There is a little known database in EPA’s website that addresses hazardous waste management issues. It is the RCRA-online database. It stores hundreds of guidance documents prepared by EPA over the program’s 29-year history. If you go to the database and type in your keywords, you may just find a few guidance documents prepared by EPA on your topic.
Below is an example of an EPA guidance document on the subject of representative sampling under RCRA:
A company wanted to dispose of a large number of fluorescent tubes in 1995. It sent one spent fluorescent tube to a laboratory for TCLP (Toxic Characteristic Leaching Procedure) analysis. The result came back indicating that the one tube “passed” the TCLP test – meaning none of the regulatory levels for the 40 chemicals on the TCLP list was exceeded. The company wrote to EPA to ask if it could then dispose of its entire inventory of spent tubes as non-hazardous waste.
EPA wrote back and told the company that the one tube that was tested was not a representative sample of the entire inventory of spent tubes. The sampling had to take into account the different brands, the various ages of the tubes, and different wattages, etc. The EPA letter is one of the Faxback documents (Faxback 11907) that you can obtain from RCRA online.