Waste Analysis Plans (WAPs) for Hazardous Waste Management (TSDF's)

A waste analysis plan serves to standardize and optimize the required testing of wastes so that all wastes at a site are properly characterized prior to disposal in a simple and efficient manner. A waste analysis plan establishes the characterization frequency and analytical requirements to be satisfied for every identified waste at the installation and provides guidance for handling new wastes. Therefore, the plan helps facilities comply with the requirements under RCRA 40 CFR 262.11 which requires persons who generate solid waste to determine if their waste is hazardous. In addition, the plan helps to ensure that non-hazardous waste are properly classified as non-hazardous. This may allow facilities to reduce their generator status and lessen the amount of regulations (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) they are required to comply with under RCRA, 40 CFR 262.

1. Responsibilities for Characterization Prior to Disposal: The personnel who make decisions regarding waste characterization and disposal must be trained in the regulatory requirements of the Resource Conservation and Recovery Act (RCRA), and must know who establishes and enforces those regulations in the generator's location. The applicable hazardous waste regulatory program could be operated by a regional office of the Environmental Protection Agency (EPA) or by an EPA-approved state agency. In this data sheet, only references to federal regulations are provided. However, additional or alternative state regulations may apply. All state programs have the same basic regulatory requirements as the federal program but should be consulted prior to establishing any procedures.

management personnel must understand the details of the characterization requirements described below so that required testing and analysis can be integrated into the waste analysis plan. In addition to determining whether a waste is covered by RCRA hazardous waste regulations, characterization must determine available waste disposal options (neutralization or other treatment, landfilling, incineration).

For waste that requires sampling and testing to determine its characteristics, the following information must be developed:

2. Characterization by Generator Knowledge of a Listed Hazardous Waste: The circumstances associated with the generation of each waste determine what means of characterization is required. First, the waste must fit the definition of solid waste stated in 40 CFR 261.2 and not fit the definition of any exclusions listed in 40 CFR 261.4. Excluded wastes may be covered by other regulatory programs, or may be allowable in the municipal solid waste stream if not prohibited by the local solid waste ordinance. Also, Appendix I of 40 CFR 260 includes diagrams for generators to use as a basic reference to determine whether their operation is subject to control under RCRA Subtitle C rules. It is designed to help generators identify applicable regulations and waste-handling requirements. 

If a waste is a solid waste (by RCRA definition), it may be a "listed hazardous waste," as specifically defined in 40 CFR 261 Subpart D (Parts 261.30 through 261.35). If the waste meets the definition of a listed hazardous waste, based on the process or circumstances of generation, then documented generator knowledge may be enough for sufficient characterization to satisfy all disposal requirements. This applies to mixtures of listed hazardous waste and non-hazardous waste (per 40 CFR 261.3 [a] [2]), and also to a waste that is derived from a listed hazardous waste (per 40 CFR 261.3 [c] [2]). An example of a derived waste is the ash that remains after a listed hazardous waste that is burned.

Each individual listed hazardous waste is assigned one or more waste type designations, based on the criteria of being ignitable (I), corrosive (C), reactive (R), toxicity characteristic (E), acutely hazardous (H), or toxic (T). Based on these characteristics, EPA specifies four hazardous waste lists, described below.

List Name Designation 40 CFR Citation
Non-specific Source Wastes

F List


Specific Source Wastes

K List


Discarded Commercial Chemical Products - Acutely Hazardous

P List


Discarded Commercial Products - Hazardous

U List


To determine if a specific waste is included in one of these lists, the lists provided in 40 CFR Part 261 must be referenced. Acute hazardous waste includes not only the "P List" waste chemicals, but selected "F List" waste types marked in the regulation with an (H). (Note that rules for accumulating waste often have specific requirements to address acutely hazardous waste.) The waste analysis plan should include an updated description of each specific source of listed hazardous wastes generated at the installation.

3. Characterization by Sampling and Analysis of a Characteristic Hazardous Waste: If a waste is a solid waste (by RCRA definition), but does not meet the definition of any of the "listed hazardous wastes," it may still be considered a hazardous waste if the material exhibits any of the characteristics as defined in 40 CFR 261 Subpart C (Parts 261.20 through 24). Sampling and testing are required to determine the following hazardous characteristics:

The suggested sampling procedures to create a representative sample of different specific waste forms (such as drummed liquid, saturated soil, etc.) are provided in an EPA guidance manual titled Test Methods for Evaluating Solid Wastes, EPA document SW-846. The specific analytical laboratory testing methods for each hazardous characteristic are specified in 40 CFR 261 Subpart C by specific references to SW-846.

To develop a waste analysis plan, a standard method of sampling and laboratory analysis for each waste should be selected based on the guidance provided in SW-846 (or other applicable EPA guidance manuals) and the background knowledge of the generator. Every analysis does not have to be performed for every waste if the generator can provide documented support that certain compounds are unlikely to be present.

4. Determining the Frequency of Characterization: Per 40 CFR 264.13 (a)(3), "Waste analysis must be repeated as often as necessary to ensure that it is accurate and up to date." This means that an analysis of a waste is necessary whenever any of the following circumstances occur:


Points of Contact:
RCRA hotline
Phone: (800) 424-9346

Hazardous Technical Information Services (HTIS)
Phone: (800) 848-4847 or (804) 279-5168
DSN: 695-5168

Methods Information Communication Exchange (MICE) Hotline (SW-846 test methods)
Phone: (703) 676-4690
Fax: (703) 903-1373
Email: [email protected]

Free waste analysis plan guidance:

Vendors: This is not meant to be a complete list, as there may be other suppliers of this type of information.

A guide for developing a formalized, installation-specific waste analysis plan is available through the National Technical Information Service (NTIS) [Phone: (800) 553-6847] or the U.S. Government Printing Office [Phone: (202) 512-1800]. Request the EPA Guidance Manual: Waste Analysis At Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes, Document Number PB94-963903, April 1994.

The EPA guidance manual titled Test Methods for Evaluating Solid Wastes, EPA document SW-846, is available through the U.S. Government Printing Office [Phone: (202) 512-1800]. Technical questions on SW-846 test methods may be addressed via the MICE Hotline at [Phone: (703) 676-4690

WAP Q&A (From the RCRA Hotline)

RO 12376
RCRA/Superfund/OUST Hotline Monthly Report Question
March 1985

Waste Analysis Plan

4. If an owner/operator of an interim status or permitted treatment, storage, or disposal facility (TSDF) accepts hazardous waste from small quantity generators, must he address that waste in his waste analysis plan required under 265.13 (for interim status facilities) or 264.13 (for permitted facilities)?

No; the owner/operator would not have to address the wastes from small quantity generators in his waste analysis plan. Sections 265.1(b) and 264.1(b) state that all of the Part 265 and 264 standards do not apply if otherwise excluded in Sections 265.(1)(c) or 264.(1)(f) and (g) or in Part 261. Section 261.5(b) states that a small quantity generator's hazardous wastes are not subject to regulation under Parts 262-265 and Parts 270 and 124 if the small quantity generator complies with the 261.5 standards. Hence, hazardous wastes from small quantity generators in compliance with 261.5 are not subject to Part 265 or 264 standards, including 265.13 and 264.13 for waste analysis.