Strategy:  Utilize Statistical Waste Analysis Plans to Minimize Sampling and Analysis Requirements

Candidates:  Consistent, High Volume Waste Streams

Potential Cost Savings:  $25,000 to Greater than $100,000 per Year

Facilities having hazardous waste combustion units are required to develop and comply with Waste Analysis Plans (WAPs) and Feedstream Analysis Plans (FAPs). The written WAPs and FAPs are required to contain the sampling and analysis procedures that facilities use to treat, store, and/or dispose of hazardous waste in compliance with regulatory and permit requirements. The facilities typically sample and analyze each batch of material to be burned in the combustion unit in order to demonstrate compliance. Many facilities have the option to use a statistical approach that does not require the costly sampling and analysis of each batch of material to demonstrate compliance.

The statistical approach uses the Upper Tolerance Limit (UTL) method of statistics in the waste and feedstream analysis process. The statistical approach yields a process of analysis that includes an outlier analysis, normality analysis, UTL calculation, maximum feed rate analysis, and a sampling and analysis frequency. The UTL methodology can be incorporated into a WAP or a FAP, and easily implemented using a computer spreadsheet.

Incorporating statistics into a WAP/FAP can result in considerable cost savings for a facility. For a facility that is currently analyzing each batch of material prior to burning, a reduction in sampling and analysis would be realized. Depending on the confidence level used for the UTL determination, a minimum of 2 and a maximum of 19 samples per year would be required. The higher the confidence level, the lower the number of samples required. Therefore, for the most consistent streams, a significant reduction in the number of samples and analyses would be realized.

Owing to the high costs associated with sampling and analysis, the statistical method provides a cost-effective alternative to demonstrating compliance. Waste/Feedstream Analysis Statistical Programs are smart compliance strategies.