HomeMy WebLinkAboutDSHW-2024-006846
ATTACHMENT 1
WASTE ANALYSIS PLAN
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page i UTD 982595795
Table of Contents
1.0 Introduction ............................................................................................................................... 1
1.1 Overview ................................................................................................................................... 1
1.2 Definitions ................................................................................................................................ 2
2.0 Identification of Wastes to be Managed ................................................................................... 5
2.1 Wastes Accepted ....................................................................................................................... 5
2.2 RCRA Wastes ........................................................................................................................... 5
2.3 Transfer-Only Waste ................................................................................................................ 5
2.4 PCB Wastes .............................................................................................................................. 5
3.0 Waste Characterization ............................................................................................................. 6
3.1 Routine Wastes ......................................................................................................................... 6
3.1.1 Profile Approval Process (Routine Wastes) ......................................................................... 6
3.1.2 Load Acceptance and Handling of Discrepancies (Routine Wastes) ................................... 8
3.2 Wastes that Inhibit Analysis ................................................................................................... 10
3.2.1 Additional Requirement for Profile Approval Process (Waste that Inhibits Analysis) ...... 10
3.2.2 Load Acceptance and Handling of Discrepancies (Waste that Inhibits Analysis) ............. 11
3.3 Heterogeneous Debris ............................................................................................................. 11
3.3.1 Profile Approval Process (Heterogeneous Debris) ............................................................. 11
3.3.2 Load Acceptance and Handling of Discrepancies (Heterogeneous Debris) ....................... 11
3.4 Off-Specification Wastes ........................................................................................................ 11
3.4.1 Additional Requirements for Profile Approval Process (Off-Specification Wastes) ......... 11
3.4.2 Load Acceptance and Handling of Discrepancies (Off-Specification Wastes) .................. 11
3.5 Transfer Operations ................................................................................................................ 12
3.5.1 Profile Approval Process (Transfer Operations) ................................................................ 12
3.5.2 Handling of Discrepancies (Transfer Operations) .............................................................. 12
3.6 PCB-Only Wastes: .................................................................................................................. 12
3.6.1 Profile Approval Process (PCB-Only Wastes) ................................................................... 12
3.6.2 Load Acceptance and Handling of Discrepancies (PCB-Only Wastes) ............................. 12
4.0 Waste Sampling ...................................................................................................................... 16
4.1 Sampling Locations ................................................................................................................ 16
4.2 Sampling Methods .................................................................................................................. 16
4.3 Traceability ............................................................................................................................. 16
4.4 Sampling Personnel ................................................................................................................ 16
4.5 Sample Labels ......................................................................................................................... 17
4.6 Logbook .................................................................................................................................. 17
4.7 Sample Preservation ............................................................................................................... 17
4.8 Sampling of Containers .......................................................................................................... 17
4.9 Sampling of Bulk Materials .................................................................................................... 18
4.10 Frozen Waste .......................................................................................................................... 18
4.11 Other Samples ......................................................................................................................... 19
5.0 Test Methods .......................................................................................................................... 19
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page ii UTD 982595795
List of Tables
Table 1: Summary of TSCA Wastes for Storage ...................................................................................... 6
Table 2: Storage and Acceptance (Fingerprint) Analyses ..................................................................... 14
Table 3: Methods and Tolerance Limits ................................................................................................ 15
Table 4: Analytical Parameters and Associated Methods ...................................................................... 20
Appendix 1 - Quality Assurance Plan
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 1 UTD 982595795
WASTE ANALYSIS PLAN
1.0 INTRODUCTION
The following describes the methods that shall be used to manage hazardous waste regulated by the
Resource Conservation Recovery Act (RCRA), waste regulated by the Toxic Substance Control Act
(TSCA), and waste regulated by the Utah Administrative Code (UAC) R315, Environmental Quality,
Division of Waste Management and Radiation Control at the Clean Harbors Clive Facility, hereafter
referred to as Clive or the Facility.
1.1 Overview
Clean Harbors Clive, LLC, Clean Harbors Aragonite, LCC (Aragonite), Clean Harbors Grassy
Mountain, LLC (Grassy Mountain) and Clean Harbors Kimball (Kimball) are all subsidiaries owned by
Clean Harbors, Inc. Analytical laboratories operated at the Aragonite, Grassy Mountain, and Kimball
facilities may be available to perform analytical work required to receive waste into storage at the Clive
facility. Additionally, the Clean Harbors, Inc., Central Profile Group located in Norwell, Massachusetts,
conducts waste acceptance procedures for the Clive facility.
The objective of the waste analysis plan (WAP) is to describe the procedures used to obtain sufficient
information regarding waste streams to operate the facility in accordance with applicable permit
requirements. More specifically, the waste analysis plan ensures that wastes accepted are appropriate
for management at the facility and that the wastes that arrive at the facility are the same as those
evaluated in the profiling process.
This plan also anticipates that wastes will be generated on-site at Clive and must be managed in
accordance with the Permit. On-site generated wastes will be subject to the same waste analysis
procedures as wastes accepted from off-site sources except for incoming load procedures which are not
required for site-generated waste.
This waste analysis plan addresses the RCRA regulated hazardous waste and TSCA regulated PCB
wastes that are managed at the Clive facility in accordance with R315-264-13(a), (b), and (c), R315-270-
14(b)(3), and 40 CFR § 761. Clive operates as a hazardous waste and PCB transfer, treatment, and
storage facility. Treatment, which occurs infrequently, is conducted in Unit 707.
The purpose of this WAP is to establish necessary sampling methodologies, analytical techniques, and
overall procedures for characterization, acceptance, and management of hazardous wastes accepted or
generated at the Clive facility.
This waste analysis plan establishes the following:
- The waste profile procedures for determining whether waste streams will be acceptable for
management at the Clive facility and for notifying the generator whether their waste will be
accepted.
- The waste load acceptance procedures for characterizing the wastes to verify the waste corresponds
to the waste profile sheet and the waste manifest and for establishing appropriate management
strategies.
- The frequency and methods for sampling and analyzing incoming loads of waste.
- The parameters for which each waste will be analyzed and the rationale for their selection.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 2 UTD 982595795
This waste analysis plan is supported by Standard Operating Procedures (SOPs) that provide detailed
instructions to perform the waste profile review, waste acceptance, sampling, and are incorporated by
reference as part of this waste analysis plan. Aragonite, Grassy Mountain, and Kimball laboratory
personnel may also use the same SOPs. The SOPs may be required for Utah certification of the
Aragonite, Grassy Mountain, and Kimball laboratories and will be followed for compliance with the
Permit. The WAP is also supported by the Quality Assurance Plan which is Appendix 1 of this
attachment.
1.2 Definitions
The following terms, applied within the WAP, shall have the following meaning:
Accept, Accepted or Acceptance: When it has been determined that a waste shipment received at
the Facility conforms to the approved profile (or all discrepancies have been resolved) and the
Facility is willing to accept the waste for treatment or storage.
Accuracy: The closeness of a result, or the arithmetic mean of a set of results, to the true, expected,
or accepted value.
Analysis: The term "analysis" means any method by which the value of a particular parameter is
determined. These methods may include laboratory procedures specified in this WAP or may rely
on knowledge of the waste or the process generating the waste.
Analyte: The substance, element, or compound for which a sample is analyzed to determine its
presence or quantity. Also known as an analytical parameter.
Analytical Method: A quantitative procedure for determining the specific concentration or
characteristic of an analyte or analyte group.
Approve, Approved, or Approval: This term is used in the context of evaluating a profile. Approval
of a waste stream profile occurs after all necessary evaluations and analyses have been made and
when the generator is notified.
ARA: means the Assistance Regional Administrator of the Office of Partnerships, Regulatory
Assistance, EPA Region 8.
Aragonite: Clean Harbors Aragonite, LLC.
Audit, performance: A check on the performance of analysts. Sometimes categorized as a
quantitative appraisal of quality.
Bulk Load: The term "Bulk Load" means any individual waste shipment transported to the facility
which is too large to be managed through the Container Management Building (e.g., an intermodal
container, end-dump truck, tanker truck, railcar, etc.).
Clean Harbors: Parent corporation of the Clive facility.
Clive: Clean Harbors Clive, LLC.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 3 UTD 982595795
Consolidation Container: Shipping containers holding small containers(bottles, jars, cans, bags) of
compatible consumer products. The outer container may or may not contain loose absorbent or
absorbent pads.
Debris: Debris is solid material exceeding a 60 mm (approximately 2-inches) particle size that is
intended for disposal and that is a manufactured object; plant, animal matter; or natural geologic
material
Director: Means the Director of the Division of Waste Management and Radiation Control.
EPA: Means the United States Environmental Protection Agency.
Generator: Generator or generator’s authorized representative.
Generator Knowledge: If generator knowledge is used to make a hazardous waste determination,
information shall be available to substantiate the waste evaluation. Below are examples of
information that can be used to make the waste evaluation required under R315-262-11 UAC. Some
or all of these examples or other information can be used to make a hazardous waste determination
applying generator knowledge.
1. Generator specific process flow diagram or narrative description of the process generating
the waste (should be used in most cases).
2. Chemical makeup of all ingredients or materials used in the process that generates the waste
(should be used in most cases).
3. List of constituents that the Facility know or have reason to believe are byproducts or side
reactions to the process that produces the waste.
4. Material Safety Data sheets (MSDSs) or Safety Data Sheets (SDS) and/or product labels or
substances used in the process that generates the waste.
5. Data obtained from approved methods of sampling and laboratory analysis by a Utah-
Certified laboratory.
6. Data obtained from literature regarding waste produced from a similar process using the
same ingredients and/or materials.
7. Documentation of product specifications of input materials and output products.
GMF or Grassy Mountain: Clean Harbors Grassy Mountain, LLC Facility.
Hazardous waste: The definition of "hazardous waste" shall be as provided in R315-261-3 of Utah
Amin. Code.
Holding Time: The maximum time allowable between time of sampling and time of extraction and
analysis, or both.
Infectious Waste: means a solid waste that contains or may reasonably be expected to contain
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 4 UTD 982595795
pathogens of sufficient virulence and quantity that exposure to the waste by a susceptible host could
result in an infectious disease (Utah Code Annotated Title 19 Section 6 Subsection 102).
Incoming Load: The term "Incoming Load" refers to a load during the period starting when a waste
shipment arrives at the facility through the time when a waste shipment is rejected or accepted.
Incoming loads may be placed in a storage unit pending the acceptance procedure.
Kimball: Clean Harbors Kimball, LLC
Laboratory: Laboratory refers to a laboratory certified by the State of Utah’s Public Health
Laboratory. Also referred to as a Utah-certified laboratory.
Laboratory Manager: The "Laboratory Manager" or however named by certifying agencies, refers to
the individual or designee responsible for implementation of the WAP.
Lab pack: A container (bottle, jar, sealed bag, etc.) or containers packed inside a larger shipping
container as described in R315-264-316 and in accordance with the specifications of 49 CFR
173.12(b).
NELAP: Means the National Environmental Laboratory Accreditation Program.
Non-hazardous waste: "Non-hazardous waste" refers to "solid waste" as defined in R315-261-2 of
Utah Amin. Code which is not also "hazardous waste" as defined in R315-261.3 of Utah Amin.
Code.
Parameter: The term "parameter" is a specific material property, such as pH, specific gravity,
viscosity, etc.
Particle size: The largest dimension of a portion of a waste.
PCB(s): The term "PCB(s)" refers to polychlorinated biphenyls (PCB(s)) or PCB Item(s) as defined
in 40 CFR § 761.
PCB Waste: Means any waste (e.g., mixture of liquid, solid, or sludge etc. or any PCB-containing
item) that contains PCBs regulated by 40 CFR § 761.
Pre-acceptance: The period in which a waste stream's acceptability for storage and treatment at the
facility is evaluated, is referred to as "pre-acceptance." This is the same as the Profile Approval
Period.
Precision: The agreement or repeatability of a set of replicate results among themselves or agreement
among repeated observations made under the same conditions.
Pre-treatment: The term "Pre-treatment" refers to the period between acceptance and treatment of
the waste.
Profile: Means Waste Profile in electronic or other format that describes a waste or waste stream.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 5 UTD 982595795
Radioactive: A "Radioactive" material shall be any Byproduct or Source Material licensable by the
Utah Division of Radiation Control or the NRC, or any waste found to have a count rate as measured
one inch from the surface that exceeds background by three times or more.
Receive or Received: Means when waste passes into the fenced portion of the facility.
Representative sample: Means a sample exhibiting average properties of the whole waste.
Screening Method: A semi-quantitative procedure for determination of the specific concentration, or
characteristic of an analyte or analyte group.
Waste Stream: Waste stream means a waste that is, or can be, identified as a line item on the
Uniform Hazardous Waste Manifest from the same source of generation and delivered with the same
load. Identical materials with the same waste profile number, that are listed on separate manifest
line items only because of container size or type are considered to be the same waste stream.
2.0 IDENTIFICATION OF WASTES TO BE MANAGED
2.1 Wastes Accepted
Materials acceptable for storage at the Clive facility include wastes regulated under the Resource
Conservation and Recovery Act (RCRA), the Hazardous and Solid Waste Amendments (HSWA),
Superfund (CERCLA), and the Toxic Substances Control Act (TSCA). Clive may also accept exempt
hazardous waste such as household hazardous waste and industrial waste.
2.2 RCRA Wastes
Wastes may be accepted in a variety of physical forms, including liquids, sludges, solids, and
compressed gases. The physical nature of some waste may inhibit waste analysis such as steel plates,
rocks, glass, etc. Wastes may not arrive in a 100% homogenous form and many waste streams may be a
mixture of hazardous wastes codes. Modules 2, 3 and 4 of this Permit identify the wastes and waste
codes that are acceptable and prohibited for management in the waste management units at the Clive
facility.
2.3 Transfer-Only Waste
Clive may also temporarily (ten days or less) hold wastes manifested to another facility in accordance
with R315-263-12. This is referred to as transfer operations. There are no restrictions on waste codes or
waste types for transfer operations.
2.4 PCB Wastes
The types of PCB materials accepted for storage and held for transfer operations at the facility are
summarized in Table 1. Definitions of the terms used in the table are given. These wastes are regulated
under the Toxic Substances Control Act (TSCA) and may be commingled with RCRA-regulated wastes.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 6 UTD 982595795
Table 1: Summary of TSCA Wastes for Storage
PCB TYPE CLASS
TYPICAL PCB
CONCENTRATION (DRY
WT)
Oil1 Liquid 0-90%
Water Liquid 0-10%
Articles & Capacitors Solid 20%
Miscellaneous Solids2 Solid 0-10%
Soils, Spill Cleanup3 Solid, Sludge < 50%
1Oil may be, but not limited to dielectric liquid containing PCB and a chlorinated solvent and is
hydrocarbon based.
2Miscellaneous solids include gloves, protective clothing, debris, etc.
3Soils means dirt, earth, rock.
3.0 WASTE CHARACTERIZATION
This Section describes the procedures that are followed for: approving a waste stream for management
at the facility; sampling, analyzing, or inspecting incoming loads to verify the waste shipment; and
resolving discrepancies that may occur upon receipt of the waste. Six load acceptance procedures
(sections 3.1 through 3.6) are provided because the differences in physical form, packaging, sampling
requirements and management options for the many waste types that will be handled at the facility
require the ability to sample and analyze a variety of different waste matrices. Section 3.1 describes the
procedures for most waste categories. Sections 3.2 through 3.6 describe alternate procedures. Clive will
clearly document the waste characterization procedure (i.e., 3.1 through 3.6) utilized for each waste
stream accepted at the facility. If more than one characterization procedure applies to a given waste
stream, Clive will choose one of the applicable characterization procedures and document the procedure
selected.
3.1 Routine Wastes
3.1.1 Profile Approval Process (Routine Wastes)
Before Clive can approve a waste stream for storage and/or treatment at the facility, (1) a generator shall
provide a completed Waste Profile Sheet; (2) Clive shall confirm the waste may be managed at the
facility pursuant to the terms of this Permit; and (3) Clive shall confirm the waste shipment corresponds
to the waste profile sheet and the accompanying waste manifest. The Central Profile Group and Clive
review the Waste Profile Sheet to determine acceptability of the waste stream at Clive.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 7 UTD 982595795
3.1.1.1 Waste Profile Sheet Review
Waste Profile Sheets contain information about the generator, physical and chemical characteristics of
the waste, process generating the waste, applicable waste codes, applicable DOT shipping name, and a
generator certification that the information provided is accurate. At a minimum, the Waste Profile Sheet
must provide the following information:
Generator Information
Generator
Address
Facility Contact
Phone #
Generator EPA ID#
General Information
Generating Process
Common Name of Waste
Rate of Generation
DOT Shipping Name
DOT Hazard Class
EPA Waste Codes
Chemical Composition
List of Chemical Constituents and Concentrations
Physical Description
Physical Description
Physical State
Phases/Layering
% Free Liquid
Regulatory Information
Regulated or Licensed Radioactive Waste
Regulated Medical Waste
Dioxin Listed Waste
TSCA Regulated Waste
Generator Certification
Certification signed, actual or electronic, by the generator that the information supplied on the
Waste Profile Sheet and any attachments or supplements represent a complete and accurate
description of the waste.
Assessment of Clive’s Ability to Manage the Waste
Following the review of the Waste Profile Sheet by the Central Profiling Group and Clive personnel,
Clive evaluates whether the waste stream may be managed at the facility pursuant to the Permit.
Additionally, the evaluation includes a review of:
-Existing storage facilities and capabilities to ensure that the waste material can be satisfactorily
managed by Clive in accordance with this Permit or a permitted off-site facility.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 8 UTD 982595795
-The physical and chemical characteristics of the waste material to ensure that the material is
compatible with other wastes present at the facility.
-The waste characterization information and available analytical data to ensure that the waste
material does not contain any specific waste codes, compounds, or properties that are prohibited at
Clive.
3.1.1.2 Decision to Receive Waste Stream
The waste profile decision is recorded electronically in the WINWEB system and includes the Central
Profiling Group/Clive personnel issuing the decision with a date/time stamp. Following approval of the
waste stream and prior to shipment of the waste, the generator will be notified in writing that the Clive
facility has the appropriate permits for and will accept the waste stream in accordance with Condition
2.B. and R315-264-12(b).
If the waste is approved for management at the Clive facility, a unique identification number (the Profile
Number) is assigned to the waste stream.
Review of Waste Profile Approval
The waste profile evaluation is repeated when: (1) a generator notifies Clean Harbors or Clive that the
process generating the waste has changed (e.g., when the raw materials to the process have changed), (2)
if Clive has reason to suspect that the waste is in non-conformance with profile documentation, or (3) at
a minimum, annually.
For an annual waste profile recertification, the generator shall notify of any changes in the waste stream
or certify in writing that the waste stream has not changed. After a positive review of the generator’s
certification, the waste profile will be reauthorized. Or if there are changes in the waste stream which do
not result in the waste stream being unacceptable, the waste profile will be updated and approved. If
there are changes in the waste stream which result in the waste stream becoming unacceptable, the waste
profile approval will be canceled, and the generator notified.
3.1.2 Load Acceptance and Handling of Discrepancies (Routine Wastes)
3.1.2.1 Waste Acceptance Inspection, Samples and Analysis
Upon approval of the waste profile, the waste may be scheduled for shipment to the Clive facility. Upon
arrival at the Clive facility, the accompanying waste manifest is reviewed, and the waste is inspected,
sampled, and analyzed (fingerprint) prior to it being accepted or commingled with other waste streams.
This serves two purposes. First, it compares the waste characteristics of the actual load with those
determined during the waste profile approval process and those listed on the waste manifest. Second, it
establishes the characteristics that identify proper management of the waste while at the facility. Clive-
generated wastes are not subject to the incoming load procedures described in this Section.
3.1.2.2 Waste Acceptance Samples Collected at Aragonite, Grassy Mountain, or Kimball
Incoming load samples collected at Aragonite, Grassy Mountain, or Kimball may be used in lieu of
taking samples of the waste when it arrives at the Clive facility only if: (1) The waste stream has an
approved waste profile issued by Clean Harbors; (2) Clive has evaluated and documented that the waste
may be managed in accordance with this Permit; (3) Clive has received and reviewed the analytical
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 9 UTD 982595795
results from samples collected at Aragonite, Grassy Mountain, or Kimball: (4) Clive has verified in
writing that the Aragonite, Grassy Mountain, or Kimball facility collecting the samples complied with
the identical sampling methods prescribed in this Permit; (5) the analysis was performed by a State of
Utah-certified laboratory for the analytical methods used; (6) Clive confirmed the analytical quality
assurance is acceptable; and (7) the analytical results and the waste profile meets the acceptability
criteria described below.
3.1.2.3 Waste Acceptance
Clive determines the acceptability of the waste based on:
- agreement between the waste profile and the load analyses,
- permit conditions at the facility, which were determined prior to waste shipment, and
- the availability of proper waste management at the Clive facility.
Waste is not officially accepted until the waste has been determined to match the waste profile and the
waste manifest and any discrepancies have been adequately resolved and documented.
Discrepancies from Waste Profile
Potential discrepancies for waste shipments include differences in quantity and type between the
manifested waste and the waste received. Waste type discrepancies are determined by inspection and by
comparing the analyses of the incoming load to the waste profile information and the waste manifest.
Discrepancy in Quantity of Waste
To check for quantity discrepancies, the number of containers, or the weight if it is a bulk shipment, is
reconciled with the uniform hazardous waste manifest. The number of containers must be correct; there
is no tolerance. The weight of bulk shipments must be within ± 10% of the manifested weight. If
discrepancies in the quantity of waste occur, the generator will be contacted by Clive to resolve the
difference.
Discrepancy in Type of Waste
Changes in the proper shipping name, additional waste codes, etc. are documented in the operating
record. If any of these conditions occur, the manifest is considered discrepant, and actions will be taken
to reconcile the discrepancy. If discrepancies of waste type occur, one or more of the following actions
may be used to resolve the discrepancy:
The sampling and analytical data are reviewed to verify that they are indeed correct.
- Additional analyses may be necessary to resolve discrepancies or to re-profile the waste. Container
shipments with waste discrepancies are sampled as described in Section 4.8. The sample
composites are analyzed for the acceptance parameters listed in Table 2. Each bulk liquid, sludge,
and solid shipment with waste discrepancies is sampled as described in Section 4.9 and analyzed
for the acceptance parameters listed in Table 2. If the container or bulk waste can be managed and
is not prohibited at the Clive facility, the waste may then be accepted.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 10 UTD 982595795
- A Clive facility employee contacts the generator or authorized representative. In cases where the
waste is amenable to management at the facility, the discrepancy may be resolved between Clive
and the generator, or authorized representative, which may require a new profile for the waste or
updating the existing profile. Waste that is not amenable to acceptance by Clive is rejected within
ten days of receipt.
Resolution of Waste Discrepancy
The manifest discrepancy resolution between Clive and the generator, or authorized representative, will
be noted on the manifest which becomes part of the operating record. If the discrepancy is not resolved
within 15 days, the Director of the Division of Waste Management and Radiation Control shall be
notified in writing.
Accepted Waste
Upon acceptance, the waste is placed into storage. The wastes may be stored and/or repackaged prior to
shipment off-site. Each movement of a waste within the facility, during which any change in its
characteristics may occur, makes the waste subject to additional inspection, sampling, and analysis to
determine the appropriate handling and management of the waste. All analyses needed for the
acceptance and storage functions are performed during incoming load verification. These are not
repeated unless it is known or believed that the waste characteristics may change during storage or
repackaging.
Prior to any mixing or commingling of any wastes, the wastes in question are subject to compatibility
testing as described in EPA-600/2-80-076 or ASTM method 5058-90 Test Method A, prior to being
commingled/mixed. If the wastes are compatible, the mixing/commingling may proceed. Incompatible
wastes are not mixed/commingled.
3.2 Wastes that Inhibit Analysis
This Section describes the process for characterizing waste material that is homogenous and could be
easily sampled but not easily analyzed, or for waste material that is heterogenous and cannot be easily
sampled. For the purposes of this section, homogenous material such as soils, powders, pellets, etc. are
not considered waste that inhibit analysis.
Examples of homogenous materials that are not easily analyzed include steel plates, glass, rocks, certain
kinds of DOT 1.4, 1.5, and 1.6 explosives, transformer internals (windings, cores), and sealed containers
such as capacitors and electrical devices that have historically contained PCBs. Homogenous materials
differ from debris (described in Section 3.3) in that 1) they are the same single type of material
contained within a drum or roll-off box, and 2) they consist of relatively large objects that could not be
readily analyzed.
Shipping containers holding smaller containers, such as lab packs or consolidation containers holding
consumer products, are considered to be heterogenous materials that are not easily sampled.
Gas cylinders are not sampled but are inspected for physical appearance and to ensure that the labeling
is consistent with the profile information. The operating record will document how each cylinder’s
contents are classified in accordance with the material types defined in the International Fire Code.
3.2.1 Additional Requirement for Profile Approval Process (Waste that Inhibits Analysis)
The profile approval process for waste that inhibits analysis is the same as that described in Section
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 11 UTD 982595795
3.1.1 except for sampling. The generator must also supply a picture or a detailed written description of
the waste stream that meet the requirements of ASTM method D4979-89.
3.2.2 Load Acceptance and Handling of Discrepancies (Waste that Inhibits Analysis)
The handling of discrepancies for waste that inhibits analysis is the same as that described in Section
3.1.2.
Prior to accepting the waste, Clive shall inspect the contents of each container or each bulk load for
physical appearance. The person inspecting the material will provide a detailed written description or
photo or will transmit video to waste acceptance personnel at Clive so that they can easily determine if
the waste matches the profile. Other information necessary to properly store the material (e.g., potential
incompatibilities) will be obtained and evaluated from the profile information supplied by the generator.
3.3 Heterogeneous Debris
Debris differs from the material described in Section 3.2 in that it contains a wide variety of materials.
In virtually all situations, debris has one thing in common: non-hazardous materials are contaminated
with organic and inorganic hazardous constituents. For example, it may contain a mixture of spill
absorbent, Tyvek® suits, rubber booties and gloves, and paper towels. PCB-contaminated "shredder
fluff" falls into this category. Items that may not be part of a debris profile include containers containing
any liquid. Sampling of waste streams that are subject to technology-based treatment standards
identified in R315-268-42 is not required.
3.3.1 Profile Approval Process (Heterogeneous Debris)
The profile approval procedures for heterogeneous debris are identical to those for waste that inhibits
analysis (Section 3.2.1).
3.3.2 Load Acceptance and Handling of Discrepancies (Heterogeneous Debris)
The procedures for accepting loads and handling discrepancies involving heterogeneous debris wastes
are the same as those for waste that inhibits analysis (Section 3.2.2).
3.4 Off-Specification Wastes
This category of wastes is limited to material that is in its original unopened packaging as a product.
The packaging and labeling must still be in good condition so that the contents are easily identified. The
Safety Data Sheet (SDS) for the material must also be available.
3.4.1 Additional Requirements for Profile Approval Process (Off-Specification Wastes)
The profile approval process for this category of wastes (Off-Specification wastes) is identical to that for
routine wastes (3.1.1) except that the SDS is submitted with the waste profile in lieu of sampling.
3.4.2 Load Acceptance and Handling of Discrepancies (Off-Specification Wastes)
The handling of discrepancies for Off-specification wastes is the same as for routine wastes described in
Section 3.1.2.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 12 UTD 982595795
Prior to accepting the load, each container is inspected to ensure that the labeling is consistent with the
SDS. If containers in the load have been opened, they will be re-opened, and the material will be
visually compared to material in one of the unopened containers to ensure the material is the same. This
will be documented in the operating record. Other information necessary to properly manage the
material (e.g., flash point, potential incompatibilities, etc.) will be obtained and evaluated from the
profile information supplied by the generator.
3.5 Transfer Operations
These are wastes that are manifested to a facility other than Clive but are held temporarily (ten days or
less) at the facility during transit. The transfer waste may be part of a load for which some of the
material is destined for Clive. The waste destined for the Clive facility shall meet the waste acceptance
procedures provided in sections 3.1, and 3.2, 3.3, 3.5 or 3.6. When transfer wastes are shipped off-site,
the original manifest accompanies the waste. This differs from wastes which are accepted for storage
and then subsequently manifested to another facility. A new manifest is created with Clive as the
generator in this situation. The Clive facility will comply with the transporter emergency response
requirements in R315-263-30 and 31 for these wastes.
3.5.1 Profile Approval Process (Transfer Operations)
No profile approval procedures are necessary.
3.5.2 Handling of Discrepancies (Transfer Operations)
The load is not accepted but rather is held on a temporary basis. There are no requirements for sampling
or ensuring waste are comparable to a profile.
When containers are off-loaded from a trailer, the containers will be inspected to ensure they are in good
condition.
3.6 PCB-Only Wastes:
These PCB-only wastes are not hazardous waste under State of Utah or Federal RCRA regulations.
These wastes include PCB Liquids, PCB Transformers/Bushings, PCB Debris (PPE, rags, wood, paper,
gloves, etc. and empty PCB drums) and PCB Capacitors/Light Ballast.
3.6.1 Profile Approval Process (PCB-Only Wastes)
PCB only wastes are categorized according to one of the previous waste categories defined in this plan
and follow the profile approval process for that category. The profile also requires the generator to
certify that the waste is RCRA non-hazardous PCB-only as defined above.
3.6.2 Load Acceptance and Handling of Discrepancies (PCB-Only Wastes)
PCB-only wastes are categorized according to one of the waste categories identified in this plan and
follow the procedures for load acceptance and handling discrepancies as outlined for that category of
waste. In addition, PCB wastes will be identified by review of the manifest, shipping papers, visual
inspection, labels on containers, and the Waste Profile Sheet supplied by the generator. If regulated
PCBs are discovered in a waste whose profile did not identify PCBs as a contaminant, a manifest type
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 13 UTD 982595795
discrepancy will exist. The generator will be required to resolve the discrepancy. If the explanation
indicates that the waste should have been manifested as PCBs, the applicable portions of the 40 CFR §
761.215 shall be followed, which include filing a "Manifest Discrepancy Report.”
Also, during the incoming load evaluation:
-All PCB Containers, PCB Article Containers, and PCB Articles not in containers will be marked
with the appropriate PCB Mark (if not already marked by the generator) to comply with the
marking requirements of 40 CFR §761.40.
-Each PCB container from a shipment will be visually inspected to verify that it is not leaking. If a
leaking container of PCB waste is discovered during the inspection, it will be re-packaged or
overpacked to prevent further leakage. The spill area will be decontaminated in accordance with
40 CFR § 761 Subpart G. In addition, the transport vehicle bed will be inspected. In the case of
flatbeds or vans carrying PCB wastes, water or other free liquid found on the bed will be collected
and managed as PCB waste or treated as a PCB spill and cleaned in accordance with 40 CFR § 761
Subpart G.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 14 UTD 982595795
Table 2: Storage and Acceptance (Fingerprint) Analyses
Parameter Rationale for Selection
Physical Description
Used to determine the general characteristics of the waste stream. Also
used to ensure correct grouping of wastes for sampling. Also used to
detect discrepancies in waste types. Also used to determine which
waste characterization procedure will be used. Also used to determine
the percentages of the various material types in debris-like wastes.
pH Used to determine the corrosivity of the waste to ensure proper storage
of the waste.
Water Reactivity
Used to determine whether the waste has a potential to react with water
to generate heat, flammable gases, or other products. It is also used to
help identify prohibited wastes.
Reactive Sulfides
Screen
Used to indicate whether the waste produces hydrogen sulfide upon
acidification. This information is necessary to avoid storage and mixing
incompatibilities.
Ignitability
Indicates the susceptibility of the waste to be ignited. This information
is necessary to avoid placement or storage of the waste in inappropriate
areas.
Reactive Cyanides
Screen
Used to indicate whether the waste produces hydrogen cyanide upon
acidification. This information is necessary to avoid storage and mixing
incompatibilities.
Oxidizer Screen
A general qualitative test used to determine if a waste is an oxidizer.
Oxidizers have the potential to react with a wide range of waste streams
and therefore often need to be segregated.
Radioactivity Screen Used to help identify prohibited wastes.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 15 UTD 982595795
Table 3: Methods and Tolerance Limits
Parameter Limits Tolerance
Physical Description Shall be consistent with profile
Specific Gravity ± 20%
pH Screen + 3 pH units, as long the profile pH is >2 and < 12.5. If the
profile pH is < 2 or > 12.5, the incoming load sample must be
the same.
TLV-Sniff If > 200 ppm, and destined for landfill, flash point shall be
conducted. If TLV-Sniff is <200, the flashpoint is considered
> 140°F and it may be disposed in landfill. Shall be < 500
ppm if destined for storage or treatment in tanks.
Water Reactivity Screen No tolerance: load samples must agree with profile
Reactive Sulfides Screen 1Shall be consistent with profile
Reactive Cyanides Screen 1Shall be consistent with profile
Ignitability Shall be consistent with profile, i.e., if profile is reported as
being >140°F it must test >140°F.
Radioactivity Screen No tolerance: load samples shall be less than 40 microR/hr
over background unless authorization is obtained as described
in the Prohibited Materials section of this Attachment. No
explanation is required for wastes profiled with a positive
radioactive screen and arriving with a negative screen.
Oxidizer Screen 1Shall be consistent with profile
1 For negative to positive results, the generator shall be contacted for a qualitative explanation
of the difference. The answer shall be documented in the facility operating record.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 16 UTD 982595795
4.0 WASTE SAMPLING
This Section presents methods utilized to obtain a representative sample of wastes. These methods
apply to waste generated off-site as well as facility-generated waste. The specific sampling methods
selected are dependent on the nature of the waste and its container.
4.1 Sampling Locations
Samples, including incoming load samples, may be taken from a variety of locations throughout the
facility and from containers on the Clive rail spur. Waste may be sampled from drums, roll-off boxes,
rail gondola cars, rail tank cars, lugger boxes, tanker or dump-type trucks, etc., or from other locations
including containment areas.
4.2 Sampling Methods
The methods and equipment used for sampling vary with the form and consistency of the waste to be
sampled. The appropriate representative sampling techniques, devices, and containers are selected from
the EPA document, "Test Methods for Evaluating Solid Wastes" (SW-846) or "American Society for
Testing and Materials" (ASTM) methods. The approved methods are found in the most current copy of
40 CFR §261.11.
In order to determine the physical and chemical characteristics of a waste, a representative sample is
needed. A representative sample is defined as a sample exhibiting average properties of the whole
waste.
Sampling accuracy (the closeness of a sample value to its true value) and sampling precision (the
closeness of repeated sample values) are the issues of importance. Thus, from both regulatory and
scientific perspectives, the primary objectives of a sampling plan are to collect samples that allow
accurate and precise measurements of the physical and chemical properties of the waste. If the chemical
measurements are sufficiently accurate and precise, they are considered reliable estimates of the
chemical properties of the waste. Statistical techniques for obtaining accurate and precise samples are
relatively simple and easy to implement. Containers will be sampled in accordance with the sampling
SOPs. In random sampling, every unit in the population has a theoretically equal chance of being
sampled and measured. Consequently, statistics generated by the sample are unbiased (accurate)
estimators of true population parameters. In other words, the sample is representative of the population.
4.3 Traceability
Sample traceability for all internal sampling and analysis by documenting on a sample collection form
and laboratory analysis report. This involves the documentation of procedures so that a set of data can
be traced back through the analyst, to the person performing the sampling, and then to the waste itself.
All samples receive a unique sample identification number to facilitate this process.
4.4 Sampling Personnel
Trained personnel perform sampling in accordance with the sampling methods. The operations manager
or designee trains sampling personnel and observes their techniques periodically to ensure a thorough
understanding of sample collection, storage, and transportation practices.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 17 UTD 982595795
4.5 Sample Labels
Sample labels are necessary to provide identification of samples. The labels are affixed to the containers
prior to or at the time of sampling. The labels are filled out at the time of collection and contain the
following information:
- sample identification
- place of collection
- date and time of collection
- person sampling
4.6 Logbook
All information pertaining to sampling is recorded in a logbook, inspection or receiving report, or
electronically. This record includes the following information:
- location of sampling point
- volume of sample taken
- date and time of collection
- sample identification number
- person sampling
- comments or observations
- sampling methodology
- number of samples and physical state
Sampling situations can vary widely; however, sufficient information is recorded to allow someone to
reconstruct the sampling conditions without reliance on the collector's memory.
4.7 Sample Preservation
All samples are preserved in accordance with the parameter to be measured, as specified by the
analytical method for that parameter. Samples for fingerprint analyses are not preserved and have a
shortened holding time.
4.8 Sampling of Containers
The term "container" refers to receptacles designed for transporting materials, e.g., drums and other
small receptacles (<120-gallon capacity) and totes (<330 gallons) as opposed to stationary tanks. This
Section addresses the sampling of containers smaller than those carrying bulk materials. Sampling of
bulk materials in large containers such as rolloffs, tank trucks, rail cars, etc. is addressed in Section 4.9.
COLIWASAs, tubes, shovels, drum thieves, and triers are the devices used to sample containers.
A random sampling strategy is employed to sample incoming shipments of containerized waste.
Samples from containers holding the same type of waste may be composited. The following procedure
will be used to determine how many containers will be sampled and which samples may be composited.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 18 UTD 982595795
Each container will be opened and visually inspected. Wastes on a single load that have the same
profile number and DOT description) and appear to be of the same waste type may be grouped together.
Ten percent (rounded up) of the containers in each of these groups will be sampled as described below.
The samples within each separate group may be composited for analysis.
A unique tracking number is assigned to each container.
Samples are taken from locations displaced both vertically and horizontally throughout the waste. For
liquids (or liquids with precipitated solids), the sampling person uses a COLIWASA or equivalent. The
sampling device is inserted into the container from the top and is pushed down slowly until the bottom
of the container is reached. The device is sealed to retain the contents. The contents of the entire
sampling device are then transferred to a polyethylene or glass bottle, which is labeled with waste
identification information specified in Section 4.5
A trier, shovel or scoop is used to sample containers holding material that is solid. These containers are
generally filled with dirt and sludges. Several areas from the container are sampled and composited into
a clean bucket where it is mixed and put in a jar in order to ensure a representative sample. The
sampling person removes a sample that uniformly represents the waste composition of the container.
4.9 Sampling of Bulk Materials
Where sampling of bulk loads is required, each bulk container (100%) of each load will be sampled as
described below.
Bulk solids in roll-offs or end dumps shall be sampled at two locations in the waste container. A trier,
thief or shovel is used in order to draw a sample from as deep a cross section as possible at each of the
two locations. The samples are composited together so that there is one sample which represents that
particular bulk solids shipment.
Bulk liquids in a road tanker are sampled by using a COLIWASA or similar device which can sample
vertical anomalies. Bulk sludges are sampled with a device appropriate for the consistency of the
material. That may be a COLIWASA, trier, dip tube, thief, etc. Each compartment of tanker trucks is
sampled. Compartment samples from the same generator and waste stream may be composited prior to
analysis.
Tank trucks without man-ways are sampled through the valve. The valve is flushed prior to the sample
being drawn.
The analytical results from a sample from a bulk solid or bulk liquids rail car can be used as the
incoming load analysis for the roll-off boxes, end dumps or road tankers that receive waste from a
railcar. For example, a rail tanker is sampled, and the sample analyzed. The contents of the rail tanker
are then transferred to four road tankers for transport to the Aragonite facility. The analytical results
from the rail tanker may be used for the four road tankers received at the Aragonite facility.
4.10 Frozen Waste
Clive will not sample waste that is frozen. Loads may arrive at temperatures which prevent a
representative sample from being obtained. Under such circumstances, the waste will be allowed to
warm in accordance with the procedures described in Attachment 8, Container Management, until such
time as sampling can be performed. Loads that require thawing before sampling may be placed in the
Thaw Unit, Unit 105 while awaiting sampling. If an incoming load is placed in Unit 105 for thawing
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 19 UTD 982595795
prior to sampling (i.e., not yet accepted), it still must be sampled, and a decision made regarding
acceptance within the ten days of arrival at the facility. If an unaccepted load of waste is placed in Unit
105, the waste location must be documented in the operating record.
4.11 Other Samples
The sampling method for wastes in/on process equipment, containment and containment surfaces,
sumps, etc., will vary with the nature of the waste material and will be collected in accordance with this
Waste Analysis Plan based on the nature of the waste.
5.0 TEST METHODS
The test methods to measure the parameters discussed throughout this plan are identified in Table 3.
The Clive facility can conduct analysis at the site in the fingerprint area located in Unit 101. This area is
primarily used to analyze samples of waste associated with the decant operations located in this area.
This fingerprint area is classified as a Class C fire hazard laboratory unit under NFPA and shall meet all
applicable NFPA requirements. Whenever a waste sample and/or chemicals are present in a fume hood,
the exhaust fan shall be running, and the hood sash shall be positioned to ensure that the minimum
airflow is maintained.
Typically, incoming load samples and other samples are analyzed at Clean Harbors Aragonite, Clean
Harbors Grassy Mountain, the Clean Harbors Kimball facility, or other Utah-Certified off-site
laboratory. The samples shall be analyzed by a laboratory certified by the State of Utah for the
analytical methods specified in Table 3, including Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, SW-846, 3rd Edition, US EPA, 1986 and its updates; American Society for
Testing and Materials (ASTM); and EPA 600/4-79-020, Methods for Chemical Analysis of Water and
Wastes; Standard Methods for Examination of Water and Wastewater, Latest Edition; EPA 40 CFR,
136, Appendix A Methods; EPA Contract Laboratory Program, Inorganic SOW and Organic SOW
Methods. Where other practical methods are not available, methods have been developed by Aragonite.
These methods are described at the end of this section.
The letter following a method number indicates the SW-846 revision of that method. When new method
revisions are promulgated by the EPA, they will be implemented within six months of promulgation.
Thus, listed method numbers will remain constant, but suffixes (A, B, C, etc.) will depend on the latest
EPA revision. Utah-certified laboratories used by Aragonite may have the prior revision designation on
their certification as long as the method number reflects that listed in Table 3, analyses are actually
performed and reported according to the latest revision, and the lab has applied for, and provided all
necessary information to obtain certification for the new revision. If a lab has not yet implemented the
update within the six months and it is necessary to use that laboratory, Aragonite may provide
justification for using that lab and request a variance from the Director.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 20 UTD 982595795
Table 4: Analytical Parameters and Associated Methods
Parameter Method
Number Reference
*Acid-Base Partition Cleanup 3650B (1)
Acid Digestion of Sediments, Sludges, and Soils 3050B (1)
Acid Digestion of Aqueous Samples and Extracts for Total Metals for
Analysis by Flame Atomic Absorption Spectroscopy or Inductively
Coupled Plasma Spectroscopy
3010A-MOD (1)
Acid Digestion of Aqueous Samples and Extracts for Total Metals for
Analysis by Furnace Atomic Absorption Spectroscopy 3020A (1)
*Alumina Column Cleanup 3610B (1)
Aluminum (ICP) 6010D (1)
Antimony (ICP) 6010D (1)
Aromatic Volatile Organics 8020A (1)
*Aromatic and Halogenated Volatile Organics 8021B (1)
Arsenic (ICP) 6010D (1)
*Arsenic (AA) 7061A (1)
Ash D482-87 (2)
Atomic Absorption Spectroscopy 7000B (1)
Barium (ICP) 6010D (1)
Beryllium (ICP) 6010D (1)
Bromide 9056A (1)
Cadmium (ICP) 6010D (1)
Calcium (ICP) 6010D (1)
*Carbamate pesticides (LCMS) 8321B (1)
Chloride 9253 (1)
Chloride (Ion Chromatography) 9056A (1)
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 21 UTD 982595795
Parameter Method
Number Reference
Chlorinated Herbicides 8151A, 8151-
MOD (1), (1)
Chromium (ICP) 6010D (1)
Cobalt (ICP) 6010D (1)
Copper (ICP) 6010D (1)
*Continuous Liquid-Liquid Extraction 3520C (1)
Fluoride (Ion Chromatography) 9056A (1)
Fluoride 340.2, 5050 (3), (1)
Florisil Column Cleanup 3620C (1)
Gas Chromatography 8000D (1)
Gas Chromatography/Mass Spectrometry for Volatile Organics 8260C (1)
Gas Chromatography/Mass Spectrometry for Semi-volatile Organics 8270D (1)
*Gel-Permeation Cleanup (GPC) 3640A (1)
Heat of Combustion (BTU) D240-87-MOD (2)
Ion Chromatography 9056A (1)
Ignitability Liquid, actual flashpoint, no suspended solids 1020B, 1010A (1)
Ignitability Liquid, at 140ºF, no suspended solids 8b (4)
Ignitability Liquid, room temperature D4982-89 (2)
Ignitability Liquid, actual flashpoint, suspended solids (sludge) 1010A (1)
Ignitability Sludge, at 140ºF 8b (4)
Ignitability Solids, room temperature D4982-89 (2)
Ignitability Solids, at 140ºF 1020B-MOD (1)
Iron (ICP) 6010D, 6010B,
6010C, 6020A (1)
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 22 UTD 982595795
Parameter Method
Number Reference
Lead (ICP) 6010D, 6010B,
6010C, 6020A (1)
LEL 14 (4)
Liquids, Sludge Compatibility (see note 3) D5058-90 Test
Method A (2)
Magnesium (ICP) 6010D (1)
Manganese (ICP) 6010D (1)
Mercury Cold Vapor (AA) 7470A, 7471B (1)
Microwave Assisted Acid Digestion of Aqueous Samples and Extracts 3015A (1)
Microwave Assisted Acid Digestion of Sediments, Sludges, Soils and
Oils 3051A (1)
Moisture (organic liquids) D1533 (2)
Moisture (Inorganics) 2540B (5)
Molybdenum (ICP) 6010D (1)
Nickel (ICP) 6010D (1)
Nitrate/Nitrite Ion Chromatography 9056A (1)
Nitrogen, Total 351 (1)
Nonhalogenated Volatile Organics 8015C (1)
Organic Extraction and Sample Preparation 3500C (1)
Organochlorine Pesticides 8081B (1)
*Organophosphorus Compounds by Capillary Column GC 8141B (1)
Oxidizer Screen D4981-89 (2)
Paint Filter 9095B (1)
*PCDD 8280B, 8290A (1)
*PCDF 8280B, 8290A (1)
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 23 UTD 982595795
Parameter Method
Number Reference
PCBs 8082A (1)
*PCB and Pesticides (GC/MS) 80801B, 8082A (6)
PCB Wipes 40§761.123,
8082A n/a
pH Electrometric 9040C (1)
pH Paper 9041A (1)
pH Waste 9045D (1)
pH Solids 9045D (1)
Physical Description D4979-89 (2)
Potassium (ICP) 6010D (1)
Purge-and-Trap 5030C (1)
Radioactivity Screen 6 (4)
Reactive Cyanide Screen (Spot Test) Confirmation (see note 2) D5049-90 Test
Method A (2)
Reactive Cyanide Screen (Drager) Prime (see note 2) D5049-90 Test
Method D (2)
Reactive Sulfide Screen (Spot Test) Confirmation (see note 2) D4978-89 Test
Method A (2)
Reactive Sulfide Screen (Drager) Prime (see note 2) D4978-89 Test
Method B (2)
Selenium (ICP) 6010D (1)
Separatory Funnel Liquid-Liquid Extraction 3510C (1)
Silica Gel Cleanup 3630C (1)
Silver (ICP) 6010D (1)
Sodium (ICP) 6010D (1)
Sonication Extraction 3550C (1)
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 24 UTD 982595795
Parameter Method
Number Reference
Soxhlet Extraction 3540C (1)
Specific conductance 9050A (1)
Specific Gravity D1429-86-MOD (2)
*Sulfides 9030B, 9031 (1)
Sulfate Ion Chromatography 9056A (1)
*Sulfur D1266-87 (2)
Sulfur Cleanup 3660B (1)
Sulfuric Acid Cleanup 3665A (1)
Thallium (ICP) 6010D (1)
Tin (ICP) 6010D (1)
TCLP 1311 (1)
Total and Amenable Cyanide (Colorimetric, Manual) 9010C (1)
*Total and Amenable Cyanide (Colorimetric, Automated UV) 9012B (1)
Total Organic Carbon 9060A (1)
Total Halogen 5050, 9253 (1)
Vanadium (ICP) 6010D (1)
Viscosity D2983-87 (2)
Waste Dilution 3580A (1)
Water Reactivity Screen (see note 1) D5058-90 Test
Method C (2)
Zinc (ICP) 6010D (1)
* Non-Aragonite laboratory only
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 25 UTD 982595795
TABLE 4: References for Analytical Parameters and Associated Methods
(1) Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication
SW-846 [3rd Edition (November 1986), with current updates]
(2) American Society for Testing and Materials
(3) Methods for Chemical Analysis of Water and Wastes, EPA 600/4-79-020
(4) Aragonite Methods, when Aragonite methods are modified, Clive must modify their permit
to reflect the changes.
(5) Standard Methods for the Examination of Water and Wastewater, Latest Edition, APHA,
WEF
(6) Alford-Steven, A.; Eichelberger, J.W. and Budde W.L. Method 680. Determination of
Pesticides and PCBs in Water and Soil/Sediment by Gas Chromatography/Mass
Spectrometry. Physical and Chemical Methods Branch. Environmental Monitoring and
Support Laboratory Office of Research and Development. U.S. EPA, Cincinnati, Ohio
45268. November 1985.
NOTES FOR REACTIVITY SCREENS:
1. A significant temperature change as called out in paragraph 24.8 of ASTM method D5058-90 is
defined as ≥15ºC. The test does not apply to wastes already in contact with excess water, nor is a
wastewater reactive if the heat generation is due solely to a strong acid/base reaction as verified by
pH analysis. Occurrence of the reactions listed in paragraph 24.4 of ASTM method D5058-90 result
in failure of the water reactivity test, except that formations of precipitates or emulsions are
considered failures only if the ability to mix and pump the resulting liquids is impaired.
2. The test is not required for wastes with pH <6.
3. A temperature rise as called out in paragraph 11.8 of ASTM method D5058-90 is defined as ≥15ºC.
Occurrence of the reactions listed in paragraph 11.7 of ASTM method D5058-90 result in failure of
the compatibility test, except that formations of layers, precipitation, emulsification, or increases in
viscosity are considered failures only if the ability to mix and pump the resulting liquids is impaired.
ARAGONITE METHODS
Radioactivity Screen (Aragonite-6)
All incoming waste shipments will be monitored for radioactivity using a count rate meter with a
Geiger-Mueller (GM) detector. The detector window shall have at least a 2.54 centimeters diameter
opening utilizing window material of approximately 1.7 milligrams per square centimeter. The detector
shall be operated in accordance with the manufacturer's recommended procedures. Detectors shall be
calibrated at least annually and after repair.
The detector window shall be placed within one (1) inch (but not in contact) of the sample surface of
bulk materials until a steady, time weighted count rate is obtained. Three (3) measurements shall be
taken of each sample and recorded.
Attachment 1 -- Waste Analysis Plan DRAFT June 2024
Clean Harbors Clive, LLC Page 26 UTD 982595795
Results of surveys are to be recorded in terms of counts per minute. Any waste found to have a count
rate exceeding background by three (3) times or greater for any measurement shall not be accepted
without receiving authorization from the Division of Waste Management and Radiation Control. A
background reading shall be taken for each sampling day prior to each sample event and the
measurement recorded.
Ignitability Screen for Sludges (Aragonite-8b)
The ignitability screen for sludges is determined using a modified version of EPA SW-846 Method
1010. Instead of an actual flash point determination as outlined in the 1010, the sludge is heated in the
test cup to 140˚F. When the temperature in the cup reaches 140˚F, the flame is applied to the sample. A
flash/no-flash measurement is determined and recorded as positive or negative. The instrument is
calibrated daily at 100o F and 140 o F.
LEL (Aragonite 14)
This method is used for the determination of the presence of explosive vapors dissipating from a waste.
A quantitative result in % LEL is indicated on the instrument.
Containers of waste are opened enough to insert the probe. The instrument pulls any vapors above the
waste into the detectors. Sufficient time must be allowed to clear the air from the sample line. The
container is sampled immediately after opening. The probe inlet is placed close to, but not touching, the
waste in the container. The result in % LEL is recorded in the logbook. Care must be exercised to
ensure that drafts are avoided in the area that is being sampled as this can cause an erroneous result. The
test is not to be run on materials that will poison the detector.
The instrument will be calibrated according to the procedures and at the frequency specified by the
manufacturer. It will be operated according to the instructions provided by the manufacturer. Daily
sensitivity checks and continuing sensitivity checks every twentieth sample will be conducted. The test
will not be run with an instrument that is not functioning correctly.