed at another treatment or storage facility, the original treatment
facility must fulfill the notification and certification requirements of the generator. If the
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waste is sent to a land disposal facility, the treatment facility must fulfill certain notification
requirements, including applicable treatment standards and waste analysis data, if
available (see OAC Rule 3745-59-07(B)(4)). The treatment facility must also certify that
the waste has been treated in accordance with the treatment standards of OAC Rule 3745-
59-40 to 44 and the applicable prohibitions in OAC Rule 3745-59-32.
Land disposal facilities disposing of restricted waste must retain copies of the
notifications and certifications required under paragraphs A and B of OAC Rule 3745-59-
07. Land disposal facilities must also test the waste, or the treatment residue, or an extract
of the waste or treatment residue using the TCLP, or any methods in OAC Rule 3745-59-
32, to ensure that it meets applicable treatment standards in OAC Rule 3745-59-40 to 44
or prohibition levels in OAC Rule 3745-59-32. Testing must be done in accordance with
the frequency specified in the WAP.
4.6.4 Special Requirements for Bulk and
Containerized Liquids
OAC Rule 3745-54-13(C)(3); OAC Rule 3745-57-
14
Off-site landfills must specify in the WAP the procedures in place to determine if a
generator has added a biodegradable sorbent to waste liquids in containers. The methods
to determine if a sorbent is biodegradable must also be specified, if testing is used. The
WAP must also describe how the facility will determine, by use of SW-846 method 9095
“Paint Filter Liquids Test”, if free liquids are being placed in the landfill. Each of these
determinations should be discussed in terms of the entire waste analysis plan
requirements (i.e., parameters, rationale, sampling methods, sampling frequencies, etc.).
4.6.5 Waste Analysis for Incineration Facilities
OAC Rule 3745-57-41
Incineration facilities must provide in the WAP all information on routine analysis
required by the trial burn. Through the trial burn process facility specific waste analysis
parameters are established which must appear in the WAP. For example, BTU or ash
content of the waste feed may need to fall within an acceptable range to meet both
permit and process conditions established in the trial burn plan. This information is
developed on a facility-specific basis and is beyond the scope of this document.
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4.6.6 Surface Impoundments
OAC Rule 3745-54-13 (B)(7)
Surface impoundments which have been exempted from land disposal restrictions
under paragraph (A) of OAC Rule 3745-59-04 must include the procedures and
schedules required under OAC Rule 3745-54-13 (B)(7) in the waste analysis plan.
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Section 5.0 List of ReferencesSection 5.0 List of References
Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous
Waste. EPA\530-R-94-024,U.S. EPA, Washington, DC,1994.
Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846,. EPA
SW-846.3.3 (most recent revision)
Design and Development of a Hazardous Waste Reactivity Testing Protocol. EPA-
600/52-84-057, U.S. EPA, Municipal Environmental Research Laboratory, Cincinnati,
OH, 1984.
A Method for Determining the Compatibility of Hazardous Wastes. EPA-600/2-80-076,
U.S. EPA, Cincinnati, OH, 1980.
Standard Practice for Sampling Bituminous Materials, D140-88, American Society for
Testing and Materials, 1916 Race Street, Philadelphia, PA 19103.
Standard practice for Collection and Preparation of Coke Samples for Laboratory
Analysis, D346-90, American Society for Testing and Materials, 1916 Race Street,
Philadelphia, PA 19103.
Standard Guide to Site Characterization for Engineering Design, and Construction
Purposes, D420-93, American Society for Testing and Materials, 1916 Race Street,
Philadelphia, PA 19103.
Standard Practice for Soil Investigation and Sampling by Auger Borings, D1452-80,
American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103.
Standard Practice for Collection of a Gross Sample of Coal, D2234-97a, American
Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103.
Standard Test Methods for Compatibility of Screening Analysis of Waste, D5058-90,
American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103.
Standards Chapter 5:Qualtiy Systems, National Environmental Laboratory Accreditation
Conference, Revision 12, July 1, 1999.
Waste Analysis Plan Guidance
Final June 2000
Appendix I - Page 31
Appendix I. Waste Analysis Plan Checklist
How to Use this checklist
The WAP checklist is intended to be used in the actual review of the WAP. Checklist use
is similar to other checklists developed to review portions of the Part B application. Next
to each of the questions, mark either yes, no, or not applicable, depending on the content
of the WAP being reviewed. Note that when information is provided, it is the responsibility
of the WAP reviewer to ensure the information is technically adequate. For example,
OEPA waste codes must be checked to ensure they are the correct code for that waste
stream.
Waste Analysis Plan Guidance
Final June 2000
Appendix I - Page 32
PART B REVIEW CHECKLIST
Section C - WASTE CHARACTERISTICS
Facility/ID# Date
Reviewer DO
Relevant Guidance Documents - WAP Advisory - OEPA/DHWM (draft - 4/98); Federal Waste Analysis guidance manual (4/94)
YES NO NA Page# Notes - NOD Comment #
C-1 Chemical and Physical analyses:
OAC 3745-50-44(A)(2), 3745-54-13
Before hazardous waste is stored, treated or disposed at the
facility, are there procedures in place to describe the waste,
identify the hazard characteristics, and give the basis for hazard
designation ?
Does the WAP contain a complete description of the chemical
and physical analyses of representative samples of waste that
will be conducted and/or obtained by the facility, in order to
treat, store, or dispose of the waste in accordance with Ohio
regulations and terms and conditions of an Ohio hazardous
waste permit?
Are all wastes listed in the part A permit addressed in the
WAP?
C-1a Containerized Waste:
OAC 3745-50-44(C)(1)(b)(i)
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 33
Do owners and operators, that store containers of wastes in
storage areas without secondary containment systems, provide
the test procedures and results, or other documentation or
information, which show that the wastes do not contain free
liquids [see D-1b(1)]? A suggested test for free liquids is the
Paint Filter Liquids Test, Method 9095 in "Test Methods for
Evaluating Solid Wastes, Physical/Chemical Methods," EPA
Publication No. SW-846 as well as visual inspection upon
arrival.
C-1b Waste in Tank Systems:
OAC 3745-55-91(B)(2), 3745-55-92(A)(2)
Are the wastes placed for storage or treatment in tanks
compatible with the tank materials (including, gaskets, valves,
welds, etc.)? If there is the potential for incompatibility what
screening tests are in place (eg., pH, corrosivity, gas
generation, etc.)?
C-1d Landfilled Wastes: OAC 3745-57-14(B)
Does the WAP provide the results from the Paint Filter Liquids
Test (Method 9095 in "Test Methods for Evaluating Solid
Wastes, Physical/Chemical Method," EPA Publication No.
SW-846) showing that containerized or bulk wastes do not
contain free liquids?
C-1e Wastes Incinerated and Wastes Used in Performance
Tests: OAC (C)(8)(c)(i), (iii),(vii), and (viii)
If the applicant opts to not conduct a trial burn, are analyses
provided for each waste or waste mixture to be burned
including:
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 34
a) heat value of the waste in the form it will be
burned;
b) viscosity of liquids or description of the physical
form of non-liquids;
c) identification of any Appendix to OAC 3745-51-11
hazardous constituents reasonably expected to
be present;
d) identification of and the basis for exclusion from
analysis those constituents that are not expected
to be present;
e) an approximate quantification of hazardous
constituents in the waste, including those that
may be POHCs based on data from other trial or
operational burns?
If data is submitted to support the claim that a trial burn is not
needed, are analyses provided that compare the waste to be
burned with data from wastes burned in operational or trial
burns, noting POHCs identified in the waste and any
differences from the POHCs in the waste for which burn data
are provided?
Is waste analysis data submitted that is sufficient to allow the
specification as permit POHCs those constituents for which
destruction and removal efficiencies will be required?
C-1f Wastes to be Land Treated:
OAC 3745-50-44(C)(5)(d)
TBD
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 35
C-1g Waste in Miscellaneous Treatment Units:
OAC 3745-50-44(C)(9)(d)
For any miscellaneous unit treating hazardous waste, does the
WAP provide a report on a demonstration of the effectiveness
of the treatment based on laboratory or field data?
C-2 Waste Analysis Plan:
OAC 3745-50-44(A)(3), 3745-54-13(A),(B) & ( C)
Has the facility provided a copy of the waste analysis plan
(WAP) that describes the methodologies for conducting the
analyses required to properly treat, store, or dispose of
hazardous wastes and to comply with the land disposal
restriction program?
It is anticipated the following facility description information
would be contained in other sections of the part B application,
however if the WAP is a stand alone document, it should be
included:
As part of the waste profiling process, are brief descriptions of
off-site hazardous waste generating processes obtained,
updated, and kept at the facility as part of the operating record?
Are all hazardous wastes generated or managed at the facility
adequately described, including identity of hazardous waste,
approximate quantities managed, process generating the
waste, rationale for identifying the waste as hazardous, and
other appropriate Ohio EPA waste classifications?
C-2a Parameters and Rationale:
OAC 3745-54-13(B)(1)
Does the WAP list parameters chosen for analysis?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 36
Are parameters for determining if a waste is hazardous or not
(e.g. flash point at 140 degrees, pH > 12.5 < 2, etc.) listed for
each waste stream managed?
Are there parameters used to ensure that wastes are within
physical and chemical operating and permit acceptance limits
of the waste management units (e.g. corrosives in steel tanks
or containers)?
Are potential changes in waste characteristics accounted for in
all phases of the treatment process?
Are rationales provided for each parameter selected?
Are sampling, analytical, and procedural methods to identify
ignitable, incompatible, and reactive wastes provided (this
would include for the purposes of storage, handling, treatment
and disposal)?
Does the WAP describe the parameters and rationale for
testing waste before treatment to ensure the appropriateness of
that treatment?
Does the WAP describe the parameters and rationale for
testing waste after treatment to make sure it was effective?
Some listed wastes are listed for additional hazards besides
toxicity (for example U223 is listed for reactivity as well as
toxicity, will the facility screen for reactivity as well). The facility
may need to determine if the additional hazard codes apply. Do
listed wastes have more than one waste hazard that need to be
analyzed for and, therefore, are the appropriate parameters
selected for these wastes?
C-2b Test Methods: OAC 3745-54-13(B)(2)
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 37
Does the WAP identify and reference (e.g., EPA Test No.) the
test methods used to test for parameters chosen?
Are the analytical methods approved methods, as found in SW-
846 or ASTM standards?
Are modifications to the approved methods or alternate
methods fully described in the permit application and is the
modified or alternate method equivalent to an approved
method?
Does the WAP specify if the laboratory used is an on-site or off-
site laboratory?
If the permittee indicates they will use an off site laboratory do
they state in the WAP they will ensure that the off site
laboratory will utilize the methods (SW-846 or equivalent
method) in the facility WAP including all QA/QC procedures?
Does the WAP include a quality assurance plan in accordance
with SW-846 chapter one or other appropriate guidance that
includes the following?
1) A statement of project objectives?
2) The WAP shall ensure that the detection limits
are in accordance with SW-846 methods or
methods approved under the WAP.
3) A description of handling and storage of sampling
and analysis records (including custody
procedures for shipping to other labs). A
statement must be in the WAP that these records
will be part of the facility operating record.
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 38
4) A description of organizational structure,
functional responsibilities, and lines of
communications for the facility’s lab personnel.
This should describe who is responsible for QA
and how others report to him/her (this should
include who is responsible for QA of off-site labs
as well).
5) Is s description of the training required for those
involved in QA/QC located in the application (this
may also be covered in section H of the
application)?
6) A description of performance evaluation. The
WAP should define how often this will occur, and
what will be done if problems are found.
7) A description of how QA/QC will be ensured for
field activities. The WAP must specify that this
will include the checks on the completeness of
field reports, validation of sampling methods, and
determination of representativeness. The WAP
must also specify how often these activities will
occur.
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 39
8) A description of how QA/QC will be ensured for
lab activities. The WAP should specify that the
following will occur at a specified time frame;
a) a check for completeness of records
b) evaluation of data with respect to detection
and quantitation limits
c) evaluation of data with respect to control
limits
d) review of holding time data
e) correlation of lab data with related tests
f) calibration of instruments.
9) A description of QA reports. The WAP must
specify how often these are generated, that they
will report on measurement quality indicators, QA
assessments, including defined operating
standards. The WAP must also specify who will
be responsible and how and what corrective
action will be taken.
10) Are quality control methods presented, including
analysis of method blanks, matrix spikes,
surrogate spikes, and duplicate samples which
are used to measure laboratory precision and
accuracy?
Are analytical methods for each parameter to be analyzed
specified?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 40
C-2c Sampling Methods: OAC 3745-54-13(B)(3)
Does the WAP identify and reference (e.g., ASTM) the
sampling methods used to obtain a representative sample of
each waste to be analyzed and document that the chosen
method is appropriate for the type and nature of the waste?
Does this include selection of the appropriate type of equipment
for the waste?
Are sampling methods used from Appendix I of OAC 3745-51-
20 (most recent version), or are they approved equivalent
method?
Is there a clearly defined sampling approach that includes
a) the objectives of sampling,
b) types of samples needed,
c) sampling locations,
d) number of samples,
e) sampling frequency,
f) collection techniques,
g) and handling techniques?
Is the sampling equipment to be used to collect each sample
clearly identified as well as the procedure to use that
equipment?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 41
Is the sampling equipment chosen appropriate based on criteria
of physical parameters, chemical parameters, and waste-
specific or site specific factors?
Are appropriate maintenance and decontamination procedures
specified for each piece of sampling equipment?
Are field calibration procedures for sampling equipment
specified (as applicable)?
Are samples properly preserved and stored in accordance with
SW-846?
Are holding times specified for each sample?
Are appropriate sample containers used?
Does the WAP describe a method for documenting and
justifying deviations from the WAP?
Are QC measures to be taken clearly identified?
Are QC procedures identified adequate to measure attainment
of QA objectives, including use of field blanks, trip blanks,
equipment blanks, split samples, and field duplicates?
Are proper chain of custody procedures to be followed
identified?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 42
Is adequate sample information collected and recorded,
including type of waste collected, names and signatures of
samplers, sample number, site map (if needed),date and time
of collection, designation as grab or composite, names and
signatures of any persons handling the samples, and the
shipping number if sample are sent to an off-site laboratory
(does the facility include the form in the WAP)?
Are health and safety protocols clearly identified?
Does section H include training requirements for personnel
collecting samples specified?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 43
C-2d Frequency of Analyses:
OAC 3745-54-13(A)(3) & (B)(4)
Does the WAP describe the frequency at which the analyses
will be repeated for each waste stream?
Are wastes re-evaluated when waste generating processes are
changed?
Are wastes re-evaluated when wastes characterized by the
TSDF do not match the pre-approved waste analysis or
manifest?
Are waste re-evaluation frequencies adequate to ensure
compliance with permit conditions and other regulatory
requirements?
For incineration facilities, is waste analyzed prior to burning
each batch to verify that the permit conditions will be met and
that prohibited constituents ( e.g. PCBS, dioxins, reactive
wastes) and other specific constituents are not present (see
page 2-48, 4/94 federal WAP guidance)?
C-2e Additional Requirements for Wastes Generated Off-
Site: OAC 3745-54-13(B)(5) & (C)
Does the WAP describe the procedures used to inspect and/or
analyze a representative portion of wastes generated off-site
when they arrive at the facility?
Are statistical methods used to determine a representative
sample of the incoming wastes (e.g., number of drums to be
sampled) described?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 44
Is there a statement in the WAP that describes the minimum
amount of waste to be sampled (eg. no less than 10 percent of
containers for an incoming waste stream)?
Is the waste analysis data that the generator agrees to provide
specified?
Are procedures to determine how well the generators data
represents the waste to be managed provided?
Are procedures to handle wastes which are significantly
different than waste characterized previously specified?
Is the method used to identify each movement of hazardous
waste at the facility specified (examples include bar code
tracking, inventory sheets, etc.)?
If fingerprint analysis is used, are methods used for obtaining a
representative sample provided?
If fingerprint analysis is used, are parameters each waste will
be analyzed for, rationale for parameters selected, and
acceptance and rejection criteria for each parameter specified?
Are there procedures in place to determine if a biodegradable
sorbent has been added to the waste in containers?
C-2f Additional Requirements for Ignitable, Reactive or
Incompatible Wastes:
OAC 3745-54-13(B)(6), 3745-54-17
Does the facility define what is incompatible (e.g. storing acids
and organic ignitables, etc)?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 45
Does the WAP describe the methods used to meet additional
waste analysis requirements necessary for treating, storing, or
disposing of ignitable, reactive or incompatible wastes?
Are procedures in place to identify ignitable, reactive, or
incompatible wastes and are those SOPs included in the WAP?
If testing is used, are testing or analytical methods provided for
ignitable, reactive or incompatible wastes?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 46
C-3 Waste Analysis Requirements Pertaining to Land
Disposal Restrictions:
C-3a Waste Characterization: OAC 3745-54-13(A)
For each hazardous waste stored, treated, or disposed at the
facility, does the facility obtain analytical data necessary to
determine if the waste is a restricted waste in accordance with
OAC Chapter 3745-59? Alternatively, is information provided
from knowledge of the waste to determine if the waste is
restricted?
Where generator knowledge is used to make this
determination, does the WAP specify that all supporting data
will be maintained in the operating record?
C-3a(1) Waste Characteristics: Solvent Wastes and Dioxin-
Containing Wastes: OAC 3745-59-30&31
Does the facility document or state that F001-F005 spent
solvent wastes and F020-F023 and F026-F028
dioxin-containing wastes are prohibited from land disposal
unless:
1) the wastes meet the treatment standards in OAC 3745-
59-41 to 44, or
2) an exemption has been granted pursuant to OAC 3745-
59-06, or
3) a case-by-case extension has been granted pursuant to
OAC 3745-59-05?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 47
C-3a(2) Waste Characteristics: California List Waste:
OAC 3745-59-32
Does the facility document or state that the following wastes
are California list wastes and are prohibited from land disposal:
1) liquid hazardous wastes with a pH less than or equal to
2.0;
2) liquid hazardous wastes containing PCBs at
concentrations greater than or equal to 50 ppm;
3) liquid hazardous wastes that are primarily water and
contain HOCs in total concentrations greater than or
equal to 1,000 mg/1 and less than 10,00 mg/l;
4) non-liquid hazardous wastes containing HOCs in total
concentrations greater than or equal to 1,000 mg/kg;
5) liquid hazardous wastes, including free liquids associated
with any solid or sludge, containing free cyanides in
concentrations greater than or equal to 1,000 mg/1?
Does the facility specify any applicable exceptions to the
prohibitions in OAC 3745-59-32(F)?
C-3a(3) Waste Characteristics: First Third Wastes with Treatment Standards:
OAC 3745-59-33, 3745-59-40 through 3745-59-43
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 48
The First Third wastes for which treatment standards have been
promulgated are listed in OAC 3745-59-33. Does the facility
document or state that wastes which do not meet the treatment
standards in OAC 3745-59-41 through OAC 3745-59-43 are
prohibited from land disposal unless (1) an exemption has been
granted pursuant to OAC 3745-59-06; or (2) a case-by-case
extension has been granted pursuant to OAC 3745-59-05?
To determine whether a First Third waste exceeds the
applicable treatment standards in OAC 3745-59-41 through
OAC 3745-59-43, the initial generator must test a
representative sample of the waste extract or the entire waste,
depending on whether the treatment standards are expressed
as concentrations in the waste extract or the waste.
Alternatively, the generator may use knowledge of the physical
and chemical characteristics of the waste to determine whether
it is restricted. Does the facility document this?
C-3a(4) Waste Characteristics: Second Third Wastes with
Treatment Standards: OAC 3745-59-34
The Second Third wastes for which treatment standards have
been promulgated are listed in OAC 3745-59-34. Does the
facility document or state that wastes which do not meet the
treatment standards in OAC 3745-59-41 through OAC 3745-59-
43 are prohibited from land disposal unless (1) an exemption
has been granted pursuant to OAC 3745-59-06; or (2) a
case-by-case extension has been granted pursuant to OAC
3745-59-05?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 49
To determine whether a Second Third waste exceeds the
applicable treatment standards in OAC 3745-59-41 through
OAC 3745-59-43, the initial generator must test a
representative sample of the waste extract or the entire waste,
depending on whether the treatment standards are expressed
as concentrations in the waste extract or the waste.
Alternatively, the generator may use knowledge of the physical
and chemical characteristics of the waste to determine whether
it is restricted. Does the facility obtain the supporting
documentation to determine that the waste exceeds the
applicable treatment standards?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 50
C-3a(5) Waste Characteristics: Third Third Wastes with
Treatment Standards: OAC 3745-59-35
The Third Third wastes for which treatment standards have
been promulgated are listed in OAC 3745-59-35. Wastes
which do not meet the treatment standards in OAC 3745-59-41
through OAC 3745-59-43 are prohibited from land disposal
unless (1) an exemption has been granted pursuant to OAC
3745-59-06; (2) the waste meets alternative treatment
standards in OAC 3745-59-44; or (3) a case-by-case extension
has been granted pursuant to OAC 3745-59-05.
To determine whether a Third Third waste exceeds the
applicable treatment standards in OAC 3745-59-41 through
3745-59-43, the initial generator must test a representative
sample of the waste extract or the entire waste, depending on
whether the treatment standards are expressed as
concentrations in the waste extract or the waste. Alternatively,
the generator may use knowledge of the physical and chemical
characteristics of the waste to determine whether it is restricted.
Does the facility obtain the supporting documentation to
determine that the waste exceeds the applicable treatment
standards?
C-3a(6) Other Sampling and Analytical Requirements :
OAC 3745-59-30 to 35
Does the WAP specify the sampling and analytical procedures
to be followed in characterizing wastes to determine if they are
restricted from land disposal?
Does the WAP indicate that the Toxicity Characteristic
Leaching Procedure (TCLP) described in Appendix to OAC
3745-59-07 must be used to develop extract of solvent or dioxin
wastes?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 51
Does the WAP specify that the actual liquid waste, not an
extract or a filtrate, must be tested when measuring pH, PCB,
and HOC concentrations in making California list restriction
determinations?
Does the WAP specify that the Paint Filter Test, as described in
SW-846, must be used to determine if wastes are liquids?
C-3a(7) Sampling and Analytical Requirements for
Treatment Residues: OAC 3745-59-07(B)
C-3a(7)(a) Wastes with Treatment Standards Expressed as
Concentrations in the Waste: OAC 3745-59-
07(B)(3)
For wastes with treatment standards expressed as
concentrations in the waste [OAC 3745-59-07(B)(3)] does the
WAP for the treatment facility provide procedures for testing the
treatment residues (not an extract of such residues) to assure
that the treatment residues meet the applicable treatment
standards?
C-3a(7)(b) Analysis of treatment Residues:
OAC 3745-59-07(B)(1)
Does the WAP specify procedures for analyzing treatment
residues to determine if treatment has achieved the required
levels? Note that this requirement does not include those
wastes for which treatment technologies have been specified
(liquid wastes with PCB concentrations greater than or equal to
50 ppm; liquid and non-liquid wastes with HOC concentrations
greater than or equal to 1000 mg/kg).
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 52
Does the WAP provide procedures for testing treatment
residues of solvent and dioxin-containing wastes, or an extract
of such residues developed using the TCLP, to determine if it
meets applicable treatment standards in OAC 3745-59-41.
Does the WAP provide procedures for testing the waste residue
(not a filtrate or an extract) of California list restricted waste to
determine if the pH is less than or equal to 2.0 or if the
concentration of California list constituents is at or below levels
specified in Section 3004(d).
C-3a(7)(c) Wastes with Treatment Standards Expressed as
Concentrations in the Waste Extract: OAC 3745-59-
07(B)(1)
For wastes with treatment standards expressed as
concentrations in the waste extract, does the WAP specify that
the treatment facilities will provide procedures for testing the
treatment residues or an extract of such residues developed
using the TCLP, to assure that the treatment residues meet the
applicable treatment standards?
C-3a(7)(d) Sampling and Analytical Procedures:
Appendix to OAC 3745-59-07(B)
Does the WAP specify the sampling and analytical procedures
to be followed in testing the treatment residues?
C-3a(7)(e) California List Wastes Not Subject to Treatment
Standards: OAC 3745-59-07(B)(2)
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 53
For California List Wastes not subject to treatment standards,
does the WAP for the treatment facility provide procedures for
testing the treatment residues according to the generator
testing requirements in OAC 3745-59-32 (see C-3a(2)) to
assure that the treatment residues comply with the applicable
prohibitions?
C-3a(7)(f) Frequency of Analysis: OAC 3745-54-13(A)(3),
OAC 3745-59-07(B)
Does the WAP describe the frequency at which analysis of
treatment residues will be repeated? Does the frequency
chosen take into account the variability of the waste(s) and
treatment process? Analysis must be performed if there is any
reason to believe that the composition of the waste or the
treatment process has changed.
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 54
C-3b Notification and Certification Requirements:
OAC 3745-59-07
C-3b(1) Retention of Generator Notices and Certifications:
OAC 3745-59-07(A)
Does the WAP specify that the owner/operator of a treatment,
storage, or disposal facility managing any waste subject to
restrictions will review and maintain notices and certifications
submitted by the initial generator of the waste (where
applicable)?
C-3b(2) Notification and Certification for Wastes to be
Further Managed: OAC 3745-59-07(B)(6)
Does the WAP specify that for treatment residues of restricted
wastes that will be further managed at a different treatment,
storage, or disposal facility, the owner/operator of the facility
sending the waste off-site will submit a notice and certification
in compliance with the notice and certification requirements
applicable to generators under OAC 3745-59-07?
C-3b(3) Additional Notification and Certification
Requirements for Treatment Facilities:
OAC 3745-59-07(B)
C-3b(3)(a) Wastes with Treatment Standards Expressed as
Concentrations: OAC 3745-59-07(B)(5)(a)
For wastes with treatment standards expressed as
concentrations in the waste extract or in the waste (OAC 3745-
59-41 and 43), does the treatment facility state that it will
submit a certification to the land disposal facility in accordance
with OAC 3745-59-07(B)(5)(a)?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 55
C-3b(3)(b) Waste with Treatment Standards Expressed as
Technologies: OAC 3745-59-07(B)(5)(b)
For wastes with treatment standards expressed as technologies
(OAC 3745-59-42), does the treatment facility state it will
submit a certification to the land disposal facility in accordance
with OAC 3745-59-07(B)(5)(b)?
C-3b(3)(c) California List Wastes Not Subject to Treatment
standards: OAC 3745-59-07(B)(5)(a)
For California list wastes which are not subject to treatment
standards, does the treatment facility state it will submit a
certification to the land disposal facility in accordance with OAC
3745-59-07(B)(5)(a)?
C-3b(3)(d) Recyclable Materials used in a Manner Constituting
Disposal: OAC 3745-59-07(B)(7)
For wastes which are recyclable materials used in a manner
constituting disposal, in accordance with OAC 3745-58-30,
does the owner/operator of a treatment facility state it will
submit a notice and certification to the Director in accordance
with OAC 3745-59-07(B)(7)?
C-3b(4) Additional Notification and Certification
Requirements for Disposal facilities:
OAC 3745-59-07(C)(1)
Does the owner/operator of a land disposal facility disposing
any waste subject to restrictions state that it will maintain
copies of the notice and certifications submitted by the
generator and the treatment or storage facilities, if applicable?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 56
C-3c Additional Requirements Pertaining to Storage of
Restricted Wastes: OAC 3745-59-50(A), (D), & (F)
Do owner/operators of treatment, storage, or disposal facilities
storing hazardous wastes that are restricted from land disposal
demonstrate that (1) they are storing such wastes in tanks or
containers and (2) such storage is solely for the purpose of
accumulating sufficient quantities of waste to facilitate proper
treatment, recovery, or disposal?
NOTE. These requirements do not apply to wastes that:
1) meet the applicable treatment standards or prohibition
levels, or
2) are the subject of an approved petition under OAC 3745-
59-06, or
3) have received a nationwide variance under OAC 3745-
59-44, or
4) have received a case-by-case extension under OAC
3745-59-05.
C-3c(1) Restricted Wastes Stored in Containers:
OAC 3745-59-50(A)(2)(a)
If wastes are stored in containers, does the owner/operator
demonstrate that each container will be clearly marked to
identify its contents and the date each period of accumulation
begins?.
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 57
C-3c(2) Restricted Wastes Stored in Tanks:
OAC 3745-59-50(A)(2)(b)
If wastes are stored in tanks, does the owner/operator
demonstrate that each tank will be clearly marked with a
description of its contents, the quantity of each hazardous
waste received, and the date each period of accumulation
begins?. Alternatively, does the owner/operator may
demonstrate that such information for each tank will be
recorded and maintained in the operating record at the facility?.
C-3c(3) Storage of liquid PCB Wastes:
OAC 3745-59-50(F)
If liquid hazardous wastes containing concentrations of PCBs
greater than or equal to 50 ppm will be stored at the facility,
does the owner/operator demonstrate that the facility meets the
requirements of 40 CFR 761.65(b)?. The owner/operator must
describe procedures for removal of these wastes from storage
within one year and treatment or disposal of the wastes in
compliance with land disposal restrictions.
C-3d Additional Requirements for Land Disposal Facilities:
OAC 3745-54-13(A)(1) and OAC 3745-59-07(C)
Does the owner/operator of a land disposal facility provide
procedures for testing the waste or an extract of the waste or
treatment residue or using any methods required for generators
under OAC 3745-59-32 to ensure that the wastes or treatment
residues comply with applicable treatment standards and
California list prohibitions?
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 58
C-3d(1) Off-site Facilities: OAC 3745-59-07(C)(1) & (2)
If wastes or treatment residues are received from an off-site
generator or treatment facility, does the WAP specify
procedures which assure that wastes will not be disposed
without receipt of proper notice and certification as specified in
OAC 3745-59-07(A) and (B)?. If the treatment standard for the
waste is a specified treatment method (liquid and non-liquid
HOC wastes and liquid PCB wastes), certification must be
received to ensure that the waste has been treated using the
specified technology.
C-3e Additional Requirements for Surface Impoundments
Exempted from Land Disposal Restrictions:
For surface impoundments exempted from land disposal
restrictions under OAC 3745-59-04(A), does the owner/operator
demonstrate the following?:
C-3e(1) Case-by-Case Extensions to an Effective Date:
OAC 3745-59-05
That the treatment, storage, or disposal facility has requested
an extension to the effective date of any restriction in Subpart C
of 40 CFR 268, has submitted an application to the Regional
Administrator, U.S. EPA, containing the information and
certification described in 40 CFR 268.5(a) and (b), and has
received U.S. EPA approval of the extension. The Director will
recognize a denial by the U.S. EPA or an approval by the U.S.
EPA.
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 59
C-3e(2) Exemption from a Prohibition:
OAC 3745-59-04
That the treatment, storage, or disposal facility requesting an
exemption from a prohibition for the disposal of a particular
restricted waste in a particular unit or units has submitted a
petition to the Director demonstrating that there will be no
migration of hazardous constituents from the disposal unit or
injection zone for as long as the wastes remain hazardous. The
petition must include the demonstration and certification
specified in 40 CFR 268.6(a) through (d).
If a petition has been approved under 40 CFR 268.6, has the
owner/operator must provide a copy of the Notice of Approval?
C-3e(3) Variance from a Treatment Standard:
OAC 3745-59-44
That the treatment facility has petitioned the Regional
Administrator, U.S. EPA, for a site-specific variance from the
treatment standard if a waste cannot be treated to the specified
level or where the treatment technology is not appropriate to the
waste. Has the applicant demonstrated that, because the
physical or chemical properties of the waste differ significantly
from wastes analyzed in developing the treatment standard, the
waste cannot be treated to specified levels or by the specified
methods?
C-3e(4) Additional Requirements for Surface Impoundments
Exempted from Land Disposal Restrictions:
OAC 3745-59-04(A)
For treatment surface impoundments exempted from land
disposal restrictions under OAC 3745-59-04(A), the
owner/operator must meet the following requirements:
Waste Analysis Plan Guidance
Final June 2000
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 60
C-3e(4)(a) Treatment of Wastes:
OAC 3745-59-04(A)(1)
Does the owner/operator demonstrate that treatment of wastes
otherwise prohibited from land disposal occurs in the surface
impoundment?
C-3e(4)(b) Sampling and Testing:
OAC 3745-59-04(A)(2)(a)
Does the facility’s waste analysis plan include the procedures
and schedules for sampling and analysis of treatment residues
and the analysis of test data to determine if the residues meet
the applicable treatment standards or prohibitions?
C-3e(4)(c) Annual Removal of Residues:
OAC 3745-59-04(A)(2)(b)
Does the owner/operator provide procedures and schedules for
annual removal from the surface impoundment of treatment
residues (including any liquid waste) that:
1) do not meet treatment standards or prohibition levels, or
2) are residues of wastes prohibited from land disposal
where no treatment standards or prohibitions apply, or
3) are residues from listed wastes that are not delisted
under OAC 3745-50-221, or
4) are wastes that exhibit a characteristic of hazardous
waste.
YES NO NA Page# Notes - NOD Comment #
Appendix I - Page 61
C-3e(4)(d) Recordkeeping Requirements:
OAC 3745-59-04(A)(2)(c)
Does the owner/operator provide procedures and schedules for
sampling impoundment contents, analyzing test data, and
annually removing any treatment residues that do not meet
treatment standards or prohibition levels or are from the
treatment of wastes prohibited from land disposal in OAC 3745-
59-30 to 35?
C-3e(4)(e) Design Requirements:
OAC 3745-59-04(A)(3) & OAC 3745-56-21
Does the owner or operator of the facility must demonstrate
that the design requirements of OAC 3745-56-21(C) have been
met or that an exemption, waiver, or modification has been
granted under OAC 3745-59-04(A)(3)?
C-3f Requirements for Land Disposal Facilities with an
approved Exemption or Extension:
OAC 3745-59-05, 3745-59-06
If a case by case extension has been approved under OAC
3745-59-05 or a petition has been approved under OAC 3745-
59-06, has the facility provided a copy of the Notice of
Approval?
Appendix II - Page 62
Appendix II. Table 7-1 from DHWM Sampling Manual
The attached table is taken from the DHWM Sampling Manual. It is provided here as a
reference only and should not be relied upon as a sole information source for determining
sample containers, preservation techniques, or holding times. Users of this table are
encouraged to contact the laboratory for help in identifying sample requirements.
Table 7-1
Parameters, Method, Preservation, Holding Times
Sample Volume, and Containers
Appendix II - Page 63
PARAMETERS METHOD MINIMUM
SAMPLE
VOLUME
HOLDING
TIME
CONTAINER CLEANED
TO EPA
PROTOCOL
PRESERVATIVE SAMPLE
TYPE
Acid Only 8270 *30 grams
**1 liter
7 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
Cool 4EC
Dark
Antimony 6010 *2 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Arsenic 7000 *2 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Arsenic 6010 *2 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Barium 6010 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Base Neutral Acid 8270 *30 grams
**l liter
7 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
.008% Na
2
S
2
O
3
Cool 4EC
pH = 4
Dark
Base Neutrals Only 8080 *30 grams
**l liter
7 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
.008% Na
2
S
2
O
3
Cool 4EC
pH = 4
Dark
Beryllium 6010 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Chromium VI *7196/7197
**218.4
218.5
*10 grams
**200 ml
24 Hours *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G
Dissolved Mercury *7470/7471
**245
*10 grams
**100 ml
38 Days in glass
13 Days in plastic
38 Days in glass
13 Days in plastic
*A
**C
Filter
pH < 2 HNO
3
Cool 4EC
Hazardous Waste
Corrosivity *1110
*
**2 liter
7 Days *
**2.5 liter A.J.
**A None G/C
Table 7.1 (cont’d)
Parameters, Method, Preservation, Holding Times
Sample Volume, and Containers
PARAMETERS METHOD MINIMUM
SAMPLE
VOLUME
HOLDING
TIME
CONTAINER CLEANED
TO EPA
PROTOCOL
PRESERVATIVE SAMPLE
TYPE
Appendix II - Page 64
Hazardous Waste
Ignitability
*1010/1020 *
**100 ml
7 Days *
**500 ml B.R.
*A
**C
None G/C
Hazardous Waste
Toxicity
*1311 *100 grams 7 Days to ext
40 Days aft ext
*2.5 liter CWM *A None G/C
Hazardous Waste
Reactivity
*7.3.3.2
7.3.4.2
*20 grams
**500 ml
7 Days *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC
Dark
G/C
Hexavalent Chromium *7196/7197
**218.4
218.5
*10 grams
**200 ml
24 Hours *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G
Hydrogen Ion *9040/9045
**150
*20 grams
**25 ml
Immediately *4 oz CWM
**60 ml HDPE
*A
**C
None G
Lead 7000 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Lead 6010 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Mercury, Dissolved *7470/7471
**245
*10 grams
**100 ml
38 Days in glass
13 Days in plastic
38 Days in glass
13 Days in plastic
*A
**C
Filter
pH<2 HNO
3
Cool 4EC
Mercury, Total *7470/7471
**245
*10 grams
**100 ml
38 Days in glass
13 Days in plastic
38 Days in glass
13 Days in plastic
*A
**C
pH<2 HNO
3
Cool 4EC
Total Recoverable
Metals (except
chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
pH<2 HNO
3
Cool 4EC
Metals, Total
Recoverable (except
chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
pH<2 HNO
3
Cool 4EC
Table 7.1 (cont’d)
Parameters, Method, Preservation, Holding Times
Sample Volume, and Containers
PARAMETERS METHOD MINIMUM
SAMPLE
VOLUME
HOLDING
TIME
CONTAINER CLEANED
TO EPA
PROTOCOL
PRESERVATIVE SAMPLE
TYPE
Appendix II - Page 65
Dissolved Metals
(except chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Filter on site
pH<2 HNO
3
Cool 4EC
Metals, Dissolved
(except chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Filter on site
pH<2 HNO
3
Cool 4EC
Suspended Metals
(except chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Filter on site
pH<2 HNO
3
Cool 4EC
Metals, Suspended
(except chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Filter on site
pH<2 HNO
3
Cool 4EC
Total Metals (except
chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
pH<2 HNO
3
Cool 4EC
Metals Total (except
chromium and
mercury)
*7000 series
6010
**200 series
200.7
*10 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
pH<2 HNO
3
Cool 4EC
G
Metals - TAL (23) 6010/7000 *2 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Metals - RCRA (8) 6010/7000 *2 grams
**200 ml
6 Months *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Organochlorine
Pesticides
8080 *30 grams
**1 liter
14 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
Cool 4EC
Table 7.1 (cont’d)
Parameters, Method, Preservation, Holding Times
Sample Volume, and Containers
PARAMETERS METHOD MINIMUM
SAMPLE
VOLUME
HOLDING
TIME
CONTAINER CLEANED
TO EPA
PROTOCOL
PRESERVATIVE SAMPLE
TYPE
Appendix II - Page 66
Paint Filter Liquid Test 9095 100 grams
100 ml
8 oz CWM A Cool 4EC
PCB's *8080
**608
*30 grams
**l liter
7 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
Cool 4EC G/C
pH *9040/9045
**150
*20 grams
**25 ml
Immediately *4 oz CWM
**60 ml HDPE
*A
**C
None G
Reactive Sulfide *7.3.3.2
7.3.4.2
*10 grams
**250 ml
7 Days *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC
Dark
G
Reactive Cyanide *7.3.3.2
7.3.4.2
*10 grams
**250 ml
7 Days *4 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC
Dark
G
Selenium 7000 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Selenium 6010 *2 grams
** 200 ml
6 Months *3 oz CWM
**500 ml HDPE
*A
**C
Cool 4EC G/C
Semi-Volatile Organic *8270
**625,1625
*30 grams
**1 liter
7 Days to ext
40 Days aft ext
*8 oz CWM
**2.5 liter A.J.
*A
**A
.008% Na
2
S
2
O
3
Cool 4EC
TCLP Extraction *1311 *100 grams 7 Days to ext
40 Days aft ext
*2.5 liter CWM *A None
TCLP Sample *100 grams 7 Days to ext
40 Days aft ext
*16 oz CWM *A None
Total Mercury *7470/7471
**245
*10 grams
**100 ml
38 Days in glass
13 Days in plastic
38 Days in glass
13 Days in plastic
*A
**C
pH<2 HNO
3
Cool 4EC
Volatile Organics *8260
**624/1624
*5 grams
**5 ml
14 Days *4 oz CWM
**40 ml Vial
*A
**B
4 Drops HCl
.008% Na
2
S
2
O
3
Cool 4EC
G
Environmental Sampling Guide, Eagle Picher, Environmental Services Department, 1993
Appendix II - Page 67
* = Solid Waste Method (SW-846)
** = Water/Wastewater Method (EPA-600)
Sample Type
G - Grab
C - Composite
HDPE = High-Density Polyethylene Bottle
B.R. = Boston Round
CWM = Clear Wide Mouth
A.J. = Amber Jug
Vial = Teflon-lined Septum
A = Cleaned to Protocol A
B = Cleaned to Protocol B
C = Cleaned to Protocol C
Preservations listed are for liquid samples.
Solid samples are preserved by placing on ice.
HCL = Hydrochloric Acid - dilute 1:1
HNO
3
= Nitric Acid - dilute 1:1
H
2
SO
4
= Sulfuric Acid - dilute 1:1
NaOH = Sodium Hydroxide - dilute 1:1
Na
2
S
2
O
3
= Sodium Thiosulfate - for dechlorination
Refer to SOP -105 for a complete list of parameters.
Appendix III - Page 68
Appendix III. Waste Analysis Regulations
The following regulations are provided for your convenience.
OAC rule 3745-54-13 General waste analysis.
(A)(1) Before an owner or operator treats, stores, or disposes of any hazardous waste, or
nonhazardous waste if applicable under paragraph (D) of rule 3745-55-13 of the
Administrative Code, he shall obtain a detailed chemical and physical analysis of a
representative sample of the waste. At a minimum, this analysis shall contain all the
information which must be known to treat, store, or dispose of the waste in accordance
with the requirements of Chapters 3745-54 to 3745-57 and 3745-59 of the Administrative
Code or with the terms and conditions of an Ohio hazardous waste permit.
(2) The analysis may include data developed under Chapter 3745-51 of the Administrative
Code and existing published or documented data on the hazardous waste or on hazardous
waste generated from similar processes.
[Comment: For example, the facility's records of analyses performed on the waste before
the effective date of this rule, or studies conducted on hazardous waste generated from
processes similar to that which generated the waste to be managed at the facility, may be
included in the data base required to comply with paragraph (A)(1) of this rule. The owner
or operator of an off-site facility may arrange for the generator of the hazardous waste to
supply part or all of the information required by paragraph (A)(1) of this rule, except as
otherwise specified in paragraphs (B) and (C) of rule 3745-59-07 of the Administrative
Code. If the generator does not supply the information, and the owner or operator chooses
to accept a hazardous waste, the owner or operator is responsible for obtaining the
information required to comply with this rule.]
(3) The analysis shall be repeated as necessary to ensure that it is accurate and up to
date. At a minimum, the analysis shall be repeated:
(a) When the owner or operator is notified, or has reason to believe, that the process or
operation generating the hazardous waste, or nonhazardous waste if applicable under
paragraph (D) of rule 3745-55-13 of the Administrative Code, has changed; and
(b) For off-site facilities, when the results of the inspection required in paragraph (A)(4) of
Appendix III - Page 69
this rule indicate that the hazardous waste received at the facility does not match the
waste designated on the accompanying manifest or shipping paper.
(4) The owner or operator of an off-site facility shall inspect and, if necessary, analyze
each hazardous waste movement received at the facility to determine whether it matches
the identity of the waste specified on the accompanying manifest or shipping paper.
(B) The owner or operator shall develop and follow a written waste analysis plan which
describes the procedures to be implemented in order to comply with paragraph (A) of this
rule. He shall keep this plan at the facility. At a minimum, the plan shall specify:
(1) The parameters for which each hazardous waste, or nonhazardous waste if applicable
under paragraph (D) of rule 3745-55-13 of the Administrative Code, will be analyzed and
the rationale for the selection of these parameters (i.e., how analysis for these parameters
will provide sufficient information on the waste's properties to comply with paragraph (A)
of this rule);
(2) The test methods which will be used to test for these parameters;
(3) The sampling method which will be used to obtain a representative sample of the waste
to be analyzed. A representative sample may be obtained using either:
(a) One of the sampling methods described in appendix I of rule 3745-51-20 of the
Administrative Code; or
(b) An equivalent sampling method.
(4) The frequency with which the initial analysis of the waste will be reviewed or repeated
to ensure that the analysis is accurate and up to date; and
(5) For off-site facilities, the waste analyses that hazardous waste generators have agreed
to supply.
(6) Where applicable, the methods which will be used to meet the additional waste
analysis requirements for specific waste management methods as specified in rules
3745-54-17, 3745-57-14, 3745-57-41, and 3745-59-07 of the Administrative Code.
(7) For surface impoundments exempted from land disposal restrictions under paragraph
(A) of rule 3745-59-04 of the Administrative Code, the procedures and schedules for:
(a) The sampling of impoundment contents;
(b) The analysis of test data; and
(c) The annual removal of residues which are not delisted under rule 3745-50-221 of the
Administrative Code or which exhibit a characteristic of hazardous waste and either:
Appendix III - Page 70
(i) Do not meet the applicable treatment standards of rules 3745-59-40 to 3745-59-44 of
the Administrative Code; or
(ii) Where no treatment standards have been established;
(a) Such residues are prohibited from land disposal under rule 3745-59-32 of the
Administrative Code or section 3004(d) of RCRA; or
(b) Such residues are prohibited from land disposal under paragraph (F) of rule
3745-59-33 of the Administrative Code.
(C) For off-site facilities, the waste analysis plan required in paragraph (B) of this rule shall
also specify the procedures which will be used to inspect and, if necessary, analyze each
movement of hazardous waste received at the facility to ensure that it matches the identity
of the waste designated on the accompanying manifest or shipping paper. At a minimum,
the plan shall describe:
(1) The procedures which will be used to determine the identity of each movement of waste
managed at the facility; and
(2) The sampling method which will be used to obtain a representative sample of the waste
to be identified, if the identification method includes sampling.
[Comment: The waste analysis plan shall be submitted with "Part B" of the permit
application.]
(3) The procedures that the owner or operator of an off-site landfill receiving containerized
hazardous waste will use to determine whether a hazardous waste generator or treater has
added a biodegradable sorbent to the waste in the container.
[Note: See rule 3745-57-14 of the Administrative Code.]
Effective: 9/2/97
Prior effective dates: 4/15/81, 1/7/83, 5/29/85 (Emer.), 8/29/85, 1/30/86, 12/30/89, 4/1/90,
2/11/92
119.032 review date: 4/30/98
OAC rule 3745-54-17 General requirements for ignitable, reactive, or incompatible
wastes.
(A) The owner or operator must take precautions to prevent accidental ignition or reaction
of ignitable or reactive waste. This waste must be separated and protected from sources
Appendix III - Page 71
of ignition or reaction including but not limited to: open flames, smoking, cutting and
welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical),
spontaneous ignition (e.g., from heat-producing chemical reactions), and radiant heat.
While ignitable or reactive waste is being handled, the owner or operator must confine
smoking and open flame to specially designated locations. "No Smoking" signs must be
conspicuously placed wherever there is a hazard from ignitable or reactive waste.
(B) Where specifically required by the hazardous waste facility standards chapters, the
owner or operator of a facility that treats, stores or disposes of ignitable or reactive waste,
or mixes incompatible waste or incompatible wastes and other materials, must take
precautions to prevent reactions which:
(1) Generate extreme heat or pressure, fire or explosions, or violent reactions;
(2) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to
threaten human health or the environment;
(3) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk
of fire or explosions;
(4) Damage the structural integrity of the device or facility;
(5) Through other like means threaten human health or the environment.
(C) When required to comply with paragraph (A) or (B) of this rule the owner or operator
must document that compliance. This documentation may be based on references to
published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot
scale tests), waste analyses (as specified in rule 3745-54-14 of the Administrative Code),
or the results of the treatment of similar wastes by similar treatment processes and under
similar operating conditions.
Effective: 1/7/83
Prior effective dates: None
Appendix III - Page 72
OAC rule 3745-57-14 Special requirements for bulk and containerized liquids.
(A) The placement of bulk or non-containerized liquid hazardous waste or hazardous
waste containing free liquids (whether or not sorbents have been added) in any landfill is
prohibited.
(B) To demonstrate the absence or presence of free liquids in either a containerized or a
bulk waste, the following test shall be used: Method 9095 (Paint Filter Liquids Test) as
described in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA
publication SW-846, (incorporated by reference, see rule 3745-50-11 of the Administrative
Code).
(C) Containers holding free liquids must not be placed in a landfill unless:
(1) All free-standing liquid:
(a) Has been removed by decanting or other methods; or
(b) Has been mixed with sorbent or solidified so that free-standing liquid is no longer
observed; or
(c) Has been otherwise eliminated; or
(2) The container is very small, such as an ampule; or
(3) The container is designed to hold free liquids for use other than storage, such as a
battery or capacitor; or
(4) The container is a lab pack as defined in rule 3745-57-16 of the Administrative Code
and is disposed of in accordance with rule 3745-57-16 of the Administrative Code.
(D) Sorbents used to treat free liquids to be disposed of in landfills shall be
nonbiodegradable. Nonbiodegradable sorbents are materials listed or described in
paragraph (D)(1) of this rule; materials that pass one of the tests in (D)(2) of this rule; or
materials that are determined by U.S.EPA to be nonbiodegradable through the petition
process in 40 CFR Part 260.
(1) Nonbiodegradable sorbents.
(a) Inorganic minerals, other inorganic materials, and elemental carbon [e.g.,
aluminosilicates, clays, smectites, Fuller's earth, bentonite, calcium bentonite,
montmorillonite, calcined montmorillonite, kaolinite, micas (illite), vermiculites, zeolites;
calcium carbonate (organic free limestone); oxides/hydroxides, alumina lime silica (sand),
diatomaceous earth; perlite (volcanic glass); expanded volcanic rock; volcanic ash; cement
Appendix III - Page 73
kiln dust; fly ash; rice hull ash; activated charcoal/activated carbon]; or
(b) High molecular weight synthetic polymers [e.g., polyethylene, high density polyethylene
(HDPE), polypropylene, polystyrene, polyurethane, polyacrylate,
polynorborene, polyisobutylene, ground synthetic rubber, cross-linked allylstyrene and
tertiary butyl copolymers]. This does not include polymers derived from biological material
or polymers specifically designed to be degradable; or
(c) Mixtures of these nonbiodegradable materials.
(2) Tests for nonbiodegradable sorbents.
(a) The sorbent material is determined to be nonbiodegradable under ASTM Method
G21-70(1984a)- Standard Practice for Determining Resistance of Synthetic Polymer
Materials to Fungi; or
(b) The sorbent material is determined to be nonbiodegradable under ASTM Method
G22-76(1984b)- Standard Practice for Determining Resistance of Plastics to
Bacteria; or
(c) The sorbent material is determined to be nonbiodegradable under the Organization for
Economic Cooperation and Development (OECD) test 301B- CO2 Evolution (Modified
Sturm Test).
(E) The placement of any liquid which is not a hazardous waste in a landfill is prohibited
unless the owner or operator of such landfill demonstrates to the director, or the director
determines, that:
(1) The only reasonably available alternative to the placement in such landfill is placement
in a landfill or unlined surface impoundment, whether or not permitted or operating under
authority or paragraph (C) of rule 3745-50-40 of the Administrative Code which contains,
or may reasonably be anticipated to contain, hazardous waste; and
(2) Placement in such owner or operator's landfill will not present a risk of contamination
of any underground source of drinking water (as that term is defined in rule 3745-34-01
of the Administrative Code).
Effective: 9/2/97
Prior effective dates: 8/30/84, 5/29/85 (Emer.), 8/29/85, 1/30/86, 12/30/89
119.032 review date: Exempt
OAC rule 3745-57-41 Waste analysis (Incinerators).
(A) As a portion of a trial burn plan required by the trial burn rules or with "Part B" of the
permit application, the owner or operator must have included an analysis of his waste feed
Appendix III - Page 74
sufficient to provide all information required by the trial burn rules. Owners or operators
of new hazardous waste incinerators must provide the information required by the trial
burn rules to the greatest extent possible.
(B) Throughout normal operation the owner or operator must conduct sufficient waste
analysis to verify that waste feed to the incinerator is within the physical and chemical
composition limits specified in his permit (under paragraph (B) of rule 3745-57-45 of the
Administrative Code.
Effective: 11/29/83 Prior effective dates: 1/7/83
OAC rule 3745-59-07 Waste analysis and recordkeeping (LDR).
(A) Except as specified in rule 3745-59-32 of the Administrative Code, if a generator's
waste is listed in rules 3745-51-30 to 3745-51-35 of the Administrative Code, the generator
shall test his waste, or test an extract using the Toxicity Characteristic Leaching
Procedure, Method 1311 in "Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods," EPA Publication SW-846 (incorposated by reference, see rule 3745-50-11 of
the Administrative Code), or use knowledge of the waste, to determine if the waste is
restricted from land disposal under Chapter 3745-59 of the Administrative Code. Except
as specified in rule 3745-59-32 of the Administrative Code, if a generator's waste exhibits
one or more of the characteristics set forth in rules 3745-51-20 to 3745-51-24 of the
Administrative Code, the generator shall test an extract using the Extraction Procedure
Toxicity Test, Method 1310 in "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods," EPA Publication SW-846 (incorposated by reference, see
rule 3745-50-11 of the Administrative Code), or use knowledge of the waste, to determine
if the waste is restricted from land disposal under Chapter 3745-59 of the Administrative
Code.
(1) If a generator determines that he is managing a restricted waste under Chapter
3745-59 of the Administrative Code and the waste does not meet the applicable treatment
standards set forth in rules 3745-59-40 to 3745-59-44 of the Administrative Code or
exceeds the applicable prohibition levels set forth in rule 3745-59-32 of the Administrative
Code or section 3004(d) of RCRA, with each shipment of waste the generator shall notify
the treatment or storage facility in writing of the appropriate treatment standards set forth
in rules 3745-59-40 to 3745-59-44 of the Administrative Code and any applicable
prohibition levels set forth in rule 3745-59-32 of the Administrative Code or section 3004(d)
of RCRA. The notice shall include the following information:
(a) U.S. EPA Hazardous Waste Number;
(b) The corresponding treatment standards for wastes F001 to F005, F039, and wastes
prohibited pursuant to rule 3745-59-32 of the Administrative Code or section 3004(d) of
RCRA. Treatment standards for all other restricted wastes must either be included, or be
Appendix III - Page 75
referenced by including on the notification the applicable wastewater or nonwastewater
(both terms as defined in rule 3745-59-02 of the Administrative Code) category, the
applicable subdivisions made within a waste code based on waste-specific criteria (such
as D003 reactive cyanides), and the rules in the Administrative Code where the applicable
treatment standard appears. Where the applicable treatment standards are expressed as
specified technologies in rule 3745-59-42 of the Administrative Code, the applicable
five-letter treatment code found in Table 1 of rule 3745-59-42 of the Administrative Code
(e.g., INCIN, WETOX) also must be listed on the notification;
(c) The manifest number associated with the shipment of waste; and
(d) Waste analysis data, where available.
(2) If a generator determines that he is managing a restricted waste under Chapter
3745-59 of the Administrative Code, and determines that the waste can be land disposed
without further treatment, with each shipment of waste he shall submit, to the treatment,
storage, or land disposal facility, a notice and a certification stating that the waste meets
the applicable treatment standards set forth in rules 3745-59-40 to 3745-59-44 of the
Administrative Code and the applicable prohibition levels set forth in rule 3745-59-32 of
the Administrative Code or section 3004(d) of RCRA.
(a) The notice must include the following information:
(i) U.S. EPA Hazardous Waste Number;
(ii) The corresponding treatment standards for wastes F001 to F005, F039, and wastes
prohibited pursuant to rule 3745-59-32 of the Administrative Code or section 3004(d) of
RCRA. Treatment standards for all other restricted wastes must either be included, or be
referenced by including on the notification the applicable wastewater or nonwastewater
(both terms as defined in rule 3745-59-02 of the Administrative Code) category, the
applicable subdivisions made within a waste code based on waste-specific criteria (such
as D003 reactive cyanides), and the rules in the Administrative Code where the applicable
treatment standard appears. Where the applicable treatment standards are expressed as
specified technologies in rule 3745-59-42 of the Administrative Code, the applicable
five-letter treatment code found in Table 1 of rule 3745-59-42 of the Administrative Code
(e.g., INCIN, WETOX) also must be listed on the notification.
(iii) The manifest number associated with the shipment of waste;
(iv) Waste analysis data, where available.
(b) The certification shall be signed by an authorized representative and shall state the
following:
Appendix III - Page 76
"I certify under penalty of law that I personally have examined and am familiar with the
waste through analysis and testing or through knowledge of the waste to support this
certification that the waste complies with the treatment standards specified in rules
3745-59-40 to 3745-59-44 of the Administrative Code and all applicable prohibitions set
forth in rule 3745-59-32 of the Administrative Code or section 3004(d) of RCRA. I believe
that the information I submitted is true, accurate, and complete. I am aware that there are
significant penalties for submitting a false certification, including the possibility of a fine
and imprisonment."
(3) If a generator's waste is subject to an exemption from a prohibition on the type of land
disposal method utilized for the waste (such as, but not limited to, a case-by-case
extension under rule 3745-59-05 of the Administrative Code, an exemption under
3745-59-06 of the Administrative Code, or a nationwide capacity variance under rules
3745-59-30 to 3745-59-35 of the Administrative Code), with each shipment of waste he
shall submit a notice to the facility receiving his waste stating that the waste is not
prohibited from land disposal. The notice shall include the following information:
(a) U.S. EPA Hazardous Waste Number;
(b) The corresponding treatment standards for wastes F001 to F005, F039, and wastes
prohibited pursuant to rule 3745-59-32 of the Administrative Code or section 3004(d) of
RCRA. Treatment standards for all other restricted wastes must either be included, or be
referenced by including on the notification the applicable wastewater or nonwastewater
(both terms as defined in rule 3745-59-02 of the Administrative Code) category, the
applicable subdivisions made within a waste code based on waste-specific criteria (such
as D003 reactive cyanides), and the rules in the Administrative Code where the applicable
treatment standard appears. Where the applicable treatment standards are expressed as
specified technologies in rule 3745-59-42 of the Administrative Code, the applicable
five-letter treatment code found in Table 1 of rule 3745-59-42 of the Administrative Code
(e.g., INCIN, WETOX) also must be listed on the notification.
(c) The manifest number associated with the shipment of waste;
(d) Waste analysis data, where available; and
(e) The date the waste is subject to the prohibitions.
(4) If a generator within the iron and steel industry, SIC codes 331X and 332X, is
managing prohibited waste resulting from the production of iron, steel, or coke, specified
in paragraph (G)(9) of rule 3745-54-01 or paragraph (C)(12) of rule 3745-65-01 of the
Administrative Code, in tanks or containers regulated under rule 3745-52-34 of the
Administrative Code, and is treating such waste in such tanks or containers to meet
applicable treatment standards under rules 3745-59-40 to 3745-59-44 of the Administrative
Code, the generator must develop and follow a written waste analysis plan which
Appendix III - Page 77
describes the procedures the generator will carry out to comply with the treatment
standards. (Generators treating hazardous debris under the alternative treatment
standards of Table 1 of 40 CFR section 268.45, However, are not subject to these waste
analysis requirements.) The plan must be kept on site in the generator's records, and the
following requirements must be met:
(a) The waste analysis plan must be based on a detailed chemical and physical analysis
of a representative sample of the prohibited waste(s) being treated, and must contain all
information necessary to treat the waste(s) in accordance with the requirements of Chapter
3745-59 of the Administrative Code, including the selected testing frequency.
(b) Such plan must be filed with the director, or his designated representative, a minimum
of thirty days prior to the treatment activity, with delivery verified.
(c) Wastes shipped off-site pursuant to paragraph (A)(4) of this rule must comply with the
notification requirements of paragraph (A)(2) of this rule.
(5) If a generator determines whether the waste is restricted based solely on his
knowledge of the waste, all supporting data used to make this determination shall be
retained on-site in the generator's files. If a generator determines whether the waste is
restricted based on testing this waste or an extract developed using the test method
described in the appendix to rule 3745-51-24 of the Administrative Code, all waste
analysis data shall be retained on-site in the generator's files.
(6) If a generator determines that he is managing a restricted waste that is excluded from
the definition of waste or hazardous waste or exempt from regulation under Chapters
3745-50 to 3745-69 of the Administrative Code, under rules 3745-51-02 to 3745-51-06 of
the Administrative Code subsequent to the point of generation, he must place a one-time
notice stating such generation, subsequent exclusion from the definition of waste or
hazardous waste or exemption from regulation under Chapters 3745-50 to 3745-69 of the
Administrative Code, and the disposition of the waste, in the facility's file.
Appendix III - Page 78
(7) Generators shall retain on-site a copy of all notices, certifications, demonstrations,
waste analysis data, and other documentation produced pursuant to this rule for at least
five years from the date that the waste that is the subject of such documentation was last
sent to on-site or off-site treatment, storage, or disposal. The five year record retention
period is automatically extended during the course of any unresolved enforcement action
regarding the regulated activity or as requested by the director. The requirements of
paragraphs (A) to (A)(10) of this rule apply to wastes even when the hazardous
characteristic is removed prior to disposal, or when the waste is excluded from the
definition of waste or hazardous waste under rules 3745-51-02 to 3745-51-06 of the
Administrative Code, or exempted from
regulation under Chapters 3745-50 to 3745-69 of the Administrative Code, subsequent to
the point of generation.
(8) If a generator is managing a lab pack that contains wastes identified in appendix I to
rule 3745-59-42 of the Administrative Code and wishes to use the alternative treatment
standard under rule 3745-59-42 of the Administrative Code, with each shipment of waste
the generator shall submit a notice to the treatment facility in accordance with paragraph
(A)(1) of this rule. The generator shall also comply with the requirements in paragraphs
(A)(5) and (A)(6) of this rule, and shall submit the following certification, which must be
signed by an authorized representative:
"I certify under penalty of law that I personally have examined and am familiar with the
waste through analysis and testing or through knowledge of the waste and that the lab
pack contains only the wastes specified in appendix I to rule 3745-59-42 of the
Administrative Code or wastes not subject to regulation under Chapter 3745-51 of the
Administrative Code. I am aware that there are significant penalties for submitting a false
certification, including the possibility of fine or imprisonment."
(9) If a generator is managing a lab pack that contains wastes identified in appendix II to
rule 3745-59-42 of the Administrative Code and wishes to use the
alternative treatment standard under rule 3745-59-42 of the Administrative Code, with
each shipment of waste the generator shall submit a notice to the treatment facility in
accordance with paragraph (A)(1) of this rule. The generator shall also comply with the
requirements in paragraphs (A)(5) and (A)(6) of this rule, and shall submit the following
certification, which must be signed by an authorized representative:
"I certify under penalty of law that I personally have examined and am familiar with the
waste through analysis and testing or through knowledge of the waste and that the lab
pack contains only the wastes specified in appendix II to rule 3745-59-42 of the
Administrative Code or wastes not subject to regulation under Chapter 3745-51 of the
Administrative Code. I am aware that there are significant penalties for submitting a false
certification, including the possibility of fine or imprisonment."
(10) Small quantity generators with tolling agreements pursuant to paragraph (F) of rule
Appendix III - Page 79
3745-52-20 of the Administrative Code shall comply with the applicable notification and
certification requirements of paragraph (A) of this rule for the initial shipment of the waste
subject to the agreement. Such generators shall retain on-site a copy of the notification
and certification, together with the tolling agreement, for at least three years after
termination or expiration of the agreement. The three-year record retention period is
automatically extended during the course of any unresolved enforcement action regarding
the regulated activity or as requested by the director.
(B) Treatment facilities shall test their wastes according to the frequency specified in their
waste analysis plans as required by rule 3745-54-13 or 3745-65-13 of the Administrative
Code. Such testing shall be performed as provided in paragraphs (B)(1), (B)(2) and (B)(3)
of this rule.
(1) For wastes with treatment standards expressed as concentrations in the waste extract
(rule 3745-59-41 of the Administrative Code), the owner or operator of the treatment facility
shall test the treatment residues, or an extract of such residues developed using the test
method described in the appendix to rule 3745-51-24 of the Administrative Code, to assure
that the treatment residues or extract meet the applicable treatment standards.
(2) For wastes that are prohibited under rule 3745-59-32 of the Administrative Code or
section 3004(d) of RCRA but not subject to any treatment standards under rules
3745-59-40 to 3745-59-44 of the Administrative Code, the owner or operator of the
treatment facility shall test the treatment residues according to the generator testing
requirements specified in rule 3745-59-32 of the Administrative Code to assure that the
treatment residues comply with the applicable prohibitions.
(3) For wastes with treatment standards expressed as concentrations in the waste (rule
3745-59-43 of the Administrative Code), the owner or operator of the treatment facility
shall test the treatment residues (not an extract of such residues) to assure that the
treatment residues meet the applicable treatment standards.
(4) A notice shall be sent with each waste shipment to the land disposal facility which
includes the following information:
(a) U.S. EPA Hazardous Waste Number;
(b) The corresponding treatment standards for wastes F001 to F005, F039, and wastes
prohibited pursuant to rule 3745-59-32 of the Administrative Code or section 3004(d) of
RCRA. Treatment standards for all other restricted wastes must either be included, or be
referenced by including on the notification the applicable wastewater or nonwastewater
(both terms as defined in rule 3745-59-02 of the Administrative Code) category, the
applicable subdivisions made within a waste code based on waste-specific criteria (such
as D003 reactive cyanides), and the rules in the Administrative Code where the applicable
treatment standard appears. Where the applicable treatment standards are expressed as
Appendix III - Page 80
specified technologies in rule 3745-59-42 of the Administrative Code, the applicable
five-letter treatment code found in Table 1 of rule 3745-59-42 of the Administrative Code
(e.g., INCIN, WETOX) also must be included on the notification;
(c) The manifest number associated with the shipment of waste; and
(d) Waste analysis data, where available.
(5) The treatment facility shall submit a certification with each shipment of waste or
treatment residue of a restricted waste to the land disposal facility stating that the waste
or treatment residue has been treated in compliance with the applicable performance
standards specified in rules 3745-59-40 to 3745-59-44 of the Administrative Code and the
applicable prohibitions set forth in rule 3745-59-32 of the Administrative Code or section
3004(d) of RCRA.
(a) For wastes with treatment standards expressed as concentrations in the waste extract
or in the waste (rule 3745-59-41 or 3745-59-43 of the Administrative Code), or for wastes
prohibited under rule 3745-59-32 of the Administrative Code or section 3004(d) of RCRA
which are not subject to any treatment standards under rules 3745-59-40 to 3745-59-44
of the Administrative Code, the certification shall be signed by an authorized
representative and must state the following:
"I certify under penalty of law that I have personally examined and am familiar with the
treatment technology and operation of the treatment process used to support this
certification and that, based on my inquiry of those individuals immediately responsible for
obtaining this information. I believe that the treatment process has been operated and
maintained properly so as to comply with the performance levels specified in rules
3745-59-40 to 3745-59-44 of the Administrative Code, and all applicable prohibitions set
forth in rule 3745-59-32 of the Administrative Code or section 3004(d) of RCRA without
impermissible dilution of the prohibited waste. I am aware that there are significant
penalties for submitting a false certification, including the possibility of fine and
imprisonment."
(b) For wastes with treatment standards expressed as technologies (rule 3745-59-42 of
the Administrative Code), the certification shall be signed by an authorized representative
and shall state the following:
"I certify under penalty of law that the waste has been treated in accordance with the
requirements of rule 3745-59-42 of the Administrative Code. I am aware that there are
significant penalties for submitting a false certification, including the possibility of fine and
imprisonment."
(c) For wastes with treatment standards expressed as concentrations in the waste
pursuant to rule 3745-59-43 of the Administrative Code, if compliance with the treatment
Appendix III - Page 81
standards in rules 3745-59-40 to 3745-59-44 of the Administrative Code is based in part
or in whole on the analytical detection limit alternative specified in paragraph (C) of rule
3745-59-43 of the Administrative Code, the certification also must state the following:
"I certify under penalty of law that I have personally examined and am familiar with the
treatment technology and operation of the treatment process used to support this
certification and that, based on my inquiry of those individuals immediately responsible for
obtaining this information, I believe that the nonwastewater organic constituents have been
treated by incineration in units operated in accordance with rules 3745-57-40 to
3745-57-51 of the Administrative Code, or rules 3745-68-40 to 3745-68-52 of the
Administrative Code, or by combustion in fuel substitution units operating in accordance
with applicable technical requirements, and I have been unable to detect the
nonwastewater organic constituents despite having used best good faith efforts to analyze
for such constituents. I am aware that there are significant penalties for submitting a false
certification, including the possibility of fine and imprisonment."
(6) If the waste or treatment residue will be further managed at a different treatment or
storage facility, the treatment, storage or disposal facility sending the waste or treatment
residue off-site shall comply with the notice and certification requirements applicable to
generators under this rule.
(7) Where the wastes are recyclable materials used in a manner constituting disposal
subject to the provisions of paragraph (B) of rule 3745-58-30 of the
Administrative Code regarding treatment standards and prohibition levels, the owner or
operator of a treatment facility (i.e., the recycler) is not required to notify the receiving
facility, pursuant to paragraph (B)(4) of this rule. With each shipment of such wastes the
owner or operator of the recycling facility shall submit a certification described in
paragraph (B)(5) of this rule, and a notice which includes the information listed in
paragraph (B)(4) of this rule (except the manifest number) to the director. The recycling
facility also must keep records of the name and location of each entity receiving the
hazardous waste-derived product.
(C) Except where the owner or operator is disposing of any waste that is a recyclable
material used in a manner constituting disposal pursuant to paragraph (B) of rule
3745-58-30 of the Administrative Code, the owner or operator of any land disposal facility
disposing any waste subject to restrictions under Chapter 3745-59 of the Administrative
Code shall:
(1) Have copies of the notice and certifications specified in paragraph (A) or (B) of this
rule; and
(2) Test the waste, or an extract of the waste or treatment residue developed using the test
method described in the appendix to rule 3745-51-24 of the administrative Code or using
any methods required by generators under rule 3745-59-32 of the Administrative Code,
Appendix III - Page 82
to assure that the wastes or treatment residues are in compliance with the applicable
treatment standards set forth in rules 3745-59-40 to 3745-59-44 of the Administrative Code
and all applicable prohibitions set forth in rule 3745-59-32 of the Administrative Code or
section 3004(d) of RCRA. Such testing shall be performed according to the frequency
specified in the facility's waste analysis plan as required by rule 3745-54-13 or 3745-65-13
of the Administrative Code.
Effective: 9/2/97
Prior effective dates: 12/30/89, 2/11/92, 9/7/92
119.032 review date: 4/30/98
