Each waste # listed below will be identified with a reference code representing the appropriate method of management. The Management Codes and corresponding certification statements, if applicable, are as follows:
A Restricted Waste Requires Treatment:This waste must be treated to the applicable treatment standards set forth in 40 CFR Part 268, Subpart D, 268.32 or RCRA Section 3004(d).
B Restricted Waste Can Be Land Disposed Without Further Treatment: 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 40 CFR 268, Subpart D. 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.
C Restricted Waste Treated to Performance Standards: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. 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 treatment standards specified in 40 CFR Part 268.40 without impermissible dilution of the prohibited waste. I am aware there are significant penalties for submitting a false certification, including the possibility of fine and imprisonment.
D Waste Which is Subject to an Exemption from the Land Disposal Restrictions such as, but not limited to a Case-by-Case Extension under 268.5, an Exemption under 268.6, or a National Capacity Variance under Sub-Part C of 40 CFR Part 268: I certify that this waste is not prohibited from land disposal.
Date the waste is subject to the prohibition: EThis hazardous debris is subject to the alternative treatment standards of 40 cfr 268.45. F Contaminated Soil Requiring Treatment (Circle each correct portion of the statement): I certify under penalty of law that I personally have examined this contaminated soil and it does contain listed hazardous waste and does exhibit a characteristic of hazardous waste but does not require additional treatment to meet the soil treatment standards as provided by 268.49(c).
Subcategory, if applicable
Date of characterization analysis(attach most recent copy with the first load)
The waste described above complies with treatment standards as defined in 40 CFR 268, Subpart D. 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 40 CFR 268, Subpart D. 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.
Name: ___________________________________ Date:_____________________________
SAMPLING INSTRUCTIONS SAMPLE CONTAINERS FOR INORGANIC AND MISCELLANEOUS ANALYSIS
Grease & Oils Phenols TOX TOC General Metals Cyanides & COD, TKN & General
(32 oz. clear (32 oz. Glass (8 oz. Glass (40 ml Glass (1/2 gallon (16 oz. Sulfides NH3 (1 quart Plastic)
Glass Flint) Amber) Amber) vial - Amber) Plastic) Plastic) (32 oz. Plastic) (16 oz. Plastic)
A - Preserved with Nitric Acid; B - Preserved with Sulfuric Acid; C - Preserved with Sodium Hydroxide; N - No preservatives required
Fill all containers to minimize the airspace in the container. Fill the 8 oz. amber for TOX and 40 ml vial for TOC so that there is no airspace by using the same procedure specified below for filling a 40 ml glass VOA vial. Immediately after collection of the samples, place them in a cooler with ice packs to cool the samples to 4 degrees Celsius (40 degrees Fahrenheit).
(40 ml Glass VOA vial) (1/2 gallon Glass (16 oz. Clear Glass (4 oz. Clear Glass)
Preserved with Hydrochloric Acid (Amber) Widemouth) Filled to capacity
Proper sample collection is essential for valid analytical results. Samples collected for volatile organics analysis must be grab samples and immediately following collection of samples, containers must be cooled in a refrigerator or with ice packs. VOA vials must be filled to capacity to have no airspace. This is done by forming a meniscus at top of the vial (see example above). Place the lid over the vial carefully and screw it on gently. Turn the vial upside-down and carefully tap the container against your hand to be sure that no air bubbles are present. Samples may generate bubbles due to the acid preservative. Micro bubbles, i.e. “champaign” sized, do not adversely affect analysis. Soil/solid VOA jars should also be packed tightly.
Questions have arisen as to why we require so much sample for waste characterization. Typically, we request 2 general bottles, a 16 oz. wide mouth quart jar, and a 4 oz. soil volatile jar for a sample. Normally, the bottles hold from 2 to 6 pounds of sample (900 to 2700g), depending on the sample density and particle size. Certain light-weight materials yield even lower sample weights.
Following is a list of sample masses needed for the permit package analysis we do most frequently:
Total Cyanide 10g
Total Phenols 10g
Reactive Cyanide 10g
Total Sulfide 10g
Amenable Cyanide 10g
Reactive Sulfide 10g
Total Solids 10g
Flashpoint, Closed Cup 100g
Metals/BNA Extraction 105g
Paint Filter 50g
Metals/BNA w/Pests&Herbs 205g
ZHE Extraction 24g
Total w/Pests&Herbs 460g
Treatability Studies: Additional 300 g per study (we sometimes must perform 2 or 3 studies).
F-Listed Volatiles 5g
Total Pests/PCBs 31g
Total BNAs 31g
Total Herbs 31g
This is the absolute minimum volume we need to do the above analyses one time. There is always the possibility of a QC failure, surrogates may be out, or we may have to re-analyze for another reason. We also need additional sample for routine quality control such as duplicates. If the waste stream is of a light-weight nature, more sample is definitely required.
WARNING: Gloves must be worn at all times while sampling. Containers with colored labels contain chemical preservatives and contact with skin must be avoided. Should skin contact occur, wash the affected area immediately with clean water and treat as a burn. Contact your physician if irritation persists. The different containers and preservatives are needed to maintain the integrity of the sample prior to analysis. Please contact your Technical Support Representative or PDC Laboratories, Inc. if your sample cannot be consistently split into the standard containers provided.
When characterizing a wastestream, it is important that a representative sample be collected and analyzed. EPA defines a representative sample as “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” (40 CFR 260.10). Only knowledge of the waste generating process and/or site-specific conditions can determine whether a grab or composite sample bestrepresents a wastestream, but either is permissible for characterization purposes. Please note that the 4 oz. clear glass VOA vial must always be a grab, even if the balance of your characterization sample is a composite.
When collecting samples to demonstrate compliance with land disposal restriction (LDR) standards, EPA requires that grab samples be analyzed. LDR analysis must be performed for those constituents directly regulated with treatment standards under a waste code, and for underlying hazardous constituents, when applicable.
Some waste types require pre-acceptance analysis for both characterization and LDR compliance. For example, F006 and F019 wastes require a representative sample for characterization and a grab sample for LDR (cyanide) analysis. Similarly, if the presence of any underlying hazardous constituents is indicated for characteristically hazardous wastes, a grab sample must be analyzed for those constituents indicated. Your PDC Technical Support Representative can assist you in determining the appropriate sample types for your wastestream.
Sample Hold Times
In order to provide quality data for our clients, PDC Laboratories, Inc. makes every effort to perform all analyses within the published holding time. However, we do experience some difficulty with the following parameters due to their relatively short holding times:
Solids(Total, Volatile, Dissolved and Suspended), Sulfides (Total & Reactive)
The maximum hold times appearing in the above table are established by EPA-required test methodology. EPA does not consider valid any data derived from samples that exceed these hold times, which are calculated from the time of sample collection. Therefore, it is imperative that your samples be shipped at the earliest possible time after they are collected, using a method of shipment that minimizes the time lost in transit. In order to avoid the inconvenience of hold time exceedances and re-sampling, PDC recommends the following:
Issue a Purchase Order number to your PDC Representative or ensure it is entered on the Chain of Custody Record form. The laboratory will not initiate any work without this form of authorization.
Review carefully the sampling information presented above.
Fill ALL of the bottles/jars COMPLETELY.
Collect your sample(s) on a Monday and ship the same day. This eliminates the potential for a two-day weekend time lapse. Also, do not ship on the day prior to a major holiday.
Ship your sample(s) via a courier and service option that guarantees overnight, second day, or, at most, third day delivery (e.g., UPS 3 Day Select).
If you are working under time or logistical constraints that prevent you from following these recommendations, in some situations indicating “Rush” above the signature block on the Chain-of-Custody Record form may still permit the analysis to be completed within the applicable hold times. Please first confirm this with your PDC Technical Support Representative as there is an additional fee associated with analytical work completed on a rush basis.
We realize that the EPA sampling protocol and maximum hold times discussed above can be both confusing and challenging. Presenting the above guidance and recommendations is not intended to make this even more confusing, but rather to help ensure we provide you with prompt, EPA-compliant service the first time!
If you have any questions or comments regarding sample collection, completing a Chain of Custody, analysis, or any portion of this Wastestream Approval Package, we will gladly provide any necessary assistance. Simply contact your Technical Support Representative at (309) 688-0760. Please know that we highly value your business and trust, and remain committed to providing you environmental services of the highest quality.