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Gossman Consulting, Inc

HWF NOTES©


Gossman Consulting, Inc.                             July, 1994


COMMENTS ON THE NEW EPA WASTE ANALYSIS PLAN GUIDANCE MANUAL

David Gossman

Gossman Consulting, Inc. provided detailed comments in July 1993 on the draft of this guidance manual in our July 1993 issue of HWF Notes. These comments were also provided directly to the EPA contractor working on the project. The final guidance was made available by EPA in May, 1994. This month's HWF Notes focuses on a review of which of our original comments were adopted and which were not. Additional major changes are also reviewed.

GCI July 1993 Comment Results
A more clear differentiation between waste analysis performed to determine regulatory status versus that used to manage a waste would be helpful. No discernable change. Differentiation still is unclear.
The document needs to identify and address one of the most crucial reasons for a commercial TSD WAP-protection of worker health and safety. Since OSHA saw fit to exempt hazardous waste from worker right-to-know, it is imperative that EPA take the lead in ensuring that enough information is gathered on each waste stream to allow it to be safely handled. We see no way to do this but to take all reasonable steps necessary to identify the broad base of hazardous constituents in a waste above a reasonable threshold concentration (perhaps 0.1-1.0%). Minor comments and changes can be found in Table 2-5.
Page 2-5; The facility description guidance in Section 2.1 exceeds the waste analysis plan requirements found in 40CFR 264.13, 265.13, and/or 268.7. Meticulous reading and re-reading of these parts do not reveal even a brief mention of a facility description. See Appendix D of the WAP guidance document. This is a separate section of the Part B application. There is no clear need for it to be part of the WAP. No substantive change. Guidance still calls for facility description.
Table 2-5; The table does not include parameters needed to protect human health and safety such as the identification of hazardous volatile and semivolatile organic constituents in organic waste streams.

Table 2-5; The table does not include testing for generally prohibited materials such as PCBs or radioactives.

"Appropriate hazardous constituents" added without specific reference to PCBs or radioactives.
Page 2-16; Particulate requirements found in Table 2.5 for Boilers and Industrial Furnaces (BIF) has been mislabeled under media type. It should be St for stack gases rather than L, Sl, or So. In the event that this media labeling is intentional, this has little use at commercial facilities since viscosity is the overriding concern. In addition, although heat content (not BTU value) is a concern BIFs are allowed to burn < 5,000 BTU/lb (not BTU/hr) materials. Appropriate changes were made.
Page 2-16; Ash content is applicable to non-cement kiln BIFs only. No change made.
Page 2-17; Reference to applicable ASTM standards on waste compatibility testing should be provided. Reference not added.
Page 2-19 through 2-37; This part of Section 2.3 was written for waste clean-up operations and "field" work, not a TSD or waste generator. The operational requirements of an on site lab performing the same analyses on the same matrices day after day is significantly different than that regarded "field work". This section needs a complete re-write. In a particularly disturbing response to our comments references to "field" were removed without making any substantive changes. The sampling guidance still has little if any real meaning with respect to TSDFs.
Section 2.4.2; It should be specifically pointed out in this section the SW-846 was not written with many sample matrices or procedures for management and treatment in mind. It was written primarily for trace analysis and hazard designation. See the preamble to the third edition SW-846 published in the federal register. Figure 2-9 is erroneous since many of the procedures indicated cannot be reliably used on streams which are primarily an organic matrix. No changes were made.
Page 2-52; Initials for Chemical Waste Management (CWM) appear in the Waste Profile Sheet Accountability Statement. Hopefully, this was inadvertent rather than deliberate. Also, will inspectors now look for each piece of information that is found in the Waste Profile Sheet example found in Table 2-11? Utilizing a specific company's form rather than something truly generic in this document could have legal implications even if all references have been removed. Initials were removed; no other changes.
Page 2-43; In the first paragraph, there is an implication that SW-846 is required unless equivalence is proven for all WAP determinations. This is not true. Only determinations used to show whether a waste is or is not hazardous require an equivalence determination. See the preamble to the third edition SW-846. Appropriate changes were made.
Page 2-44; In the fourth paragraph, the implication that shipment by shipment analyses cannot be performed is erroneous. many facilities perform remarkably complete analyses on every shipment received and do so in less than one hour. Appropriate changes were made.
Page 2-45; For the sake of regulatory clarity "if applicable" should be added after Part 268 - Treatment Standards. Appropriate changes were made.
Page 2-46; There is an implication here that screening procedures are available for dioxins. Either identify such procedures, detection limits, and applicable matrices; or remove this reference. Appropriate changes were made.
Page 2-51; The symbol for potassium is "K" not "P". Appropriate changes were made.
Page 3-1; Section 1 of the Part Three: Checklist is not applicable in a Waste Analysis Plan as pointed out in the page 2-5 comments. No change made.
Page 3-3; 40CFR 264.13, 265.13 and 268.7 all refer to special procedure requirements "where applicable". It would seem prudent to add this phrase, perhaps in parenthesis, beside the Section 6 title of Part Three: Checklist, Special Procedural Requirements. Change made.
Page 4-5; While the use of the fictitious landfill name of Rottaway may have been intended to be humorous, it implies disrespect for a legal and viable disposal option. It is also generally unprofessional in nature. Is the WAP guidance document intended to be humorous? No change made.
Pages 4-7, 4-23, 4-31, 4-43, and 4-64; the five sample waste analysis plans presented in this part all include sections on a facility description. As pointed out in comments provided on page 2-5 and 3-1, facility descriptions are not applicable in a waste analysis plan. In addition, none of them are examples for a commercial BIF, which incidentally handle more wastes than commercial incinerators. No change made.
Page 4-46; TCLP metals is irrelevant for an incinerator. Total metals (for metals of real concern) should be determined on each batch of waste incinerated prior to incineration to insure that metal feed-rate limits are not exceeded. Appropriate changes made.
Page 4-46; Most incinerators and BIFs handle all waste as flammable, therefore flammability and flashpoint are irrelevant parameters. Appropriate changes made.
Page 4-46; A broad based identification of volatile and semivolatile constituents is technically feasible and should be included to protect worker health and safety. No change made.
Page 4-46; The suggestion that odor will be used as a screening technique is archaic and in direct conflict with good health and safety practices. Appropriate changes made.
Page 4-46; Heat content, not BTU value, is the appropriate parameter. Appropriate changes made
Page 4-46; Ash is a typical "fingerprint parameter". Appropriate changes made.
The guidance for incinerators (and BIFs) seems, in general, to confuse a WAP with a Trial Burn Plan. The two are separate and distinct. A more clear separation of relevant issues throughout the document would be useful. Appropriate changes made.
Page 4-56; Page 4-46 indicates PCB determinations are required for every shipment, yet there is no mention of dioxins. Now (pg. 4-56) both are to be checked randomly. This is inconsistent. If dioxins are to be included, a method should be provided. (We are aware of no direct method for high organic content streams.) No change made.
Page 4-60; It should read "1,000 BTU/lb minimum", not "1,000 BTU minimum". Appropriate changes made.
Page 4-60; The suggestion that .01 ppm PCBs can reliably be determined during a "fingerprint" analysis on organic wastes reflects complete unfamiliarity with analytical techniques. Try 50 ppm, the TSCA lower limit for contamination determination. Appropriate changes made.
It is not clear if those parameters apply to incoming waste or outgoing waste. LDR values suggest outgoing. PCBs and heat of combustion suggest incoming. This requires significant clarification. Not Clarified.
Page 4-63; This is part of a Trial Burn Plan, not a WAP. Change made.


Additional Major Changes

Page 2-34; Table 2-9 has had a worthwhile footnote added pointing out that highly concentrated samples generally do not require preservation. A further note that the same is generally true for holding times would have also been warranted.

Page 2-48; A provision requiring off-site combustion facilities to analyze each batch of waste burned for all BIF metals plus nickel, selenium, vanadium, and zinc has been added. No rationale, regulatory or otherwise, is provided. There is no discussion regarding those regulatory situations that do not require all metals to be determined. On-site facilities are provided the option of a lower analysis frequency based on statistics. A clear distinction is made between on-site versus off-site facilities in this regard despite the lack of any differenciation in the regulations.