Eastman Business Park - Hazardous Waste Management Facility … · attachment a - application...

ATTACHMENT A - APPLICATION

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

TABLE OF CONTENTS

EPA Application Form- 8700-23 Appendix A-1 - HWMU Photographs Table A-1 - Environmental Permits for Kodak Operations at Eastman Business Park

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APPENDIX A-1 LIST OF HWMU PHOTOGRAPHS

EASTMAN KODAK COMPANY

EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY

EPA ID NUMBER NYD 980592497

Photo# Unit# Building# Process Codes

1 HWMU-32 B-95 T03, Waste Sludge Incineration – APCE

2 HWMU-32 B-95 T03, Waste Sludge Incineration – MHI

3 HWMU-33 B-322 S02, Storage Tank T-675

4 HWMU-33 B-322 S02, Storage Tank T-682

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ATTACHMENT A - TABLE A-1

ENVIRONMENTAL PERMITS FOR KODAK OPERATIONS AT EASTMAN BUSINESS PARK

EASTMAN KODAK COMPANY EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

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December 13, 2013

Table A-1 EPA ID No. NYD 980592497 Eastman Business Park, Eastman Kodak Company and RED-Rochester, LLC

Hazardous Waste Permit Application Part A

A. Permit

Type / Number B. Application Type / Number

C. Description

N NY0001643 SPDES Permit – Eastman Business Park (Kodak and RED)

E 158 County of Monroe Sewer Use Permit (Kodak)

R 8-2614-00205/00104 6 NYCRR Part 373 Permit for Eastman Business Park (Kodak and RED)

E 08-1580 6 NYCRR Part 610 Major Petroleum Facility License (RED)

8-601656 Petroleum Bulk Storage Registration (Kodak)

P 8-2614-00205/01801 Title V Operating Permit for Kodak Operations at the Eastman Business Park Facility – permit issued to Eastman Kodak Company

P 8-2699-00126/00001 Title V Operating Permit for the Eastman Business Park Boilers – permit issued to RED

E 8-000107 6 NYCRR Part 596 Hazardous Substance Bulk Storage Registration (Kodak)

8-000490 6 NYCRR Part 596 Hazardous Substance Bulk Storage Registration (RED)

E 1347-0255 NYS Department of Health Radioactive Material License (Kodak)

E C5607 NYS Department of Health Radioactive Material License (RED)

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6 NYCRR Part 373 Permit Attachment B: General Facility Description December 2013

ATTACHMENT B

FACILITY DESCRIPTION


HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NO. 980592497

General Facility Description

Facility Maps

Site View - RKPR-009-04AN-Site_View

HWMU32 - RKPR-009-04DC-Topology HWMU-32

HWMU33 – RKPR-009-04DA-Topology HWMU-33

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ATTACHMENT B

FACILITY DESCRIPTION

The Eastman Business Park site is a large, integrated manufacturing plant. Kodak operations at EBP produce photographic films, synthetic organic chemicals, and toner and ink materials. EBP is also Kodak’s head quarters for research and development and includes a research complex. RED Rochester, LLC operations at EBP provide utilities services and industrial wastewater services for EBP customers. Utilities services include steam & electric generating facilities, refrigeration and process water. Industrial wastewater services include the Kings Landing waste water treatment plant, the multiple hearth sludge incinerator and the EBP industrial sewer system. EBP also includes many tenants and companies that lease from Kodak or have bought buildings at Eastman Business Park. The plant is located at 1669 Lake Avenue, Rochester, New York. The 100 Year floodplain includes a small portion of the land on which the Kings LandingWastewater Treatment Plant portion of Eastman Business Park is located. The Multiple Hearth Incinerator (HWMU-32) is clearly not in the 100 year floodplain. HWMU-32 is located in Building 95 at Eastman Business Park and is a Multiple Hearth Incinerator with a capacity of 6,101 lbs/hr of sludge and grit from the wastewater treatment plant. HWMU-32 is operated by RED. HWMU-33 is located at Building 322 at Eastman Business Park and is a Tank Storage system consisting of two tanks with a total capacity of 65,000 gallons. HWMU-33 is operated by Kodak.

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ATTACHMENT B – FACILITY MAPS LIST

FacilityMapsTitle Drawing#

HWMU‐33 Topology ERKPKP‐009‐05DAHWMU‐32 Topology ERKPKP‐009‐04DC

Eastman Business Park Site View DRKPKP‐009‐04AN

(DRAWINGS IN ATTACHMENT J)

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6 NYCRR Part 373 Permit Attachment C: Waste Analysis Plan September 2012

ATTACHMENT C – WASTE ANALYSIS PLAN


HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NO. NYD980592497

TABLE OF CONTENTS

Waste Analysis Plan Appendices:

Appendix C-1 Waste Analysis for B-95 Multiple Hearth Incinerated Sludge & Grit Appendix C-2 Waste Parameters, Methods and Rationale Appendix C-3 Sampling Methods Appendix C-4 Waste Analysis for B-322 Storage Tanks

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Attachment C - Waste Analysis Plan At the frequencies listed in Appendix C-1, in order to demonstrate compliance with permit limits, the Permittee must obtain representative samples of wastes and perform detailed chemical and physical analysis of such for the parameters, and utilizing the methods, specified by this attachment. Compatibility of materials for continuous feed processes (HWMU–32) is determined prior to entry into the aggregated wastestream by the generator and documented on the waste profile. At this HWMU process knowledge of the few individual waste streams fed into the unit is used to determine compatibility. At HWMU-32, the materials in the wastestream are from the wastewater treatment process and would be known to be compatible through the wastewater treatment process. If the results of periodic testing of materials continuously fed to the Multiple Hearth Incinerator are inconsistent with the profile for the stream, the material is not accepted for further treatment until the discrepancy is resolved and/or the profile is modified by the generator or the treatment facility.

C-1 Chemical and Physical Analyses

General description of waste Waste Sludge and Grit Process generating waste sludge Wastewater treatment plant operation Process to obtain samples The sludge samples will be collected from the sludge

conveyor just prior to introduction of waste into the hearth. Samples will consist of a 12-hour composite sample, made from grab samples drawn every 2 hours during the sampling day, and refrigerated. After a sampling run is completed the sludge is manually blended and a single composite sample is obtained for analysis. This methodology is similar to the one described in Chapter 9 of SW-846 ‘Test Methods for Evaluating Solid Waste’. See Appendix C-3

Frequency of testing see Appendix C-1 Parameters chosen for testing Chlorine

Ash Cadmium Lead

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Mercury Arsenic Beryllium Chromium Nickel Silver Moisture Organics

Rationale for chosen parameters These parameters were chosen to ensure appropriate feed

rates to the MHI for compliance with permit limits, and for proper operation.

Test methods see Appendix C-2

Also, certain sample matrices may not be amenable to these preparative procedures for metals analysis, resulting in the need for procedural modifications and use of alternative procedures. The modifications needed for these process matrices may include the use of a reduced sample size (which results in elevated detection limits) and alternate digestion acids to improve recovery of certain metals. The need for these modifications can generally be determined only during sample preparation.

Quality Assurance/Quality Control Plan

All QA/QC procedures are specified in the analytical method

Records of analytical results All raw analytical data is stored in an electronic database.

½ the MDL will be used for non-detects. Once the results are obtained, they will be entered into a spreadsheet that is stored on a local database. Analytical results of the waste stream incinerated will be maintained as a part of the operating record until closure of the facility.

EPA codes see Module I Schedule I, Table E-2

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NYSDEC December 13, 2013

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Appendix C-1

Waste Analysis for the B-95 MHI Incinerated Sludge & Grit Sampling and analysis shall be performed on the sludge waste stream in accordance with Table 1, and Appendix C-2.

Table 1 - Characterization

Analyses Frequency Organics Annually Metals - Arsenic, Beryllium, Cadmium, Chromium, Lead, Mercury, Nickel, Silver Ash Chlorine - see Module I Schedule I, Table E-3 Moisture

Compliance verification: once per month.

Treatment of Outlier Data 1) RED will collect a 12-hour composite sample of the sludge feed to the MHI once

per month. Enough sample material will be collected to allow for 4 separate analyses. The concentration/results from the initial analysis will be multiplied by the 12-hour sludge feed rate that occurred during the sampling time to calculate feed rates and evaluate compliance. Due to the potential for analytical error and/or non-homogeneity of the waste feed, if this results in a value in excess of any permit limit, RED will analyze the additional 3 samples (same waste feed material as the original sample) and use the following confirmation procedure to demonstrate compliance.

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NYSDEC December 13, 2013

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2) The result confirmation procedure will be as follows. The three additional aliquots will be analyzed for the potential outlying parameter(s). Because of the potential for an erroneous non-representative outlier, the four results will be compared to determine if there are any outliers using Dixon’s ratio-procedure. If there is any outlier at the 95% confidence level, it will be discarded and the remaining results will be averaged and this average will be used to determine compliance. If no results are determined to be outliers by Dixon’s ratio-procedure at the 95% confidence level, all four values will be averaged and this average will be used to determine compliance. (It should be noted that this final average value could be higher or lower than the initial single value and any single one of the four samples could be an outlier, or none could be.)

3) Dixon’s ratio procedure evaluates whether the various samples are part of the

normal distribution of values. If a value does not fit the distribution, it is likely that it is produced by an anomalous factor that is not representative of the entire sample, such as analytical error, or a non-representative piece of material within the sample. To calculate the Dixon ratio for a potential outlier, divide the difference between the largest and second largest value by the difference between the largest and smallest value. For four samples, if this ratio is greater than 0.765, there is a 95% probability that the highest value is not part of this normal distribution and should be discarded as an anomalous outlier. Repeat this procedure for the smallest value and second smallest value.

4) The above sampling protocol for outliers may only be employed once per

parameter per sampling event. 5) The HWC MACT FAP will use the monthly 12-hour composite sample results

(outlined above that will be collected/used for Part 373 compliance). Statistical analysis will be done at the receipt of each quarter’s analyses to project feed rates and allow for continuous compliance, and the last 12 months data will continue to be used as the applicable data set.

New Waste Profiles

The MHI shall only incinerate sludge generated from the King’s Landing wastewater treatment process, grit, and reintroduced incidental ash. No other wastes are allowed for incineration at this unit without approval of NYSDEC.

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Eastman Kodak Company and RED-Rochester, LLC Eastman Business Park, Rochester New York

Waste Parameters, Test Methods and Rationale For Waste Analysis Appendix C-2

PARAMETER TEST METHOD RATIONALE

Notes: Analysis is used when Process Knowledge is not sufficient. 1. Standard Test Methods will be followed unless an equivalent recognized by EPA/NYSDEC is

available. 6 NYCRR Part 373 Permit Attachmentt C: Waste Analysis Plan - Appendix C-2 Page - 1 Revised by NYSDEC - December 2013

Principle Constituents

and/or Significant Hazardous

Constituents

USEPA SW-846, Method 8260C or DEC approved equivalent

Determine compatibility and suitability for treatment. Assist in assigning USEPA hazardous waste number. Assure waste codes identified on the profile will be consistent with those permitted for the area.

Volatile Organics USEPA SW-846, Method 8260C or DEC approved equivalent

Semivolatile Organics

USEPA SW-846, Method 8270D

or DEC approved equivalent

Moisture ASTM D2216 or DEC approved equivalent

Determine suitability for treatment and allow adjustment of feed rate to maintain unit within operable limits.

Chlorine Content USEPA SW-846 Method 5050

Method 9056A or DEC approved equivalent

To ensure that the chlorine feed rate to the incinerator is within operable limits.

Ash Weight % ASTM D482-03 or DEC approved equivalent

Allow adjustment of feed rate to maintain ash generation within operable limits.

Metals Content USEPA SW-846, Methods 3051 and 6010C (ICP only)

or DEC approved equivalent

Control feed rate to maintain metal concentrations within operable limits.

Mercury Content USEPA SW-846, Method 7471B and Cold Vapor Atomic

Absorption or DEC approved equivalent

Determine mercury content.

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Appendix C-3 Sampling Methods

6 NYCRR Part 373 Permit Attachment C: Waste Analysis Plan - Appendix C-3 1 Revised by NYSDEC – October 2007

A-1 Introduction When necessary, wastes will be sampled and analyzed to provide physical and chemical information for proper waste characterization or verification of waste materials. The proper method and technique for obtaining a representative sample of these waste materials is critical for securing accurate data. This appendix contains information regarding the objectives of the sampling program, specific sampling methodologies, and the Quality Assurance/Quality Control (QA/QC) procedures that will be utilized to ensure the integrity of all sampling activities. A-2 Objective The objective of this plan is to describe the sampling methods that will be utilized to obtain representative samples for the purposes of waste characterization and verification. All sampling activities outlined in this Sampling Plan conform to the following publications except as noted in 3.1.1:

USEPA SW-846, Chapter 9, September, 1986, and its updates; and "Samplers and Sampling Procedures for Hazardous Waste Streams", EPA 600/2-

80-018, January 1980 Waste Analysis At Facilities That Generate, Treat, Store And Dispose Of

Hazardous Waste, A Guidance Manual, PB94-96303, OSWER 9938-4-03, April 1994, Section 2.3.

A-3 Sampling Descriptions and Procedures 3.1 Sampling Equipment and Procedures: This section describes the sampling equipment and sampling procedures. Section 3.1.1. describes typical sampling methods for solids.

3.1.1 General sampling of solids could include one of the following techniques:

a. Thief Sampler. For most loose, granular or powdered waste, a thief or a similar device can be employed. The sampler will be inserted diagonally from the top to bottom edges, when possible. The collected material will be transferred to a sample bottle. b. Scoop or Trowel. If the waste is known to be homogeneous, a scoop or trowel may be employed with sample material extracted from just below the surface. The sample will be transferred to a sample bottle.

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c. Veihmeyer Sampler. A Veihmeyer type sampler may be employed to sample hard-packed material or viscous sludge from large and small containers. For small containers, the sampler will be inserted diagonally from the top to bottom edges, when possible. For large containers, several randomly selected top-to-bottom columns are extracted. If necessary, the sample will be crushed in a vessel or on an inert surface using inert tools.

3.2 Cleaning and Storage of Equipment: All samplers are cleaned before and after use. Manual samplers are washed with a warm detergent solution, rinsed thoroughly with tap water and then distilled water, and dried. 3.3 General Sampling Procedure:

3.3.1 The appropriate sampler is selected. A primary device is chosen with an alternative back-up.

3.3.2 The appropriate equipment is selected. 3.3.3 The waste is sampled as described in section 3.1. Sampling accuracy is

achieved by random sampling and sampling precision is achieved by maximizing the physical size of the samples collected.

3.3.4 Sample bottles to be used are described in the QA/QC portion of this document 3.3.5 Dependent upon the types of analysis, the appropriate volume of sample will be

collected. 3.3.6 The appropriate sample preservation technique will be used for transport to the

respective analytical laboratories. 3.3.7 Chain of Custody procedures and other documentation requirements are

described in Section 4 for samples that will be subject to analytical testing. 3.3.8 Waste samples in sample bottles will be handled as described in Section 4.

A-4 Quality Assurance/Quality Control Procedures: The QA/QC procedures described in this section represent an integral part of the over-all sampling plan for the samples that will be subject to laboratory analytical testing. 4.1 Sample Preservation and Bottles: Sample handling will be conducted in a manner to maintain original characteristics of the sample. Proper sample management will be maintained from the time of collection until analysis. Preservation methods and holding times will be followed in accordance with accepted analytical methods. In cases where the policy of the Department requires more stringent holding times, these will be followed. When required, samples will be packed in an ice cooler immediately after collection. 4.2 Sample Labels: Labels will be placed on all samples and will include the following information:

Date and time of collection

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Sample Location Sample Type Analysis to be performed Name(s) of sampling personnel and affiliation Laboratory Sample ID Number (after generation by the laboratory) Sample bottle lot number

After sample collection, the bottles will be sealed to prevent tampering prior to laboratory analysis. All collected samples will be labeled with appropriate warning labels, identifying all known skin, eye, respiratory, chemical reactivity and flammability hazards in addition to the routine sample label. When health effects are unknown, the samples will be so labeled and handled as highly hazardous materials. 4.3 Field Log Books: The field log books used during sampling procedures will include the following information:

Date and time of collection Sample Location Sample Type Sampler's Initials Laboratory Sample ID Number (after generation by the laboratory) General Remarks/Observations Sample bottle lot number

Entries in the field log books will be made in ink or electronic equivalent. 4.4 Sample Custody: A chain-of-custody form (COC) will be completed after sample collection and entries into the field log book. The chain of custody forms will accompany the samples to the laboratory. The field personnel collecting the samples will be responsible for the custody of the samples until transportation to the laboratory. Sample transfer will require the individuals relinquishing and receiving the samples to sign, date and note the time on the chain-of-custody forms. 4.5 Sample Analyses: A Request for Analysis (RFA) will be completed before sample collection and delivered to the laboratory. The RFA details the required analyses the laboratory is to perform on the collected samples and ensures that the laboratory is prepared to perform analyses within the required time-frame. References:

SW846 Third Edition, September, 1986 1. EPA 600/2-80-018, January 1980

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2. New York State Code of Rules and Regulations, Title 6, Part 371, Appendix 19

3. Waste Analysis At Facilities That Generate, Treat, Store, And Dispose Of Hazardous Wastes, A Guidance Manual, PB94-963, OSWER 9938.4-03, April 1994, Section 2.3.

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APPENDIX C-4 Introduction Appendix C-4 of the Waste Analysis Plan applies specifically to waste receipt and storage practices at HWMU-33. Regulated activities at this HWMU are limited to tank storage prior to material reclamation in the existing distilling department operations, which are exempt from RCRA permitting. HWMU-33 accepts material from off-site non-Kodak sources for storage in tanks. A complete description of the HWMU-33 is included in Part D-2: Process Information -Tanks. The non-Kodak materials stored in the tanks is consistent with Kodak’s reclamation specifications and similar in chemical characteristics to Kodak materials processed at the facility. Based on generator characterization some of these non-Kodak materials may be classified as a Hazardous Waste. A complete list of USEPA waste codes which may be accepted by Kodak for storage are included in Schedule 1 of the permit. The remaining portions of this appendix outlines the profile approval, pre-acceptance, waste receipt, verification and acceptance processes which are undertaken for all non-Kodak hazardous waste that are accepted for storage. Profile Approval Pre-Acceptance Process Before a waste stream can be approved for storage at HWMU-33, a Waste Profile Sheet (WPS), and sample, if necessary, will be provided to Kodak for evaluation. The WPS shall contain information about the generator, physical and chemical characteristics of the waste, processes generating the waste, applicable waste codes, and a generator certification regarding accuracy of the information. The following list details the minimum information that will be supplied as part of the WPS: Generator Information

Name Address Contact Person Phone # Facility EPA ID #

General Information Generating Process Common Name of Waste DOT Shipping Name and Hazard Class

Chemical Composition List of Chemical Constituents and Concentrations

Physical Description Physical State Phases/Layering Odor Color

Regulatory Information

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Regulated or Licensed Radioactive Wastes Regulated Medical Waste TSCA Regulated Waste EPA Waste Codes LDR requirements Other State Waste Codes

Generator Certification Certification signed by the generator that the information supplied on the WPS and any attachments or supplements represent a complete and accurate description and characterization of the waste

An evaluation of the WPS information will serve as the basis to determine if the waste is acceptable for storage. The evaluation will include reviews of:

Appropriate documents to ensure that the acceptance of the waste material will be in compliance with applicable federal, state and local laws, regulations and permit requirements.

The physical and chemical characteristics of the waste material to ensure that the material

is compatible with the tank storage system and other materials that may be present in the tanks.

The material contains recoverable solvents.

The waste characterization information to ensure that the waste material does not contain

any waste codes, chemicals or properties that are not authorized by the permit. If the material is acceptable for storage at HWMU-33, the WPS will be assigned a unique identification number for recordkeeping purposes. The WPS will be signed by the generator or the generator’s representative. The generator will be notified in writing that Kodak has the appropriate permits for storage of the material. WPSs will be available on-site for agency review.

All tank storage areas at HWMU-33 meet the requirements for secondary containment. In accordance with Table 3, the following information will be reflected on the WPS and be available prior to storing material in tanks:

Constituents - Information regarding constituents is supplied to assure that waste codes identified on the profile are consistent with those permitted for the area.

Hazard Indices - Appropriate hazard ratings must be assigned to be able to identify the proper handling procedures for the waste.

Compatibility - The waste profile must provide information to assure that the materials within the container are compatible with each other and the container.

Physical State - This information will identify whether the material is a liquid and therefore whether secondary containment is needed for storage. The definition of liquid includes materials that do not pass the paint filter test.

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pH - pH is used as an indicator for liquids to determine potential concerns with corrosivity of the material and the tanks.

The WPS will be reevaluated when a generator notifies Kodak that the process generating the waste or the characteristics of the waste change. At a minimum, each WPS will be recertified on an annual basis. For the annual recertification the generator will be required to certify that the process or waste characteristics have not changed. Waste Receipt, Verification, and Acceptance at HWMU-33 The waste receipt, verification, and acceptance process used by HWMU-33 is illustrated in Figure 1. Waste Manifest Each hazardous waste container that is shipped to HWMU-33 must be accompanied by a waste manifest. Waste Receipt Prior to acceptance of the waste at HWMU-33, an operator confirms that: 1) the container is in good condition; 2) the container is properly labeled; 3) the container is accompanied by the necessary shipping information (manifest, LDR notification); and 4) the waste is approved. Waste Verification The contents of containers received from off-site generators are verified prior to acceptance. Physical verification is described in Table 1. If the visual observations raise questions regarding the validity of the waste identification, then the verifier will proceed with additional waste verification (i.e., specific gravity). In addition each waste received will be sampled and analyzed for organic constituents to verify that reclaimable solvents are present at the levels indicated on the WPS.

Table 1: Hazardous Waste Verification 100% of Wastes

Waste Stream Physical Verification Liquids

Visual observation of identifying characteristics. Specific Gravity Reactivity Indicator

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Compatibility Test Prior to acceptance for storage in tanks, a bench-scale compatibility test is conducted to assure that incompatible wastes are not mixed at HWMU-33. A sample of wastes from the tank is mixed with a sample of the incoming wastes, and checked for potential reaction. Table 2 presents the bench-scale compatibility test procedure. Waste Acceptance Waste is accepted for storage at HWMU-33 only after an operator has: 1) reviewed the associated manifest; 2) verified off-site wastes according to the protocol listed above; and 3) performed bench-scale compatibility tests for liquids destined for tank storage. If inconsistencies are identified in the paper work, verification, or testing, then the verifier will contact the generator to resolve the issue or reject the waste. Rejected wastes may be returned to the generator for proper characterization, or sent to an alternate TSDF under the direction of the generator for management.

Table 2: Bench-Scale Compatibility Test Procedure HWMU-33

Step 1

Obtain a sample representative of the material in the tank. The sample is collected directly from the tank.

Step 2

Obtain a sample from the incoming waste (approximately one pint). Typically a Coliwasa sampler is used to ensure a representative sample of the incoming waste.

Step 3

Combine equal amounts of both samples, hold the mixture for 5 minutes, and check for any indications of incompatibility: - fuming - settling - solidification - generation of heat If the compatibility of a waste stream is in question, the operator will hold the mixture for no less than 30 minutes, and check for indications of incompatibility.

Step 4

If there are no signs of incompatibility, waste may be added to the storage tank.

Step 5

If the incoming waste is incompatible, load is rejected.

Personnel

The bench-scale compatibility procedure is performed by an operator at the permitted unit or an on-site laboratory. Also available for additional information are the on-site chemists and technical support.

Quality Assurance/Quality Control Procedures:

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The QA/QC procedures described in this section represent an integral part of the over-all sampling plan for the samples that will be subject to off-site laboratory analytical testing. 1 Sample Preservation and Bottles: Sample handling will be conducted in a manner to maintain original characteristics of the sample. Proper sample management will be maintained from the time of collection until analysis. Preservation methods and holding times will be followed in accordance with accepted analytical methods. In cases where the policy of the Department requires more stringent holding times, these will be followed. When required, samples will be packed in an ice cooler immediately after collection. 2 Sample Labels: Labels will be placed on all samples and will include the following information:

Date and time of collection Sample Location Sample Type Analysis to be performed Name(s) of sampling personnel and affiliation Laboratory Sample ID Number (after generation by the laboratory) Sample bottle lot number

After sample collection, the bottles will be sealed to prevent tampering prior to laboratory analysis. All collected samples will be labeled with appropriate warning labels, identifying all known skin, eye, respiratory, chemical reactivity and flammability hazards in addition to the routine sample label. When health effects are unknown, the samples will be so labeled and handled as highly hazardous materials. 3 Field Log Books: The field log books used during sampling procedures will include the following information:

Date and time of collection Sample Location Sample Type Sampler's Initials Laboratory Sample ID Number (after generation by the laboratory) General Remarks/Observations Sample bottle lot number

Entries in the field log books will be made in ink or electronic equivalent. 4 Sample Custody:

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A chain-of-custody form (COC) will be completed after sample collection and entries into the field log book. The chain of custody forms will accompany the samples to the laboratory. The field personnel collecting the samples will be responsible for the custody of the samples until transportation to the laboratory. Sample transfer will require the individuals relinquishing and receiving the samples to sign, date and note the time on the chain-of-custody forms. 5 Sample Analyses: A Request for Analysis (RFA) will be completed before sample collection and delivered to the laboratory. The RFA details the required analyses the laboratory is to perform on the collected samples and ensures that the laboratory is prepared to perform analyses within the required time-frame. References:

1. SW846 Third Edition, September, 1986 1. EPA 600/2-80-018, January 1980 1. New York State Code of Rules and Regulations, Title 6, Part 371,

Appendix 19 1. Waste Analysis At Facilities That Generate, Treat, Store, And Dispose of Hazardous

Wastes, A Guidance Manual, PB94-963, OSWER 9938.4-03, April 1994, Section 2.3.

Table 3 Parameters Applicable to Wastestreams Stored in Tanks

Constituents X Hazard Ratings X Compatibility X Physical State X Halogen Wt% X * Metals Content X * pH (liquids) X Specific Gravity (liquids) X *

* Required for initial characterization only

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FIGURE 1WASTE RECEIPT, VERIFICATION, ACCEPTANCE

HWMU 33

Container arrives at HWMU-33

Operatorconfirms that:- container is in good condition- container is properly labeled

container has proper shipping information- container has proper shipping information- waste profile- shipping ticket- manifest (if necessary)

OperatorReviews waste profileactive profileactive profile- storage requirements- handling requirements (PPE, etc.)Contacts generator for discrepancies

Operator-Completes waste verification -Contacts generator for discrepanciesM d t h i l & h i l t ti if-May conduct physical & chemical testing ifnecessary

-May choose to reject waste

Acceptable for storage Reject Load

No

Conduct Compatibility Test (Table 2)

Yes

Compatible

Reject LoadIncompatible

Pump to storage tank

September 2012

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