The United States Environmental Protection Agency ("EPA") is seeking public comments on a revision to "Waste Analysis at Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual." The guidance manual was last updated in 1994. The current version of the guidance manual (dated January 2013) is available here.

The manual provides guidance on how to develop and implement a Waste Analysis Plan in accordance with the Resource Conservation and Recovery Act ("RCRA"). The primary audiences for the manual are hazardous waste generators and owners/operators of treatment, storage, and disposal facilities ("TSDFs").

EPA has identified the following areas as in particular need of clarification in the revised guidance manual:

  • Design of characterization studies;
  • Recharacterization frequency;
  • How to address issues of waste variability;
  • Establishing and employing data quality objectives;
  • Selection of indicator parameters to reduce testing costs;
  • Measurement uncertainty; and
  • Using statistical concepts to guide the characterization process.

The EPA is inviting operating TSDFs, permit writers, trade associations, and environmental groups to provide comments on the updated guidance. EPA will accept comments through April 30, 2013. More information is available on the EPA website.