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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 data analysis methods that will be used. The SAP is a living document in that the petitioner and the agency will probably go through several iterations before a final SAP will be produced. You cannot proceed with the overall process until you have an agreed upon SAP. There are lists of chemicals that are expected to characterize certain wastes (e.g., petroleum refinery wastes) and those chemicals should be incorporated into your SAP. Steps 3, 4, and 5 ��� Engineering Analysis, Generator Knowledge and Identifying Analytes. There are several additional ways to modify the COCs list. One way is to conduct an engineering analysis that essentially involves conducting a mass balance around major process units at the facility undergoing the delisting. This is typically done by using a plant���s chemical management system to assemble the list of potential inputs to a process. Essentially you take a process unit and treat it as a black box with chemical inputs, and product, and waste outputs. Material Safety Data Sheets (MSDSs) are extremely useful in conducting this phase of the analysis. By lining up the constituents, as displayed on an MSDS, you can approximate a mass balance around a given process unit. An example of this is provided in Figure 1. As with the characterization of any RCRA waste, the petitioner can use generator knowledge to add to or subtract from the COC list. Frequently, generator knowledge is the best type of information to use in making a determination as to what to test for or what not to test for. For example, a person familiar with a plant���s layout will likely be able to know quite quickly rather or not a particular waste flows into a sewer pipe that eventually makes it to the WWTP. You are now at a point where the list of COCs should be fairly complete and you have identified all analytes that may be in the waste. Steps 6 and 7 ��� Select Analytical Methods and Prepare QAPP. The standard reference for collecting and analyzing waste samples is the series of some 200 methods referred to as SW 846. iv This again is a very important point of coordination with the agency so that everyone is on the same page when it comes to not only what is being analyzed for but how it will be determined. What method is selected can frequently determine the sensitivity of the final analytical result. For example, you would want to select a method that had a reporting limit of 0.001 mg/l over one that had a limit of 0.1 mg/l if the point for comparison from the risk assessment model (see later section on the use of the DRAS model) was 0.01 mg/l. In conjunction with selecting the analytical methods it is also very important to decide upon the quality assurance and quality controls that will accompany each piece of data. A Quality Assurance Project Plan (QAPP) describes the activities of an environmental data operations project involved with the acquisition of environmental information whether generated from direct measurements activities, collected from other sources, or compiled from computerized databases and information systems.v The QAPP documents the results of a project���s technical planning process, providing in one place a clear, concise, and complete plan for the environmental data operation and its quality objectives and identifying key project personnel. 729

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