2540-PM-BWM0001 6/2005
Instructions
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF WASTE MANAGEMENT
INSTRUCTIONS FOR COMPLETING
FORM R1 - WASTE ANALYSIS AND CLASSIFICATION PLAN
FOR PROCESSING FACILITIES AND BENEFICIAL USE
Important: Read all instructions carefully before
completing the attached form.
at the time that the waste is being proposed for
processing at the facility.
Instructions: Complete the attached form and provide
the Waste Analysis and Classification Plan addressing
all of the following requirements. The plan should begin
on the attached form and continue on 8½ x 11 sheets of
paper which should be attached to the form.
Processing Facilities
In addition to parameters required on Form 26R for the
gross analysis, trace analysis, and hazardous waste
determination of the waste, constituents in the waste
which contribute to the processing of the waste or may
limit the processing of the waste should be determined.
The plan shall address all of the requirements set forth
which are applicable to the processing facility or
beneficial use. These requirements relate to three
general areas:
Beneficial Use
In addition to parameters required on Form 26R for the
gross analysis, trace analysis, and hazardous waste
determination of the waste, constituents in the waste
which contribute to the beneficial use of the waste or
may limit the beneficial use of the waste should be
determined. For any beneficial use involving placement
of the residual waste directly onto the land, the additional
parameters for Class III residual waste landfills found in
the instructions to Form U shall be included.
1. Sampling and analytical procedures and rationale
which will be employed to determine whether a
waste is acceptable for management at the
processing facility or for the beneficial use.
2. Screening and management procedures for
incoming waste which will be used on a daily basis
to ensure that the incoming waste is reasonably
consistent in content with the waste as it was
originally approved.
Test Methods
This plan shall include the test method(s) to be used for
each parameter. The analytical methodologies used
shall be those set forth in the most current edition of the
EPA's Test Methods for Evaluation Solid Waste (EPA
SW-846), Methods for Chemical Analysis of Water and
Wastes (EPA600/4-79-020), Standard Methods for the
examination of Water and Wastewater (prepared jointly
by the American Public Health Association, American
Waterworks Association, and Water Environment
Federation), or a comparable method subsequently
approved by the Department.
3. Methodology (including specific numerical limits)
which will be used to determine whether a waste is
acceptable for management at the processing facility
or for the beneficial use. This will address any of the
following, if applicable: waste/leachate compatibility
(with other wastes, facility liner or pad, process
equipment, and the process), storage, and
groundwater protection.
Sampling and Analytical Procedures: The plan shall
specify each parameter for which the waste will be
analyzed as well as the rationale for selection of that
parameter. Analysis shall include the requirements of
Form 26R unless, on a case-by-case basis, the
generator certifies in writing the absence of the
constituent based on his or her knowledge of the
process which generated the waste. Also, based on this
same knowledge, it may be necessary to include
additional parameters not listed in the instructions to
Form 26R. For each waste type proposed to be
managed at the facility or to be beneficially used, these
additional parameters should be specified. For some
generator-specific wastes which could be proposed for
processing at the facility in the future but which are not
included under a previously approved waste type, it may
be necessary to include other parameters. These
should be included in the analysis provided with Form U
Reanalysis Frequency
This plan shall also include a discussion concerning the
frequency with which the sampling and analysis of any
waste will be repeated or reviewed to ensure that the
original analytical data are accurate and up-to-date. The
rationale for the specified frequency shall be clearly
explained.
Sampling Methodology
The plan shall include an explanation of the sampling
methods that will be used to obtain accurate and
representative samples of the waste to be analyzed,
including quality assurance and quality control
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2540-PM-BWM0001 6/2005 INSTRUCTIONS FOR COMPLETING FORM R1, continued
procedures employed in the field.
A discussion
concerning the manner in which temporal and spatial
variability of each waste will be addressed (especially in
terms of numbers of samples needed and statistical
tests to be employed to define variability) should be
included.
tanks, and other components of the processing
equipment. These limits may be based on actual
testing or, in lieu of testing, existing published or
documented data on the waste or waste generated
from similar processes. Testing protocols and use of
existing published or documented data is subject to
Department approval.
Screening of Incoming Waste: The plan shall include a
description of the method or procedure to screen
incoming waste daily to ensure that the waste is
reasonably consistent in content with the waste as it was
originally approved. The procedure shall, at a minimum,
be applied to each waste load as it is received at the
processing facility or prior to being beneficially used and
shall include a check of the waste's color, physical state,
and phases. These characteristics shall be compared
with those specified on the Form U or Form 26R which
was originally approved.
Additional screening
parameters may include texture, density, particle size
(determined visually), or spectroscopic examination of
the waste.
Since these screening parameters are very subjective, a
procedure to determine whether a waste meets or fails
should be included. In addition, for a waste which is
rejected based on the screening procedure, a
description of the manner in which the rejected waste
will be managed shall be included in the plan. This
description shall include, as applicable, additional
sampling and analysis which may be necessary to
determine that the waste is the same waste that was
originally approved (or meets the limitations for that
waste type), names of responsible persons and
municipalities, and the method by which an alternative
waste management facility will be selected (if the waste
is rejected).

Concentration limits in the waste which can be
adequately processed in the processing system in a
manner that will protect public health, safety, and the
environment. These limits may be based on actual
testing or, in lieu of testing, existing published or
documented data on the waste or waste generated
from similar processes. Testing protocols and use of
existing published or documented data is subject to
Department approval.

For those contaminants for which the hazardous
waste
Toxicity
Characteristic
applies,
the
concentration limit shall be less than the Maximum
Concentration of Contaminants for the Toxicity
Characteristics (as listed in Table 1 of 40 CFR
Part 261).
For pH, ignitability, and reactivity, the hazardous waste
limits in 40 CFR Part 261, as incorporated by reference
at 25 Pa. Code 261a.1, shall be set forth.
In order to determine whether a waste and/or its
leachate is compatible with any other waste or leachate
already existing at the facility, either a laboratory
compatibility test protocol or a description of how such
compatibility will be ensured shall be set forth. The
procedure set forth in EPA's "A Method for Determining
the Compatibility of Hazardous Wastes" (EPA-600/2-80076) or other equivalent method approved by the
Department may be used,
Waste Acceptance Procedure: The purpose of this
procedure is to quickly and easily determine the
acceptability of a waste at a processing facility or for the
beneficial use by allowing a detailed comparison of the
waste characteristics (which may be submitted with
Form U for specific waste streams) with maximum
allowable levels (which are based on process limitations,
waste and liner compatibility, protection of groundwater,
and protection of human health and the environment
from harm or threat of harm).
Beneficial Use
For each parameter or contaminant which may be
applicable to or exist in any waste (or its leachate) which
may be beneficially used, the following limits shall be set
forth:

Concentration limits in the waste/leachate which will
adequately ensure the integrity of the liner, pad,
tanks, and other components or any storage
equipment. These limits may be based on actual
testing or, in lieu of testing, existing published or
documented data on the waste or waste generated
from similar processes. Testing protocols and use of
existing published or documented data is subject to
Department approval.

Concentration limits in the waste which can be
beneficially used in a manner that will protect public
health, safety, and the environment. These limits
may be based on actual testing or, in lieu of testing
The following discussion sets forth the information which
shall be included in the waste acceptance procedure.
Processing Facilities
For each parameter or contaminant which may be
applicable to or exist in any waste (or its leachate) which
may be processed at the facility, the following limits shall
be set forth:

Concentration limits in the waste/leachate which will
adequately ensure the integrity of the liner, pad,
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2540-PM-BWM0001 6/2005 INSTRUCTIONS FOR COMPLETING FORM R1, continued
existing published or documented data on the waste
or waste generated from similar processes. Testing
protocols and use of existing published or
documented data is subject to Department approval.
For beneficial use where the waste is proposed to
be used as a construction materia1, soil substitute,
soil additive, antiskid material, or otherwise placed
directly onto the land, the concentration limits shall
not exceed the requirements of 25 Pa. Code
288.623(a) (relating to minimum requirements for
acceptable waste).

For pH, ignitability, and reactivity, the hazardous waste
limits in 40 CFR Part 261, as incorporated by reference
at 25 Pa. Code 261a.1, shall be set forth.
Transfer Facilities: The plan for transfer facilities shall
include all applicable requirements for other processing
facilities. In addition, the plan shall include a procedure
to ensure that the facility destined to accept any waste
shipped from the transfer facility has the approval of the
appropriate regulatory agency to manage the waste. If
different waste types are consolidated at the transfer
facility, the plan shall address a procedure to ensure
each waste type has the necessary approval for
management at the destination facility.
For those contaminants for which the hazardous
waste
Toxicity
Characteristic
applies,
the
concentration limit shall be less than the Maximum
Concentration of contaminants for the Toxicity
Characteristics (as listed in Table 1 of 40 CFR
Part 261).
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Date Prepared/Revised
2540-PM-BWM0001
6/2005
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF WASTE MANAGEMENT
DEP USE ONLY
Date Received
FORM R1
WASTE ANALYSIS AND CLASSIFICATION PLAN
FOR PROCESSING FACILITIES AND BENEFICIAL USE
This form must be fully and accurately completed. All required information must be typed or legibly printed in the spaces
provided. If additional space is necessary, identify each attached sheet as Form R1, reference the item number and identify
the date prepared. The “date prepared/revised” on any attached sheets needs to match the “date prepared/revised” on this
page.
SECTION A. SITE IDENTIFIER
Applicant/permittee:
Site Name:
Facility ID (as issued by DEP):
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