A Model Waste Analysis Plan for Commercial BIF Facilities

David Gossman

President - Gossman Consulting, Inc.

Jim Woodford

Operations Consultant - Gossman Consulting, Inc.



Presented at the AWMA International Specialty Conference on Waste Combustion in Boilers and Industrial Furnaces April, 1997

ABSTRACT

EPA's guidance, to date, of Waste Analysis Plans has failed to provide specific recommendations for the special needs of commercial BIF facilities. EPA has instead focused primarily on traditional incinerator and landfill options for hazardous waste management. In order to fill this gap, a model waste analysis plan for commercial BIF facilities is developed along with the rationale for key features.

INTRODUCTION

In 1994, EPA issued its latest guidance on the preparation of Waste Analysis Plans (WAPs). As part of this guidance, EPA included example WAPs for a commercial landfill and commercial incinerator. In spite of the fact that there are more commercial BIFs than incinerators and completely disregarding public comment made on the draft guidance document, EPA chose to not provide an example WAP for commercial BIFs. This has further reinforced the mistaken notion that BIFs and incinerators can be treated as similar devices. In order to plug this knowledge gap and provide a ready reference, this paper provides a model WAP for a basic liquid hazardous waste fuel facility operated at a cement plant using hazardous waste fuels. It should be kept in mind that a wide variety of factors can influence the design of a WAP. These may include, but are not limited to, fuel substitution rate, worker exposure, facility design, types of waste acceptable/not accepted, state and federal regulations, etc. No single WAP will fit all circumstances.

MODEL WASTE ANALYSIS PLAN

Introduction

Due to the number of industries which generate wastes suitable for processing into hazardous waste fuel (HWF) candidate waste streams exhibit a range of chemical compounds and compositions.

There are two types of wastes which are managed at the facility:

  1. Combustible organic liquids and sludges received from waste generators in containers approved by the Department of Transportation (DOT).
  2. Combustible liquid organic wastes received in bulk tank trucks and railcars from HWF blenders and waste generators.

Waste Codes. The Part A application presents the list of waste codes which have been used by suppliers to identify waste streams designated for fuel use at the facility.

Excluded Waste Types. Candidate waste streams may be unsafe or unsuitable for processing or use as fuels and therefore will not be processed at the facility. PCBs (greater than 50 parts per million [ppm]), or wastes which might pose significant or unwarranted risk to the facility personnel, the cement-making process, or the environment will not be accepted for processing at the facility.

Containerized Waste. All container management areas will be provided with secondary containment so all wastes received in containers may be assumed to contain free liquids. Therefore, no testing is required to verify the presence or absence of free liquids.

Waste in Tank Systems. All wastes managed in the tank system are assumed to be ignitable and are managed accordingly. Some waste streams will exhibit the characteristic of TCLP Toxicity.

Waste Analysis Plan

Reliable information about the chemical and physical properties of the hazardous waste fuels will be derived from engineering knowledge of the waste generating process, from a generator questionnaire regarding the probable waste constituents, and from an analysis of at least three representative samples. These analyses are:

  1. Testing of a representative sample of the generator's waste to qualify it for use at the facility.
  2. Testing of a sample of each incoming waste shipment to verify its constituents.
  3. Testing of one or more samples taken during or after blending to verify the quality of the resultant HWF.

Parameters and Rationale. Table 1 presents a list of the chemical and physical parameters that may be analyzed. Also listed are the analytical methods which, in modified form, may be used to measure the waste characteristics. Table 2 provides an outline overview of which parameters will be determined at which point in the process.

Organic Composition-Health and Safety Concerns. Analysis for organic composition identifies waste streams containing unacceptable levels of extremely hazardous chemicals or compounds. Such waste streams can be excluded from operations if they require extraordinary handling procedures or extraordinary personnel protection. (This is definitely site specific.)

PCBs. Identifies the presence of PCBs, which will be prohibited at the facility in concentrations greater than the regulatory limit of 50 ppm.

Heating Value--Fuel Quality and Consistency. To be able to produce a consistent quality fuel, the heating value of the waste streams and individual shipments must be known. This information allows personnel to selectively mix shipments so that the final fuels have a reasonably consistent heating value for reliable combustion.

Metals--Cement Quality and Process Emissions. The metals content is important because of its possible impact on the quality of the cement product and its potential effect on air emissions.

Chlorine, Bromine and Fluorine. Due to the unique chemistry of the cement manufacturing process, there is an optimum level of halogens required for best overall operation and product quality. Inorganic chlorides have been traditionally used in some cement plants to remove excess sodium and potassium from the kiln system. These chlorides can now be replaced by the chlorine in the HWF.

pH-Identification of Incompatible and Reactive Waste. The tank system is constructed of mild steel and would be subject to corrosion from waste materials that exhibit a very high or very low pH. Corrosive wastes might also be reactive when mixed with the organic wastes commonly received at the facility. Corrosive wastes would normally be identified by the generator on the Application Form and would be manifested under the EPA Code of D002. Each waste stream and each waste shipment will be tested to determine its pH. Compatibility testing, done by mixing delivery vehicle samples with samples taken from blending tanks, can also be performed to ensure that the wastes can be mixed in the tank system without undesirable results.

Physical Properties--Material Handling. The physical properties of the waste streams are important in evaluating the waste material for handling or processing requirements. The viscosity, miscibility, consistency, and the general appearance of the incoming waste streams are assessed.

Other Parameters--Fuel Quality. Other parameters, such as ash, will be analyzed as required to verify fuel quality.

Test Methods

Table 1 lists the test methods that may be used to test for the parameters chosen.

Sampling Methods. As indicated by 40 CFR §261, Appendix I, sampling techniques are designed to provide randomly selected, representative samples from various sources of waste.

Core samples of liquids and sludges in tank trucks and railcars will be taken using a modified coliwasa(1). For solids, a tube is inserted into the material, and the sample is then pushed out into a sample container. Drums will be sampled in lots of ten or less with a representative sample from each drum being composited into one sample container. Portable containers will be sampled individually, and the samples will be composited with samples from other portable containers received from the same generator. At least 10% of the small containers (typically 6 gallons each) will be randomly selected for sampling and compositing.

Representative samples from the storage tanks are obtained from a sampling port on the side of the tank. Approximately one pint of HWF will be collected in an appropriate sample container while the tank is being agitated. A portion of this sample will be retained for record purposes in a capped bottle in an acceptable storage location for at least 60 days.

Sampling of coal and raw materials for analyses to comply with the BIF regulations is performed by taking grab samples from pre-ground and well mixed process streams just prior to them being fed into the kilns. Generally, daily samples will be composites of samples taken during the day. This sampling will be performed in accordance with SW-846 guidelines.

Frequency of Analyses

Analyses of waste from off-site include qualification, shipment, and final analyses.

Waste Profile. Each source of waste considered for processing into HWF is prequalified by asking the generator to complete a profile form. An example of the profile form is provided in Appendix 1. This form is updated periodically. The application requires the generator to advise ABC Corporation (ABC) of the raw materials which could become a part of the waste stream, as well as the process by which the waste is produced. The data submitted by the generator on this application is used to determine the candidate waste stream's suitability and the specific parameters necessary to characterize the waste stream. This application is part of the generator's permanent record kept at the facility.

Prequalification Sampling. The prequalification sampling at the generator site is conducted by a representative from ABC or by the generator. Generators must certify on the application form that samples are taken in a manner that provides a representative sample.

Qualification Analysis. The purpose of the qualification analysis is to assemble a detailed profile of the chemical and physical characteristics of the candidate waste stream. This profile determines whether the material can be processed into HWF, and if so, whether it can be handled safely and efficiently. The criteria for this decision include the key parameters in Table 1.

Based on the generator application form, however, analyses of additional parameters may be specified to adequately characterize a particular waste stream.

The qualification analysis may be repeated as necessary to ensure that information is accurate and up-to-date. At a minimum, the qualification analysis will be repeated when:

  1. There is reason to believe the process generating the waste has changed,
  2. The waste received does not match the anticipated contents of the shipment or the accompanying manifest, or
  3. The waste has not been received at the facility for at least a year.

In addition, an annual review of analysis data collected for the waste during the year will be conducted. This review will help to determine whether the process generating the waste has changed.

Shipment Analysis. Each waste shipment entering the facility is sampled and analyzed for the following parameters: ash, halogens, pH, heat content, PCBs, an organic fingerprint (See Table 2.) and selected metals as needed. This sampling and analysis is done to verify that the material received is acceptable and is consistent with the manifest description. The acceptable levels for all of the parameters, except heat content and PCBs, vary. Wastes containing different levels of the parameters are blended so that the final HWF is acceptable for use in making Portland cement. Table 3 contains the acceptable levels for heat content, halogens (bulk shipments only), and PCBs. Based on the information shown on the generator application form, the qualification analysis results, and the history of other shipment analyses, additional parameters may be specified by the ABC facility manager in charge to ensure that the waste can be managed properly.

A representative sample will be collected when each waste shipment is delivered to the facility. The sample is placed into an appropriate container and labeled with the generator's name, the sampler's initials and the date on which the sample is taken. A portion of the sample will be used immediately for the shipment analysis. The portion of the sample not used for chemical analysis will be kept in an acceptable storage location for at least 30 days.

Laboratory records of the results of the shipment analyses and of the quantities of materials inventoried will be maintained as part of the facility's Operating Record. These records will also be available for agency review and for use by the Emergency Coordinator when responding to an emergency. These records will be retained at the facility for at least three years.

Rejection Policy. ABC has a permit whereby HWF can be used as a fuel in the cement kilns. The terms of the permit require that only select materials meeting certain specifications can be delivered to the cement facility. The permit further requires that all incoming shipments be tested and analyzed to ensure that they are indeed acceptable materials. The purpose of this document is to set forth the policy and procedures that ABC will use for the acceptance or rejection of supplemental fuels delivered to the cement facility.

Authority. The ABC facility manager and/or his designated alternate has the responsibility of insuring that the quality assurance testing of each shipment of HWF has been performed and has the authority for acceptance or rejection of each shipment of HWF.

Safety. The transporter delivering supplemental fuels to the cement facility will abide by ABC's safety, insurance, and operational rules and regulations, and will use trucks equipped with safety items and other necessary equipment so the unloading of the materials may be accomplished safely. Inadequate or unsafe equipment is reason for rejection of any shipment.

Scheduling. All shipments of supplemental fuels must be scheduled with ABC in advance. A shipment arriving without the necessary pre-scheduling may be rejected or delayed.

Documentation. All shipments of waste materials will be accompanied with (a) a manifest that complies with state and federal hazardous waste regulations, and (b) any other documentation required for the transport of said materials to the cement facility. A shipment arriving without necessary documentation may be rejected. Exceptions to this case may exist if material handled is non-hazardous and specific provisions have been made in advance.

Analysis of Shipments. Only materials that have been prequalified will be scheduled for shipment as HWF. All incoming shipments will be analyzed before the materials will be accepted for delivery as supplemental fuels. Materials that are different from that represented in "The Waste Profile" may be rejected. Normally, the analytical screening procedures are accomplished in 40 to 50 minutes. However, if the results indicate that further analysis is required, acceptance or rejection may be delayed. The cost of transporter demurrage caused by this delay will be the responsibility of the broker and/or generator.

Notification. In the event that a shipment must be rejected, the on-site personnel will give notification to the following organizations:

Rejection. A rejected shipment in ABC's possession shall be prepared for lawful transportation and returned to the generator. The shipment shall be returned to the generator within a reasonable time, not to exceed five days, after notice of ABC's rejection has been communicated to generator. This shall be done unless within such time the parties agree to some alternative manner for the disposal of the rejected shipment. Generator shall pay ABC its reasonable expenses and charges for handling, loading, mixing, transporting, storing, and caring for rejected shipments. Generator shall also pay for all costs if an alternate disposal method is agreed upon and is accomplished through or by ABC.

Final Analysis. Final analysis is performed on representative samples of blended, HWF. This analysis is done on each burn tank. Blended specifications for liquid HWF are found in Table 4. These specifications for metals and chlorine may be adjusted based on an appropriate adjustment to the maximum burn rate. A portion of the sample will be retained for future reference in a capped bottle and placed in a storage cabinet designed for storing flammable materials. The samples will be retained for at least 30 days. At the end of the retention period, the sample containers are emptied into bulk storage, crushed and placed in plastic pails which are injected into the cement kiln using an air cannon.

Analysis of On-site Waste. Small quantities of process filter and strainer catch and facility clean-up materials may be accumulated temporarily and then introduced into the kiln. These materials are assumed to be ignitable and toxic because they are derived from the waste materials. Representative samples of these wastes will be analyzed for metals and chlorine for BIF compliance purposes.

In the event that these materials are to be sent off-site, however, they may need further characterization. Separately on-site generated waste oils and solvents will be blended in HWF only after being tested for PCBs.

Recordkeeping. A complete set of records will be maintained on-site for each shipment. Records will be maintained by sequential delivery in a calendar month. A complete set of lab results will be maintained by sequential load numbers which will cross reference to lab log books. A complete set of paperwork will include, but not be limited to, the following:

All waste analysis records will be kept as a part of the facility operating record and will be maintained as required by law.

Additional Requirements for Wastes Generated Off-site. Representative samples are taken from one hundred percent of all bulk shipments and from containers delivered to the facility in accordance with previously described procedures. Single, central-core samples are taken from each bulk shipment and analyzed individually. Core samples are obtained from each 55-gallon drum and composited into one analytical sample. No more than ten drums from the same generator and waste stream will be composited. Representative samples from larger volume containers are analyzed by composite. Smaller containers will have at least 10% of the containers sampled and composited.

Additional Requirements for Ignitable, Reactive or Incompatible Wastes. All wastes accepted at the facility are assumed to be ignitable and are managed accordingly. The application form and the chemical and physical analyses described earlier identify any reactive or incompatible wastes. Reactive and incompatible wastes are handled under limited conditions. If a load arrives which is incompatible with the fuels in the tank, one of three alternatives will be exercised. The first will involve holding the vehicle until other loads arrive which will be compatible with the fuels. Under this alternative a vessel will not be held for more than 24 hours. The second alternative is out right rejection of the load back to the generator or another facility that the generator elects to ship it to. The third alternative is to direct feed the shipment to the kiln. The specifications for receiving the incompatible load will be that the fuel meets the burn specification. Should one of the parameters for metals be above the burn specification, the feed rate would be reduced from normal energy replacement to a level that achieves the total input maximum in pounds per hour for the metal value that is out of specification.

BIF Compliance Analysis

Analyses of coal and raw materials for metals and chlorine are performed at a sufficient frequency to maintain compliance with BIF requirements. Methods that may be used have been previously identified in Table 1. Records of these analyses are maintained on-site along with calculations demonstrating compliance with the BIF feed rate limits.

Kiln Dust. A sample of kiln dust will be gathered each shift and composited into one daily sample. Monthly, a randomly selected sample of the composited kiln dust will be tested for organic compounds and TCLP metals. If none are found in the first year, then only annual samples will be taken thereafter.

Raw Materials. A sample of coal and raw mix will be gathered and tested for total metals once a month. Should the plant change raw materials or begin to utilize different non-hazardous raw materials, the samples of raw mix and/or fuel will be tested monthly during its use.

Quality Assurance/Quality Control

Quality Assurance Policy. It is the Quality Assurance Policy of ABC Corporation to provide laboratory data which is scientifically valid, defensible, and of known precision and accuracy. By implementation of this Quality Assurance Policy, ABC insures that it's laboratory data is adequate to support the associated business activities and objectives.

Quality Control Policy. ABC Corporation laboratories use standard Quality Control procedures as part of an overall Quality Control Assurance Program. These Quality Control procedures specify that the performance of the operations are to be challenged and evaluated using control samples with known characteristics and actual samples as received. Each ABC analytical procedure uses the following QC checks, where applicable:

  1. Calibration and Reagent Standardization - Each time an instrument is calibrated or a reagent is standardized, a record must be kept of the results. The data quality objectives specify the procedure and frequency required to maintain accuracy.
  1. Known Standards - If a method is not calibrated frequently, a known standard will be analyzed on a regular basis. One or the other must be done either daily or weekly depending upon the next scheduled calibration or known standard.
  1. Blanks - Where applicable, methods blanks will be run each analysis day and the results recorded.
  1. Duplicates - A duplicate sample will be run once a day.
  1. Blind Standards - Where available, a blind standard will be analyzed every three months. A blind standard will contain a known compound at concentration which is unknown to the analyst.
  1. Round Robin Testing - A quarterly program of sample and standard exchange will be used to compare results from individual laboratories. This program will include blind standards, reference standards, spiked samples, and real samples.

Quality Control Checks Summary. Quality Control Frequency varies from every sample, to weekly, monthly and quarterly depending on the parameter and method. To a large extent, these are very similar from method to method, as shown in a brief summary from some of the more frequently used methods. Table 5 is a listing of the quality control checks.

Data Quality Objectives. Data quality objectives (DQOs) are qualitative and quantitative statements which specify the quality of the data required to support decisions related to the various business ventures within the ABC. DQOs are determined based on the end use(s) of the data to be collected. They are established prior to data collection during the formulation of standard operation procedures and are not treated as a separate consideration. Rather, the DQO development process is integrated with the project planning process that functions within the quality assurance policy previously outlined, and the results are incorporated into the sampling and analysis plans and written standard operating procedures (SOP).

The DQO development process results in a well-thought-out sampling and analysis plan which details the chosen sampling and analysis options and statements of the confidence in decisions made using this data. Confidence statements are possible through the application of statistical techniques to the data.

DQOs are established to ensure that the data collected are sufficient and of adequate quality for their intended uses. Data collected and analyzed in conformance with the DQO process described below can be used in assessing the uncertainty associated with a given decision. The term "uncertainty" is used in a broad sense to describe the likelihood of all types of errors associated with a particular decision.

Data quality objectives at ABC are developed through a three-stage process:

1) Define the types of decisions that will be made using the data to be generated. For the laboratory that includes:

a. Whether a waste could be used as a fuel.

b. Whether the material is approved by ABC for handling.

c. Whether further analyses are required.

d. What is the proper manifest designation.

e. Whether any special handling will be required for reasons of safety.

2) Specify the data necessary to meet the objectives. This primarily involves the identification of the characteristics of the material or operations that are used to make the required decisions.

3) Specify the methods by which data will be obtained to make decisions. This stage involves selection of the sampling approaches and analytical options. Information on ABC sampling protocol is contained in a previous section of this WAP. The analytical methods are contained in Table 1.

Adhering to approved SOPs ensures sample integrity and data comparability and reduces sampling and analytical error. Typical issues impacting data quality include the following:

If limited or no information exists for a particular sample on sample collection, preservation techniques or holding times, the data is to be interpreted with caution.

The data requirements given in the various standard operating procedures and specifications approved by ABC management reflect all of the considerations discussed above.

Data Reporting. Since data are the only products of the laboratories, as much care is taken to maintain high quality standards in terms of reporting the data as in generating it in the first place. The variety of reports parallels the variety of samples analyzed and purposes for performing the testing. The following records are maintained and kept for three years.

1) Receiving Papers - Date, time, sample ID, customer name, stream ID, estimated volumes generated, sample receipt/delivery.

2) Worksheet - Raw results for each test (titers, instrument readings, sample weights, etc.), date, initials of analyst, and sample ID.

3) Instrument Use Logbook - Date, sample ID, type, initials, result, duplicates, blanks, maintenance, reports of corrective action, etc.

4) Calibration and Performance Sample Results - Initials, result, daily duplicates results for calibrations, duplicates, known standards, blanks, blind standards, and reference samples. All the QC results must be compiled and kept in one place, each set of results will be compared graphically with QC limits, records should show the basis for QC limits.

5) Instrument Maintenance and Repair Record - On every analytical system.

Corrective Actions. While the goal of the ABC QA/QC program is to provide sufficient training, equipment, facilities, technical support, and supervisory oversight to avoid inadequate measurements or data, it is recognized that data quality can fall outside our established limits for a variety of reasons. The program provides for reporting and review procedures that permit early and effective corrective action. specifically:

1) All samples are tracked by receiving documents to ensure that the necessary analyses are performed. Any sample which does not complete its required testing is flagged for the laboratory manager, who then makes a specific assignment to ensure that the data is obtained.

2) Data generated each day are entered onto report sheets and a data summary recorded in the logbooks for each sample. These sheets provide an opportunity for quick review of the data to see if the various results are internally consistent. Apparent discrepancies are brought to the attention of the laboratory manager.

3) Completed data sheets on all samples are reviewed prior to shipment receipt by the laboratory manager or his designate. This data is then filed for future reference.

If problems are found, several corrective actions are considered, depending on the apparent source. These include:

In all cases, a corrective action form is to be completed for incorporation into the appropriate file. An example is provided. This permits ready determination of systematic problems and provides for quick compilation of actions of various types taken over any given period of time.

Table 1. Analytical Parameters, Methods and Rationale.

Parameter Reference Method(s)1 Reason for Analysis
Organic Composition ASTM D2908, D3271, E260,

SW-846 8260, 8270

 Personnel exposure risk assessment

Identification of restricted wastes
PCBs ASTM D3534, D4059, D3304, E697, SW-846 3600, 8000, 8080, 8081 Restricted material
Heat Content (BTU/lb) ASTM D5468 Fuel quality control
Sulfur ASTM D5468, SW-846 9056 Fuel quality control
Ash ASTM D5468 Fuel quality control
Viscosity ASTM D4979 Fuel quality control
Metals: Ba, Ag, Sb, Cd, Pb, Be, Cr, As, Hg, Tl ASTM E926, D2332, D3327, D4326, SW-846 3040, 7130, 7190, 7240, 7420, 7950 Fuel quality control

Personnel exposure risk assessment

Boiler and Industrial Furnace regulatory requirement
Chlorine, Bromine, and Fluorine ASTM D5468, SW-846 9056 Fuel quality (process control)
Compatibility ASTM D5058 System and waste compatibility
Radioactivity ASTM D5928 Restricted Material
pH ASTM D4980,

SW-846 9045

 System and waste compatibility

1. One or more of the above as modified, amended, revised, updated, or replaced including equivalent or similar methods in accordance with the following quotations from the Federal Register, February 8, 1990, pages 4440-4445, EPA Proposed Rules - Preamble to SW-846 3rd edition.

"This notice, or the subsequent final rule, should not be construed to require the use of SW-846, Third Edition methods except where specifically prescribed by regulation."

"Except for those situations where the RCRA regulations specify use of a particular method, it is appropriate for the chemist to use judgment, tempered by experience, in selecting an appropriate set of methods from SW-846 or the scientific literature for preparing and analyzing a given sample."

"Implicit in the proceeding argument is the fact the SW-846 was designed largely for use in showing that a waste does not contain certain hazardous constituents or characteristics. In that regard, many SW-846 sample preparation methods are designed around trace analysis rather than the percent level determinations often required for concentrated wastes. These methods, however, might be suitable for percent level determination analysis when appropriately modified by the analyst."

"Sample preparation methods are not currently available in SW-846 to render non-aqueous liquids in a form that can be analyzed by the atomic absorption or inductively coupled plasma atomic emissions (ICP) type analytical methods for six important elements. These elements are: mercury, arsenic, selenium, lead, barium, and silver."

Table 2. ABC Corporation Waste Analysis Plan Outline.

Parameter Generator Qualification Shipment Receipt Blended Batch
Heat Content

X

X

X
Ash

X

X

X
Sulfur

X

X

X
Fluoride

X

X

X
Chloride

X

X

X
Bromide

X

X

X
pH (extracted)

X

X

X
Viscosity

X

X
Metals
(Depending upon Qualification)
Lead

X

X
Chromium

X

X
Arsenic

X

X
Cadmium

X

X
Antimony

X

X
Mercury

X

X
Thallium

X

X
PCBs

X

X
Volatile and Semi-Volatile Organics:

Analysis

X

X
Fingerprint*

X
Radioactivity

X

X

*Note: The fingerprint check can be a computerized overlay of the truck receipt gas chromatograph with the original generator qualification gas chromatograph. Only new gas chromatograph peaks then need to be identified.

Table 3. Shipment Analysis Parameters, Acceptable Levels.

Parameter Acceptable Levels
Heat Content Greater than or equal to 5,000 BTU/lb
PCBs Less than 50 ppm
Halogens Less than or equal to 30% (bulk shipments only)

Table 4. Liquid HWF Permit Specifications.

Parameter Specification
Heat Content 5,000 BTU/lb
Viscosity 300 cp
Chlorine and bromine 5.0% by wt.
Fluorine <5.0% by wt.
Sulfur 4.0% by wt.
pH (extracted) 4, 11
Metals*:

Lead

Chromium

Arsenic

Cadmium

Mercury

Thallium

Antimony



3000 ppm

3000 ppm

200 ppm

250 ppm

200 ppm

200 ppm

1000 ppm
PCBs < 50 ppm
Radioactivity No level above 2X background

Note: Routine monitoring of Be, Ba and Ag are not required because they do not occur in HWF at levels which could cause emission problems. If they did occur at non-typical levels, they are nonvolatile and would be retained in the process solids at a very high efficiency.

Table 5. Quality Control Checks.

Method Blind

Standard

 Round Robin

Testing

Blanks
1. Organic Composition quarterly quarterly daily
2. Sulfur none quarterly daily
3. Radioactivity none quarterly daily
4. pH none quarterly none
5. Viscosity none quarterly none
6. Ash none quarterly none
7. Heat Content none quarterly none
8. Halogens none quarterly daily
9. PCBs quarterly quarterly daily
10. Metals quarterly quarterly daily

Table 5. Quality Control Checks. (continued)

Method

Calibration		 Known

Standards

 Duplicates
1. Organic Composition yearly weekly daily
2. Sulfur daily weekly weekly
3. Radioactivity none weekly daily
4. pH daily daily weekly
5. Viscosity none weekly weekly
6. Ash none none weekly
7. Heat Content monthly weekly weekly
8. Halogens daily weekly weekly
9. PCBs weekly daily daily
10. Metals daily daily daily


Key Words

DQOs

guidance

Part A

recordkeeping

test methods

WAP

QA /QC Corrective Action Form

DATE:

COPIES TO:

DESCRIPTION OF PROBLEM AND WHEN IDENTIFIED:______________________________

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SUSPECTED OR KNOWN CAUSE:

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FOLLOW-UP (INCLUDES DATES AND RESPONSIBLE PERSON):

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Figure 1. QA/QC Corrective Action Form.

APPENDIX 1

ABC Sample No.

Sample Submitted:

ABC CORPORATION Fuel Waste for Recycling

MATERIAL SURVEY Other ______________

A Federal

Company Name: _______________________________________________ EPA ID No.: _________________________________ County: ____________

Billing Address: Manifest Address Facility Address: Manifest Address

Street: _______________________________________________________ Street: _________________________________________________________

City: ___________________________ State: _______ Zip: ____________ City: ______________________________ State: _______ Zip: ____________

Nature of Business: ________________________________________________________________________________ SIC No.: _____________________

State ID Numbers: State: _______ ID ____________________ State: ________ ID ____________________ State: ________ ID ____________________

B Material Description _________________________________________ D. Material Composition (vol%) Min Max Typical
Process Description ___________________________________________







Volume (gal) ___________________/ Wk Mth Qtr Yr Once



Volume on Hand (gal) ________________________



Storage Capacity (gal) ____________________ in Drums Bulk



Shipping Frequency (gal) __________________ in Drums Bulk








C Physical Description Color _____________



Layers One Two Three Water -


Physical State Liquid Semisolid Solid Non-volatile Material -


Liquid Viscosity Low Medium High Settled Solids -


E Attach material safety data sheets for components requiring employee communication under OSHA (ref. 29 CFR 1920.1200).

Attach any current analysis of the material. MSDS attached Analysis attached No attachments

F Check all of the following substances which may be in the material. Identify if present Amount Units
DOT Corrosives, Poisons, Forbiddens, Radioactives, Explosives, or Gases.


TSCA regulated materials (PCBs, PBB, Chlorinated dibenzodioxins or furans).


Materials used exclusively as pesticides, herbicides, insecticides, etc..


OSHA carcinogens above exclusive levels (Ref. 29 CFR 1910).


Toxic components with OSHA PEL or ACGIH TLV less than 2 ppm or 8 mg/m3.


Toxic metals (Antimony, Arsenic, Cadmium, Mercury, Selenium, Thallium).


Reactive components (Sulfides, Cyanides, Shock Sensitives, Pyrophorics, etc.).


Water reactive components (Isocyanates, Acid Chlorides, Anhydrides, etc.).


Biological hazards (Pathogenics, Infectious agents, Etiologic agents, etc.).


None of the above Special Handling Required _____________________________________________________________________________
G DOT Hazardous Material Description (Ref. 49 CFR 172.101)

Proper Shipping Name _______________________________________________

___________________________________________________________________

Hazard Class _____________________________ Number _________________

Not a DOT Hazardous Material

H EPA Hazardous Waste Description (Ref. 40 CFR 261)

Waste Number(s) D001 D002 F001 F002 F003

F004 F0051 __________ ______

Hazardous Code(s) I T C R E H

Not an EPA Hazardous Waste
I A sample and a fee is required for the qualification of all new material. Purchase Order No. ________________________________________

Type of sample: Grab Tank Composite of ______ drums Sample taken by Customer ABC Representative

J To the best of my knowledge, this is an accurate description and the sample submitted is representative of the material.

Name _______________________________________________________ Title ____________________________________________________

Signature _______________________________________________________ Date __________________ Phone (____) _____________________

Comments ___ ____________________________________________________________________________________________________________________



ABC Use Only

Broker _______________________ Salesperson _______________________ Territory # _______________________ Phone (____) _________________



ABC CORPORATION

_______________________________________________________________________

SALESPERSON TERRITORY SAMPLE NO.

_______________________________________________________________________

COMPANY TELEPHONE NO.

_______________________________________________________________________

ADDRESS

_______________________________________________________________________

DESCRIPTION OF SAMPLE

_______________________________________________________________________

SAMPLE COLLECTED BY DATE COLLECTED

_______________________________________________________________________

SAMPLE SUBMITTED BY

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SIGNATURE DATE SHIPPED











ABC CORPORATION

INSTRUCTIONS FOR WASTE PROFILE

This profile has been specifically designed to provide ABC Corp. with information necessary to transport, recycle, treat, and/or store your material in full compliance with state and federal regulations.

A separate profile is required for each material. A revised profile must be submitted; (1) whenever there is a change in the characteristics of the material or a change in process which might result in change in material characteristics; or, (2) there is a change in state or federal regulations which changes the regulated status of the material or any constituents. The profile must be submitted to the appropriate ABC laboratory along with a sample and approved through ABC's internal review process. No material can be received at any ABC facility unless specifically authorized by an approved profile and ABC Qualification.

A representative quart sample of the material must be submitted with each profile. Proper sampling methods may be found in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods", EPA publication SW-846. This sample must be packaged, labeled, and shipped in accordance with the provisions of 40 CFR 251.3(d)(2) and applicable US DOT and transporter regulations. The "pull-off" label provided above must be completed, signed, and attached to the sample container.

When the profile is completed, remove the customer copy and keep with instruction pages for your records. Return the original to the ABC laboratory below.

ABC CORPORATION

HWF Laboratory

123 South Any St.

P.O. Box 000

City, State zip

MAKE SURE THAT LABEL AND PROFILE ARE FILLED OUT CORRECTLY AND LABEL IS APPLIED TO SAMPLE CONTAINER. THE SAMPLE CONTAINER MUST BE CLEAN BEFORE APPLYING LABEL. MAKE SURE THAT THE SAMPLE AND PROFILE ARE SUBMITTED TOGETHER.

SEE FOLLOWING PAGES FOR IMPORTANT INSTRUCTIONS

FOR MORE INFORMATION, CALL A ABC REPRESENTATIVE

WASTE PROFILE SPECIAL INSTRUCTIONS

ANSWERS MUST BE PROVIDED FOR ALL QUESTIONS AND ITEMS ON THE ATTACHED FORM. Remove instruction pages and print (pen only) or type the answer (or check boxes) so that all pages are legible. If additional information is submitted to complete an answer, indicate on the form that there are attachments (see section E).

PART A - Customer Information

Company Name - Name exactly as used on all official documents and correspondence.

Billing Address - Address for all billing.

EPA I.D. No. - The unique 12-digit number for the facility or location where the material is generated. For spill situations, an Emergency Temporary Identification Number may be obtained through regional offices of the U.S. EPA. Questions should be directed to the RCRA Industry Assistance Hotline at 800-424-9346.

County - County where facility is located.

Facility Address - Street address of the facility where material is generated. No Post Office Boxes please.

Nature of Business - General description of business of company.

S.I.C. Number - Four-digit number that identifies nature of business, if known.

State I.D. No - Number(s) for any facility shipping material to ABC Corp. from any state requiring separate I.D. numbers.

Manifest Address - Mark the address (Billing or Facility) which will be used as the address on any manifest. Check one box only.

PART B - Material Information

Material Description - Trade name, generic name, or common name of material. The description generally identifies the nature of the material.

Process Description - A brief generic description of process generating material, i.e. vapor degreasing of motors, etc. Description should be sufficiently complete to allow comparison with EPA process descriptions in 40 CFR 261.31 and 32.

Volume - Amount of material in gallons generated per period. Check one box only.

Volume on Hand - Gallons of material currently at facility.

Storage Capacity - The gallons of material that can be stored at facility, to assist in scheduling shipments.

Frequency - Description of frequency (weekly, monthly, etc.) which is desired for shipments.

PART C - Physical Description

Color - Description of material color.

Layers - Number of layers or phases for typical material.

Physical State - The state at room temperature. If the material changes with reduced ambient temperatures, indicate change in Comments.

Liquid Viscosity - Thickness at room temperature.

Low - Thin or watery consistency.

Medium - Consistency of motor oil

High - Like honey or thicker.

PART D - Material Composition

The primary material components, preferably chemical names. Indicate the minimum, maximum, and typical concentration of each component. Be sure to include any water, non-volatile material (such as dissolved solids, resins, oils, etc.) and settled solids. Material Safety Data Sheets from suppliers may help provide this information.

PART E - Additional Information (MSDS and Analysis)

Material Safety Data Sheets are required for all material components which require employee hazard communication under 29 CFR 1910.1200 (OSHA Right-To-Know). MSDS are not required for any materials which ABC already handles routinely. If a recent analysis is available, please attach to profile. Check at least one box.

ABC routinely handles most common industrial solvents and mixtures, such as the following examples:

Acetone Methyl Ethyl Ketone

Aliphatic Hydrocarbons Methyl Isobutyl Ketone

Amyl Acetates Methylene Chloride

Butyl Acetates Methylpyrrolidone, N-

Butyl Alcohols Mineral Spirits

Chlorotoluenes Monochlorobenzene

Dichlorobenzenes Naphtha

Dioxane, 1, 4- Perchloroethylene

Ethyl Acetate Propyl Acetate, N-

Ethyl Alcohol Propyl Alcohol, N-

Ethylene Glycol Propylene Glycol Ethers

Freon TF Styrene

Hexanes and Heptanes Tetrahydrofuran

Isopropyl Acetate Toluene

Isopropyl Alcohol Trichloroethane, 1, 1, 1,-

Methyl Acetate Trichloroethylene

Methyl Alcohol Xylenes and Ethylbenzane

PART F - Restricted, Prohibited, or Special Substances

These substances may represent special hazards under certain circumstances, even to personnel opening samples in the lab. Identify any potential presence of these substances in the material. Review MSDS and shipping documents to obtain this information. Generally, companies handling these types of substances are already aware of the special handling required. Be certain to check "None of the above" if none of these substances are present. Check at least one box.

THE FOLLOWING LISTS ARE ONLY EXAMPLES AND DO NOT INCLUDE ALL RESTRICTED, PROHIBITED, OR SPECIAL SUBSTANCES.

DOT Special Hazards - Based on their Department of Transportation classification, these materials may present special hazards:

Restricted, Prohibited or Special Substances (continued)

Dot Corrosives - Materials which are corrosive to skin or metal, such as the following examples:

AceticAcid Amines

Chloroacetic Acid Caustics

Cresols Caustic Soda

Formic Acid Dimethylamine

Hydrochloric Acid Monoethanolamine

Phenol Soda Ash

Sulfuric Acid Sodium Hydroxide

WASTE PROFILE SPECIAL INSTRUCTIONS (continued)

DOT Poisons - Highly toxic substances, such as the following examples:

Acetone Cyanohydrin Methyl Chloroformate

Acrolein Methyl Isocyanate

Allyl Alcohol Nicotine

Aniline Nitroanilene

Chloropicrin Nitrobenzene

Ethyl Chloroformate Nitrochlorobenzene

EthyleneChlorohydrin Phenol

Hydrazines Phosgene

Methyl Bromide Tetraethyl Lead

DOT Forbiddens - Materials forbidden for transport.

DOT Radioactives, Explosives, Gases - Components which are assigned these DOT hazard classes.

TSCA - Materials whose disposal is regulated under the Toxic Substances Control Act, such as chlorinated biphenyls (PCB), brominated biphenyls (BB), chlorinated dibenzodioxins, chlorinated dibenzofurans.

Pesticides - Compounds used exclusively to destroy or inhibit plant or animal pests, including pesticides, insecticides, herbicides, rodenticides, miticides, etc. These materials are registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

OSHA Carcinogens - Known human carcinogens as designed by the Occupational Health and Safety Administration in 29 CFR 1910. The majority of these compounds are no longer manufactured or used in the United States. Companies which handle these compounds are generally required to post "CANCER HAZARD" signs.

OSHA Carcinogen ExclusionLevel

Acetylaminofluorene, 2- 1.0%

Acrylonitrile NA

Aminodiphenyl, 4- 0.1%

Arsenic, Inorganic NA

Benzidine 0.1%

Chloromethyl Ether, bis- 0.1%

Debromo-3-chloropropane, 1, 2 NA

Dichlorbenzidine, 3, 3- 1.0%

Dimethylaminoazobenzene, 4- 1.0%

Ehtyleneimine 1.0%

Ethylene Oxide NA

Methyl Chloromethyl Ether 0.1%

Methylenebis(2-Chloroaniline), 4, 4- 1.0%

Naphthylamine, 1- 1.0%

Naphthylamine, 2 -0.1%

Nitrobiphenyl, 4- 0.1%

Nitrosodimethylamine, N- 1.0%

Propiolactone, beta 1.0%

Vinyl Chloride Monomer NA

Toxic Components - Substances that have extremely low exposure limits. This limit is assigned by OSHA as permissible Exposure Level

(PEL) or by American conference of Governmental and Industrial Hygienists (ACGIH) as Threshold Limit Value (TLV). Common substances having an OSHA PEL or ACGIH TLV less than 2 ppm or 8 mg/m3 are listed below.

Acrolein Ethylene Glycol Dinitrate

Allyl Chloride Formaldehyde

Allyl Alcohol Hexachlorocyclopentadiene

Anisidine Hexachloronaphthalene

Benzoquinone Isocyanates

Bromoform Mercaptans

Diazomethane MethylIsocyanate

Dichloropropene Methylene Dianiline, 4, 4-

Dimethylsulfate Pentochlorophenol

Dinitrotoluene Propylene Glycol Dinitrate

Ethylene Dibromide Toluene Diisocyante

Toxic Metals - Trace metals which are both highly toxic and volatile under certain conditions, such as Antimony, Arsenic, Cadmium, Mercury, Selenium or Thallium.

Reactive Components - Materials which may decompose or react adversely with other common compounds such as:

Sulfides and Cyanides - These inorganic compounds can release toxic gases (H2S and HCN) when mixed with acidic materials.

Shock Sensitives - Materials that can be detonated by mechanical impact.

Pyrophorics - Compounds that ignite spontaneously in or at temperatures up to 130oF.

Oxidizing Agents - Substances which can oxidize organic compounds, generating other compounds and heat.

Peroxides - These compounds can be very unstable in concentrated form and can rapidly decompose, generating explosions and heat.

Water Reactive Components - Any materials that react with water to give off heat, fumes, or gases, such as:

Isocyanates - These compounds react with water to generate heat and carbon dioxide. Unreacted polymeric isocyanates will also react with water in the presence of common amine catalysts.

Acid Chlorides and Anhydrides - These materials react with water to generate heat and produce acids.

Biological Hazards - Materials which are special hazards to humans, such as pathogenics, infectious agents, etiological agents, drugs, or antibiotics.

None of the above - Check this box if the material does not contain any of the above substances.

Special Handling Required - Special procedures required to safely handle the material.



WASTE PROFILE SPECIAL INSTRUCTIONS (continued)

PART G - DOT Hazardous Material Description

This description must match the one which will be used on the shipping papers. Department of Transportation (DOT) regulations are contained in 49 CFR. Common waste descriptions are shown below:

Proper Shipping Name Hazard Class Number

Waste Flammable Liquid, NOS Flammable Liquid UN1993

Waste Paint Related Material Flammable Liquid NA1263

Waste Combustible Liquid, NOS Combustible Liquid NA1993

Waste Petroleum Naphtha Combustible Liquid UN1255

Waste Methylene Chloride ORM-A UN1593

Waste, 1,1,1-Trichloroethane ORM-A UN2831

Waste Trichloroethylene ORM-A UN1710

RQ Waste Perchloroethylene ORM-A UN1897

Hazardous Waste Liquid, NOS ORM-E NA9189

NOTE: Do not use the word "waste" in the DOT proper shipping name for any samples.

Current DOT regulations may require additional information as part of the description. These additions may be required for substances designated as "Hazardous Substances" under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). If the material contains a "Hazardous Substance" at greater that the "Reportable Quantity" in a single container, then "RQ" must be added to the Proper Shipping Name. In addition, if the Hazardous Substance" name is not part of the Proper Shipping Name, then either the chemical name or the EPA waste number, in parentheses, must be added to the end of the DOT description. This is only a summary of the regulations. For more detailed information, contact the Department of Transportation.

PART H - EPA Hazardous Waste Description

If the material is an EPA Hazardous Waste, indicate the number(s) and code(s) for the waste. Environmental Protection Agency (EPA) regulations are contained in 40 CFR. The information must match the information which will be on the manifest. Common descriptions are shown below:

Waste Hazard

Number Code Hazard

D001 I Ignitable

D002 C Corrosive

F001 T Toxic

F002 T Toxic

F003 I Ignitable

F004 T Toxic

F005 I,T Ignitable and Toxic

PART I - Sample and Qualification Information

Please provide a purchase order number for the material qualification. Also, provide information about the type of sample submitted for qualification. EPA SW-846 guidelines require that liquid samples be "core" samples taken with a "COLIWASA" or similar sampler. Other options may include sampling from an agitated tank or grab samples directly from the process.

PART J - Customer Certification

This certification must be performed by an authorized employee of the company identified in PART A. If the signee is not an employee of the generator, then provide a statement showing authorization. Be certain to complete all sections.

1. . The modification consists of a ball valve closing device with an extended handle which reaches the bottom of the tank. When collecting a sample, the handle will be pushed to the closed position, sealing the sampled material in a one-half inch pipe. The advantage of this sampler is that it will provide a more positive seal and will be more durable than the standard, specified unit. However, the difference in the sealing process does not change the basic nature of the sampling mechanism.