Metal Finishing Guide Book


Issue link:

Contents of this Issue


Page 694 of 843

Table 2. Typical Delisting References pdf Guidance for Quality Assurance Project Plans - EPA QA/G-5, EPA/240/R-02/009, December 2002 User's Guide Delisting Risk Assessment Software (DRAS) Version 3.0, October 2008 Delisting Risk Assessment Software RCRA Hazardous Waste Delisting: The First 20 Years, U.S. EPA, Office of Solid Waste, June, 2002 URL Document Title EPA RCRA Delisting Program Guidance Manual for the Petitioner, US EPA, March 23, 2000. Steps 1 and 2 — Identifying Constituents of Concern. There is perhaps no other step in securing a delisting that is more important than identifying the constituents of concern (COC). The process involves reviewing a number of regulatory lists (e.g., Appendix VIII and Appendix IX)iii to determine if a given constituent is in the subject waste. For one list of chemicals in particular, Appendix VIII, it is difficult to identify all of the chemicals on the list because either standard methods do not exist, or the procedure is incredibly expensive, or the method will not work in the matrix of the waste sample. Either way, it will be important to establish with the regulatory authority the total universe of chemicals to include in your review. One thing the petitioner (the entity conducting the delisting is termed the petitioner) should keep in mind is that it is your responsibility to provide a complete and thorough characterization of your waste. Ultimately, it is not uncommon for the petitioner and the agency to settle on analyzing for all constituents (~ 222 chemicals) on Appendix IX. An important document that the petitioner must prepare is the Sampling and Analysis Plan (SAP). The SAP lays out specifically what will be analyzed for, the number of samples, the analytical techniques, and 683

Articles in this issue

Links on this page

view archives of Metal Finishing Guide Book - 2013